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CLOSING ARGUMENT                                JUNE 14, 2021  ■  47


                                                 EDITORIAL BOARD


          across disciplines, but there will                                report makes clear that the
          always be a need for specialists                                  impending lack of staff on the
          to make sure the decisions are                                    environmental quality side will
          being made based on the best                                      impact the service and continu-
          science available.                     The CREATE report          ity of protection for the public
            Two key initiatives of DEEP        suggests that reducing       from “hazardous environmen-
          are important to this discus-      enforcement is a potential     tal  issues.”  Indeed,  DEEP  has
          sion: 1) the addition of energy      solution to the staffing     already acknowledged that it is
          to the DEEP mission, and 2)         problem, but that will be     not able to do inspections and
          the streamlining of the regula-     detrimental to public and     enforce permit requirements.
          tory process. Both have already      environmental health.        The CREATE report suggests
          adversely impacted the envi-                                      that reducing enforcement is a
          ronmental quality/conservation                                    potential solution to the staff-
          side of the agency and will con-                                  ing problem, but that will be
          tinue  to  do  so  during  this HR                                detrimental to public and envi-
          transition, if not addressed.                                     ronmental health.
          In 2011, energy was added to the environmen-        Finally, it must be noted that DEEP’s environ-
          tal protection agency creating the current DEEP.  mental quality and conservation divisions do not
          Advancing clean energy and climate change miti- just work on regulatory programs. They also pro-
          gation became a major focus of the department,  vide technical assistance, gather scientific data,
          while the environmental quality side was urged to  and administer federal grants. With DEEP se-
          streamline its regulatory process. On its face, that  verely understaffed, who will be left to assist local
          might sound good, but it is not when you look  inland wetland commissions? Who will oversee
          more closely.                                     the EPA 319 non-point source pollution program?
            Addressing climate change through mitigation  How much federal funding is being left on the ta-
          and adaptation requires that all DEEP divisions  ble for programs like Long Island Sound because
          work with other state agencies. The reality at DEEP  DEEP does not have the human resources to ad-
          is that the energy and environmental protection  minister the funds? After years of improvement to
          efforts are virtually siloed. One unfortunate conse- the environment DEEP will no longer be capable
          quence is the promoting of clean energy through  of ensuring environmental quality to Connecticut
          the siting of large-scale solar, which has ended up  residents, nor will it be able to meet the challenges
          with the loss of prime farmland and clear-cutting  of climate change including maintaining the criti-
          forests.                                          cal ecosystem services provided by our working
            Anyone who has been involved in environmen- and natural lands.
          tal permitting recognizes the work that DEEP        The immense human resources problem at
          undertook to improve the efficiency and trans- DEEP is the imminent challenge and our sustain-
          parency  of the process.  Much  of  this has  been  ability and resiliency as a state is dependent upon
          accomplished  through  the  use of  online  por- our  success  in  solving  it.  This  is  not  a  problem
          tals. Making a process more efficient and easier  limited to DEEP, but one which will increasingly
          to understand and access should not, however,  impact the other state agencies by causing tremen-
          result in a reduction in environmental protec- dous loss of institutional skill and memory across
          tion of our public trust resources. The CREATES  the whole expanse of state government.         ■


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