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June 30, 2016
Mr. Christopher Sullivan
Planning and Standards Division
Connecticut Department of Energy and Environmental Protection
79 Elm Street
Hartford CT 06106
Re: Comments on Integrated Water Resource Management in Connecticut
Dear Mr. Sullivan,
Thank you for the opportunity to comment on the potential areas for plan development identified through the DEEP’s new approach to Integrated Water Resource Management in Connecticut.
I can appreciate the need for a more systematic, data driven and objective approach to prioritizing basins for restoration and protection. The technical support document was helpful in understanding how RPS Tool was used to achieve this goal. However, it is difficult for watershed managers to offer either agreement or further input on the rankings in Appendix D without seeing the data for the indictors which constitute the index numbers. For example, miles of free flowing streams is a heavily weighted indicator for several scenarios. If a watershed manager knows of one or several small dams that may not be in DEEP’s inventory there is no way for that watershed manager to know if the input was accurate and to what extent it skewed the index scores and, therefore, the overall ranking.
Thank you for incorporating Wild Trout Management Areas (WTMAs) into the analysis beyond the RPS tool. Wild brook trout are an excellent indicator of cold, high quality water. However, Wild Trout Management Areas represent a fraction of the rivers and streams that support wild brook trout in Connecticut. I recommend that you incorporate additional data from Inland Fisheries on locations of wild brook trout populations into ARCGIS.
While every watershed manager would like to see all high quality or threatened sub-watersheds protected and every impaired sub-watershed restored, prioritization is necessary as resources are – sadly – always limited. I will be addressing only the waters identified within the Connecticut River Watershed.
Lower Scantic River
I am in full agreement with the prioritization of the Scantic River for restoration. Bacteria impairment is well documented in several sections and any action taken to reduce bacteria impairment will reduce other nutrient loads. The Connecticut River Watershed Council is willing to partner with local organizations in order to meet restoration goals on the lower Scantic River
Mill Brook-Farmington River
I will defer to any comments made by the Farmington River Watershed Association about Mill Brook-Farmington River.
Roaring Brook, Lower West Branch Farmington River and Eightmile River
It would be silly to disagree with any watershed within the Connecticut River Watershed singled out as a priority protection for nutrients. In the case of all three of these watersheds, as is with nearly every watershed in a populated state, the primary cause of an increase in nutrient loads will be development. With the exception of the communities that surround Roaring Brook, many of the towns surrounding these protected watersheds are not subject to the MS4 Permit which is an important regulatory mechanism. I have concerns that the protections available through permitting may not be enough to protect these watersheds from the quality degrading effects of development.
It still remains to be determined if priority watersheds will also be a priority for state and federal grants. If this turns out to be the case, consideration should be given to how current funding is factored in to prioritization and how prioritization will impact future funding for watersheds that may never be considered a priority for restoration using the current analytical methods. The Lower West Branch of the Farmington River and Eightmile River are both designated Wild and Scenic which means they receive a fairly reliable stream of federal funding. While the very strong partners in both watersheds could certainly do a tremendous amount with more resources, would there be a greater benefit by spreading those resources out among watersheds that do not enjoy a steady stream of income? Will critically impaired watersheds like the Park Watershed which may never make the priority ranks be doomed to further degradation due to lack of resources and perhaps cancel out the improvements make in other parts of the Connecticut River Watershed?
Thank you again for the opportunity to provide comment. I look forward to meeting with you and your staff to determine how we can be of assistance in meeting water quality goals in the identified priority areas in the Connecticut River watershed.