Public Feedback On Connecticut Laws

Gov.
Malloy: Regulatory Review Public Comments

October-December 2013

Name Affiliation Town Regulating Agency Regulation
Subject Matter
Regulation
Section Number
Comments Submission Date
Time
Jeff Yale Energy and
Environmental
Protection, Dept Of
Sunday Hunting Currently CT does not allow hunting on Sundays. This is an old
law based on the old belief that Sunday should be a day of rest.
Times and religious beliefs have changed and hunters should get
the full weekend to hunt during the limited seasons we have.
Most sportsmen work hard all week at full-time jobs and only
have Saturday to get into the field. We are at the mercy of the
weather on that one day. Some years a hunter could have
consecutive Saturdays of bad weather and not be able to use the
permit they have paid for. The weather on Sunday might have
been great, but we are not allowed in the woods those days.
10/18/2013
10:51:37 AM
Matt Shelton Firearms Permit
Examiners, Board Of
Gun Laws The new gun laws are violating the second amendment. These
new laws do nothing to protect the law abiding citizen, it does
the complete opposite. Criminals will not follow theses new
laws because they are criminals, the only people who will follow
these laws will be people like myself (a law abiding citizen). You
are limiting my right to protect myself and my family while you
governor Malloy have protection that I could not have..double
standard. I like many citizens of this state are not part of the
elite and should be able to protect myself the same way you do.
I want YOU Gov Malloy to look and read the second amendment
carefully. It says "A well regulated Militia, being necessary to the
security of a free State, the right of the people to keep and bear
Arms, shall not be infringed."

Well good going you infringed on my rights! Listen to the people
of this state and reverse these laws!
10/18/2013
10:51:37 AM
Jerome
Rosenfeld
Bridgeport I don't know Public
Transportation
Improvements to Both Rail and Bus Transportation in Fairfield
County, Connecticut and surrounding region.
10/18/2013
10:51:37 AM
Paul Passarelli Libertarian Norwalk I don't know All Simply sort the entire list by cost and start striking out the most
expensive items!Don't stop until the State budget can afford
what is left without the Income Tax, the Sales Tax, the gas tax,
excise taxes, etc. If that means that **all** the regulations are
struck from the books, then you'll have an idea of where we
should be.Less Government. More Freedom.
10/18/2013
10:51:37 AM
michael
mclane
Gales Ferry I don't know Annual Fee for
corporations
I am treasurer for a NON-PROFIT charitable corporation,
incorporated in CT. Each year we have to spend funds intended
to help our local community to ""renew"" our corporation
identity. Give me a break - We'll let you know if we ever go out
of business. We'll gladly make the computer reports we now
make annually but STOP charging us money to keep up STATE
records. We do all the work of annual updates!
10/18/2013
10:51:37 AM
T.L. Schroeder Motor Vehicles
Department
front license plate Connecticut didn't used to require license plates on the front of
cars, only on the back. Let's return to that system. Just one more
law we don't need.
Thanks.
10/18/2013
10:51:37 AM
Walter Harris Hamden I don't know Strike this law Here is the law I would strike down:

When a utility pole or line is downed by a storm or accident, the
utility company can only obtain reimbursement if it replaces
with the same equipment. By law it cannot obtain
reimbursement for a smart alternative, such as undergrounding
a utility line. Strike this law so that public policy encourages
smart, long-term solutions.
10/18/2013
10:51:37 AM
John Smith Administrative
Services, Dept Of
Employee files Ability to keep electronic (PDF) records of employee files rather
than paper copies.
10/18/2013
10:51:37 AM
Robert
Mackin
Artisan Wines Inc Consumer
Protection, Dept Of
Liquor Control-
Brand label registr
I have a company that holds a wholesale permit to distribute
wine and liquor to retailers and restaurants. Our laws require
that each and every label be registered with the state at cost of
$200. A Unimerc number is also required for this registration at
an additional cost of $40. This $240 expense is a regressive tax
effectively on smaller businesses in this activity. Large
distributors that sell huge amounts of mass produced wines pay
the same fees which for them is an inconsequential cost per case
sold. Not so for a small business and/or the smaller wineries
they tend to represent. Neighboring states have no such
requirements and it is no wonder there is greater selection and
better pricing in those states as a result. The irony is that under
the guise of "Consumer Protection" choices are more limited
and prices higher. Just how are we protecting consumers with
these policies? These regulations should simply be abolished.
The state does generate revenue however through these fees
(regressive taxes in my opinion) and those could be replaced by
simply increasing the gallonage based excise tax on volume sold.
Personally I would be very happy with a 2 cent per gallon
increase in excise tax provided the fees and laborious process
was eliminated. I believe an increase that small would replace
the revenue from fees. In this way the playing field would be
leveled, and small businesses could compete with the bigger
ones. I would likely HIRE MORE PEOPLE to work for the company
in such a scenario as these fees add up to two salaries for a small
business that sells a wide array of product in small volumes.
10/18/2013
3:10:18 PM
Michael
O'Reilly
Citizen Westport I don't know Emissions Governor Malloy,

Here is your opportunity to win over moderate Republicans.
while still keeping your $20.00 tax for emmissions.

