January 28, 2013

Jason M. Coite
University of Connecticut – Office of Environmental Policy
31 LeDoyt Road, U-3055
Storrs, Connecticut 06269

Regarding: UCONN EIE for Potential Sources of Water Supply

Dear Mr. Coite,

I am submitting comments on the EIE for additional sources of water supply on behalf of the Connecticut River Watershed Council.

The Connecticut River Watershed Council (CRWC) is a nonprofit organization established in 1952 to advocate for the sustainable use of the Connecticut River throughout the entire four-state watershed that is home to more than 2.5 million people. We work to conserve, protect and restore water quality and quantity, habitat and recreational access within the Connecticut River watershed.

As the Lower River Steward, I regularly comment on planned development, permitted activities and standards affecting the health of the watershed. In this case two of the three preferred alternatives are proposed diversions from important subwatersheds of the larger Connecticut River system.

Understandably, what many feel is most concerning about this proposal are the potential long-term impacts of continuing to stress our water resources and adding the precedent of transferring that water to areas of pronounced development and increasing population.

Though the Watershed Council has a documented history of opposing certain inter-basin transfers, we do not oppose them out of hand. Rather, we consider inter-basin transfers to be significant proposals which require an objective way to measure the relative impacts of alternatives, a thorough decision making process, early communication with stakeholders, robust information, creative thinking when outlining alternatives and adequate time to come to the best possible alternative. We also believe that any entity seeking an inter-basin transfer (or any increase in water supply for that matter) demonstrate they have implemented thorough water conservation and demand management programs.

In summary, we ask you to consider the following:

  • This inter-basin transfer highlights the fact that the state has not yet completed the necessary water resources planning that would allow your proposal to be evaluated comprehensively. We would ask that the work of the Water Utility Coordinating Committee and the Water Planning Council be completed before any additional inter-basin transfers are allowed.
  • Stakeholders need to be consistently engaged throughout all stages of this proposal.
  • The EIE needs more information in certain areas in order to aid decision makers with a more complete picture of anticipated direct and indirect impacts, especially environmental impacts.
  • UCONN must demonstrate that it is implementing progressive water management practises, utilizing all possible water conservation and efficiency measures and that water planning is thoroughly integrated into any expansion plans.
  • Ideally inter-basin transfers are the exception and water suppliers provide only for customers with a demonstrated commitment to maximizing water conservation.

 

As such, we ask you to consider the following:

1. Decision Making Process
A more comprehensive statewide planning process is needed – As others submitting comments have noted, the scope of this project, the involvement of an inter-basin transfer and the many environmental, land use and socioeconomic implications illuminate our being ill-equipped to uphold Principle 6 of the State Plan of Conservation & Development, which calls for the promotion of “integrated planning across all levels of government…”. Several comments have pointed us to gaps—gaps in process and in practice. The author of an editorial that appeared in the Hartford Courant January 2, 2013 describes the Water Utility Coordinating Committee, passed in the 1985 legislative session as a long-term drinking water supply planning process, emphasizing regional coordination—the author points out that the northeast part of the state around UConn is one of the area which still “has no water plan.” Other comments assert that the EIE should address the CT Water Planning Council and ‘the need to have a statewide water supply planning process beyond the regional WUCC process,’ as it is not comprehensive enough to accomplish “integrated planning across all levels of government and address all of the issues which concern the state the regions and the local communities.” We see that we are not alone in our concern about this project operating outside of existing planning structures and being of a magnitude that points to the inadequacy of existing, underutilized processes. As projects of this nature and magnitude are likely to reoccur, we agree with Meg’s Reich recommendation of including text indicating this lack in the EIE and also recommend that this lack of an approach be communicated directly to state and regional government.

Earlier and more thorough engagement of stakeholders is needed- As proposed solutions have many layers, affect multiple areas and stakeholders in the state and have precedent setting potential, a transparent, thorough decision making process that welcomes and gives adequate time to potentially affected stakeholders for participation is essential. We thank UCONN for ultimately being responsive to requests for extensions of comment deadlines. Though CEPA’s requirements leave great flexibility in the public notification process and UCONN utilized the CEQ among other avenues for notice, now that the proposal has become of great interest to many, it seems it would be in both UCONN and the potential water suppliers’ interest to better and more thoroughly engage stakeholders. When we initially heard of this proposal in the early summer thanks to a concerned citizen, we requested to be kept in the loop as this moved forward and then we heard nothing formal about it until we learned of the impending comment deadline informally from the environmental community. We recommend a list of those submitting comments be maintained and utilized for outreach purposes as this proposal moves forward and other major decisions affecting water resources in the state are planned by the university or the potential suppliers. This will hopefully encourage meaningful, substantive engagement that will add value to, rather than impede, the decision-making process.

2. The Right Information
The EIE needs to be more comprehensive and specific in order to aid decision makers and convince the public of the efficacy of the process – The EIE currently contains some useful information, but it would be more helpful if expected impacts were represented in one place in the EIE. Once a preferred alternative is selected a more thorough EIE will be required under Connecticut Regulations for Water Diversion, but decision makers and stakeholders need to be able to compare relative expected impacts holistically before that point is reached.

