On September 30, 2010, the Connecticut Department of Environmental Protection (DEP) released its Permitting Assessment Report which comprehensively reviews 25 individual permit programs and recommends specific Process Improvements and Programmatic Changes designed to achieve more timely decisions on permit applications. The DEP is optimistic that the proposed changes will streamline and clarify the DEP’s permit programs governing air emissions, water discharges, inland water resources, coastal resources and waste management.
The Permitting Assessment Report is the product of Public Act 10-158, which directed the DEP to issue a report that "prescribes changes to be made to the department’s review schedules for individual permits, including reducing the time frames for identifying deficiencies in permit applications and issuing tentative determinations."
In the Report, the DEP recommends over 40 Process Improvements (steps that can be taken quickly without the need for further statutory or regulatory changes, e.g., issuing new procedures or forms) and more than 20 Programmatic Changes (changes that require new authorizations, e.g., issuing new general permits or enacting regulatory and statutory changes).
The Process Improvements include:
- Expanding the use of pre-application meetings with applicants to ensure that information requirements are understood and to give applicants an opportunity to discuss options that might simplify the regulatory process;
- Prioritizing applications for projects having a significant positive economic impact in coordination with the Department of Economic Development’s Permit Ombudsman;
- Further streamlining permit application processing; and
- Developing simpler processes for permit renewals where no changes are needed.
The highlights of the proposed Programmatic Changes include:
- Eliminating programs deemed unnecessary, such as the Stream Channel Encroachment Line Program and the Noise Program;
- Replacing individual permits with general permits, which the DEP has already initiated in the area of water discharges by developing a General Permit for Industrial Metal Finishing and Electroplating Discharges, consolidating up to nine existing general permits for sewer discharges into a General Permit for Miscellaneous Discharges of Sewer Compatible Wastewater; and developing a General Permit to Discharge from Subsurface Sewage Disposal Systems Serving Existing Facilities; and
- Adopting new and revised regulations to promote consistency and clarity.