With few exceptions, all Automobiles exceed the emission
standards set in 1993. Yet the owners of older cars 2001- 2004
are continually harrased by having to make unnecessary, costly
repairs to meet emmision standards the cars already meet.

I can tell you of at least three companies with Van fleet's that
have chosen not to expand their presence in CT. because of this
intrusive law. It is becoming a final straw for me moving to
Florida in three years when my last child goes to college.
10/20/2013
6:22:23 PM
Arthur J.
Renner
CT Society of
Certified Public
Accountants
Rocky Hill Revenue Services,
Dept Of
bazaar or raffle
permit
CGR-2 Dear Sir:
The purpose of this letter is to provide comments regarding out-
dated state regulations as stated in your Executive Order of
October 16, 2013. We sincerely appreciate the opportunity to
do so.

We are the Connecticut Society of Certified Public Accountants,
a nonprofit organization with about 6,000 members. We hold
an annual golf tournament and raffle, the proceeds of which are
used to provide scholarships to accounting students in post-
secondary schools located in Connecticut. We are required to
submit an Application for a Permit to Conduct a Bazaar or
Raffle (CGR-2). The administrative commitment to prepare the
permit is very burdensome. The process requires three (3)
original signatures of members living in the town/city where the
raffle is to be held, plus the original signature of an officer of the
organization. The application is then delivered to the police
department of the town/city where the raffle is to be held and
then a background check is conducted of each individual who
signed the permit. (There is no language on the raffle permit to
indicate that a background check would be performed). Upon
completion of the background check, the permit must be
approved by the chief of police. Lastly, the permit is delivered to
the Department of Consumer Protection, Department of
Revenue Services for a final review and approval. This process
may take up to one week or longer.

The majority of our raffle prizes are donated and we do not
receive them or learn of their donation in advance of the
tournament. To further complicate the application process, the
top three major prizes must be listed on the sample raffle ticket
and all prizes and their value must be documented on the permit
application prior to its approval. The value of each donated
raffle prize does not exceed $600. The total value of the prizes
awarded ranges from $5,000 to $5,500, a deminimis amount.

We suggest that the existing application process is unnecessary,
complicated and burdensome for small raffles such as ours and
should be required only for organizations that hold bazaars and
raffles which exceed a higher value threshhold.
10/21/2013
8:16:17 AM

Again, thank you very much for the opportunity to comment.

Sincerely,
Arthur J. Renner CPA
Executive Director, CT Society of CPAs
Greg Secretary Of The
State, Office Of
Business Entity Tax I find the Business Entity Tax to be unfairly punitive for small
businesses. I have avoided starting a business and registering as
an LLC because I am unsure how long it would take me to recoup
the $250. I understand it's a pittance for a large company -- but
it is the sole factor holding me back from starting a small
marketing business.

Would suggest folding it into a corporate tax, perhaps? Or
finding a way to eliminate it.
10/21/2013
6:35:00 PM
Anne Gast Brookfield Administrative
Services, Dept Of
Employment
Application
The process for applying for state employment is unnecessarily
complicated, frustrating and opaque. It is difficult to find
appropriate exams, impossible to attend examinations for folks
unavailable on Saturdays, and challenging to track your progress
or ascertain if and when your paperwork has been received or
processed.

The exams (if they are truly needed at all) should be online with
clear indicators of your standing. The physical exams should be
used only if a demonstrable skill is needed (a unique computer
program on a state computer, for example) -- or as an option for
people without internet access.