A number of CEQ’s comments were well thought out and presented. We support:

  • the need to use up-to-date data on river flows in light of a changing climate that is hopefully comparable in utility across potential donor basins to aid in equitable assessment.
  • an obligation for UCONN to explain how it will rectify inconsistencies between this project and the State Plan and how it expects the project to proceed in light of these inconsistencies.
  • the recommendation of presenting the decision maker with a matrix clearly illustrating relative impacts of the three alternatives with a ranking and explanation of the selected alternative. We need to clearly be able to compare relative impacts to aquatic life, river ecology, and direct and indirect effects of any pipeline extensions on the donor basin, receiving basin and pipeline affected communities. This should include but not be limited to:

1) all affected water bodies (names, types, classifications and Waterbody ID segment)
2) any impacts on wetlands and smaller streams
3) effects on the system as a whole in times of high and low water
4) quantified volume and loading effects to the Willimantic River, and,
5) the opinions of fisheries and water resource experts as to which option is least harmful overall.

Other info the EIE should address:

  • It would be helpful if the associated maps included clear labels of potential donor and receiving water bodies, specifying the source and destination (i.e. reservoir, river, etc.).
  • Additional energy consumption and costs of preferred alternatives
  • The financing mechanism of the proposed pipelines.
  • Sec. 22a-377 (c)-2. (3) of the Connecticut Regulations for Water Diversion will require that the ‘the proposed diversion is designed and will be carried out so as to minimize and, if possible, eliminate flooding and flood hazards.’ What potential flooding impacts might the increase in flow have to the receiving water system?
  • With the multiple questions asked regarding impacts to the receiving water body, it seems a separate section in the EIE should address this directly, including volume and loading effects and as much specificity as possible.

3. Stewardship & Responsibility on Supply & Demand
The Council supports increasing investments in higher education and recognizes that the long-term growth plan for the university will create many positives for the state and region. However that growth must be holistically planned and responsible.

Clarity is needed on the amount of water UCONN is requesting. Though it is understandably difficult to project all possible water needs decades out, the changing numbers related to this proposal have caused discomfort. The EIE should clearly explain the transition from .5 to 1 mgd and beyond. Five million gallons per day is not at all reflective of actual needs, and it is incumbent upon UCONN to outline why 1.93 mgd is truly needed even with conservation measures; if it does so, the request should not increase beyond this. We agree with Meg Reich’s sentiment (assumed in reference to the once 5 mgd request), submitted in her comments: ‘that a water supply far in excess of that needed for UCONN and Mansfield would not incent either to conserve a scarce resource and that communities’ access to the proposed pipeline could lead to further development that might not otherwise be supported by water available from local sources.’

To what extent will the University continue to expand in a water-poor area? What was not included in the original list of alternatives was the idea of locating the Technology Park elsewhere, in other cities. Environmental justice communities with abundant water were suggested. We know the Technology Park was covered in a previous EIE and will be considered outside the scope of this EIE, but as UCONN wants to expand services in a water poor area, proposed expansions should be comprehensively planned with alternative locations considered and strict water management and low impact development built into the ethos of all future expansions. Does such a strategic, comprehensive planning process exist now?

The extension of a water supply line to the UCONN campus, like all infrastructure, has the potential to be sprawl-inducing. As such this project must be developed so that it is in keeping with the State Plan for Conservation and Development as well as local plans in order that it not facilitate haphazard and sprawling development along its route.

  • While it is clear that UCONN has made strides in improving its water conservation and demand management programs, we are not convinced that enough conservation implementation and comprehensive planning effort has been put to that end in order to ensure that the most appropriate supply is being requested. Among other initiatives on campus we commend UCONN for its upcoming water reclamation facility. Other universities’ water reclamation programs have documented significant water and energy savings including the recently operational one at the University of Massachusetts. The opening of the water reclamation facility will be a great step for UCONN, and we applaud the university’s creative ideas about how water might be used in the future, such as watering sports fields. We know that UCONN has increased its water conservation public education efforts in light of environmental stress caused at times of peak demand. In order to justify an interbasin transfer of water, the proposed customer should concretely demonstrate it is doing everything it can, including public outreach, water efficiency, reduction in lost water through a leak detection and repair program, prioritization and creative reuse of water in order to conserve and reduce consumption. Does such a concrete plan exist?
  • In shaping or improving such a plan, the Massachusetts Interbasin Transfer Act has a helpful process for determining if a customer’s water conservation measures warrant a transfer. The Act has some elements in common with Connecticut regulations governing a water diversion and may be helpful to CT lawmakers by providing a good checklist for would be customers to use in their own self assessment. Some such requested information that we ask UCONN to include in this EIE:
    • Describe the on-going meter installation, maintenance, and replacement program. State the percentage of the system that is metered.
    • When was the last audit of public facilities? Has a system-wide water audit ever been conducted?
  • The EIE states that “unavoidable adverse impacts are possible along some of the pipelines, especially in the rural or less-developed areas of Tolland, Bolton, Coventry, and Mansfield, … with the Town of Mansfield considered most equipped and well-positioned to directly address the risks for development along pipelines.” Where does this leave the other towns, and does UCONN have a plan for helping municipalities along a route, once an alternative is chosen?

We appreciate the desire of utilities to increase revenue while mindful that strategic intentions to increase revenues can be at odds with commitments to water conservation. Because that conflict is inherent in a water rate structure which rewards consumption, we commend suppliers who are looking to reframe the structure to reward conservation, a key issue which might reappear on the legislative agenda this year. We support water planning that stewards, not stresses, the health of inland water resources.

Thank you for the opportunity to comment on this proposal and for the time UCONN is taking to select an alternative which minimizes detrimental impacts. We look forward to supporting the university’s forward thinking on water management, as the resource is key to the prosperity of us all.

Sincerely,

Jacqueline Talbot

River Steward

Connecticut River Watershed Council