Thank you for undertaking this review process.
10/21/2013
6:40:27 PM
Kevin Deame Ellington Revenue Services,
Dept Of
Gambling Losses For federal taxes I am able to offset gambling losses at the CT
casions agains any winnings. For the State of CT taxes I have to
pay on the winnings, even though there are offsetting losses.
For example, if I break even for a year I do not have to pay
federal income tax on the gambling income (losses can be offset
using itemization). But in that same year if I have $50,000 in
winnings and the same in losses, I would have to declare the
winnings for the purposes of CT taxes and pay income tax even
though I may have even lost money at the casino. This is very
unfair and certainly discourages me from going to any casino.
10/23/2013
11:13:09 AM
Janet Settle Little House in the
Country Child Care
Ellington Motor Vehicles
Department
student
transportation
vehicles
The regulations and process for getting licensed to drive a
daycare student transportation vehicle as well as the yearly
registration process for the vehicles is much too complicated
and confusing. Most daycare centers do not understand which
license/registration process is required for vehicles used to
transport children to and from school from a daycare center. We
are not transporting from private residences, only from a center
which is usually within a five or ten minute drive of the school.
Most importantly, we need clarification on the training process
for van drivers. It should not cost $500 to have a daycare van
driver trained to transport a child to school. This cost is not
realistic for most daycare programs. Also, we need more training
programs available to us.
Other unnecessary regulations for this process include the
contents of the first aid box(in addition to the first aid box that
the health department requires us to carry with us at all times).
Some of the items are very difficult to find and are unnecessary
and will never be used.
Also, there is apparently a newer regulation that prohibits
displaying the program website on the vehicle. This requirement
seems random and unnecessary. Most businesses display a
website on their vehicles, and daycare vehicles are permitted to
display the name and phone number of the program on the
vehicle. Displaying the website does not seem to present any
more of a safety issue.
Thank you, Janet Settle
10/23/2013
11:15:48 AM
Janet Settle Little House in the
Country Child Care
Ellington Motor Vehicles
Department
student
transportation
vehicles
The regulations and process for getting licensed to drive a
daycare student transportation vehicle as well as the yearly
registration process for the vehicles is much too complicated
and confusing. Most daycare centers do not understand which
license/registration process is required for vehicles used to
transport children to and from school from a daycare center. We
are not transporting from private residences, only from a center
which is usually within a five or ten minute drive of the school.
Most importantly, we need clarification on the training process
for van drivers. It should not cost $500 to have a daycare van
driver trained to transport a child to school. This cost is not
realistic for most daycare programs. Also, we need more training
programs available to us.
Other unnecessary regulations for this process include the
contents of the first aid box(in addition to the first aid box that
the health department requires us to carry with us at all times).
Some of the items are very difficult to find and are unnecessary
and will never be used.
Also, there is apparently a newer regulation that prohibits
displaying the program website on the vehicle. This requirement
seems random and unnecessary. Most businesses display a
website on their vehicles, and daycare vehicles are permitted to
display the name and phone number of the program on the
vehicle. Displaying the website does not seem to present any
more of a safety issue.
Thank you, Janet Settle
10/23/2013
11:15:55 AM
Kevin Public Health, Dept
Of
day care 19a-79-11(e) Group size is listed as 20 for school age children. Group size
should be increased to 30. Many schools have class sizes of more
than 20.
10/23/2013
12:54:20 PM
Of
day care 19a-79-5a(a)(1)(B) The day care provider does not need to know the business
address of the parent. Phone numbers are sufficient.
10/23/2013
12:57:05 PM
Of
day care 19a-79-3a(c)(2) Why does the department need to know when I change fees. I
understand parents deserve 30 days notice but I should not have
to notify the state.
10/23/2013
1:01:11 PM
Jean Suffield Transportation, Dept
Of
Livery license We are a small business trying to provide handicap
transportation to seniors in Simsbury area. It took us 60 days to
provide the 33 pieces of info to submit an application. Much of
the info was really none of the states business like our business
plan, where were we getting the start up money etc. Fingerprint
approval took 4 months. Now we are told it will be 2 months
until we have a required HEARING to make sure nobody objects
to our business.We want to provide this service and jobs but the
process places a burden on applicants.At this point it will be 7
months from start to finish to obtain a handicap livery license.
10/23/2013
2:26:23 PM
Of
day care 19a-79-4a(h)(C) There is no regulations that require you to have a dental policy
so this consultant in theory has to do nothing. This is an added
cost since most centers have to pay a consultant. This regulation
should be removed.
10/23/2013
9:45:11 PM
Of
day care 19a-79-4a(h)(C) There is no regulations that require you to have a dental policy
so this consultant in theory has to do nothing. This is an added
cost since most centers have to pay a consultant. This regulation
should be removed.
10/23/2013
9:47:18 PM
Of
day care 19a-79-
7a(d)(11)(E)
Regulations require single use disposable towels in bathrooms
and do not allow for the use of hand dryers. Centers that use
hand dryers are also required to have disposable towels which is
an added cost.
10/23/2013
9:50:07 PM
Of
day care 19a-79-7a(e)(10) regulations require chemicals to be locked. Regulation should be
changed to chemicals shall be inaccessible to children. If
chemicals are kept up high in an unlocked cabinet centers would
still not meet the regulation even though the children are still
safe.
10/24/2013
12:08:33 PM
Allan Pilver South
Windsor
Energy and
Environmental
Protection, Dept Of
Motor vehicle
emissions testing
The requirement to emissions test vehicles is of questionable
value. There should be a review to determine how many vehicles
fail these days, relative to the number tested, especially when
they are much more efficient than in prior decades. I have not
had a problem in as long as I can remember even with cars over
10 years old. I no longer see cars, and even pick up trucks,
spewing pollutants out of the tail pipe. The emissions testing
should be ended or justified. I expect it is a waste of time and
money.
10/24/2013
4:57:25 PM
Jennifer
Hamilton
I don't know Adverse possession This law is outdated. In this day in age people should not be
able to take people's property. Land is now clearly defined and
owned. The seven year of use is ridiculous and squatters
should have no rights.
10/24/2013
8:14:34 PM
Of
day care 19a-79-7a(c)(3)(A) Testing water supplied by public water companies for lead
every 2 years seems excessive.
10/25/2013
12:36:43 PM
Virginia
Benedetto
Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the State Agencies Regulations to allow
individuals with valid Permits to Carry Pistols and Revolvers to
carry a handgun for self defense while in CT State Parks and
Forests. Specifically:

- Remove the prohibition on the 'carrying of firearms' in Section
23-4-1(c) of the Connecticut Agencies Regulations
- Add an exemption to 26-66-2 to allow the carrying of pistols
and revolvers (including handguns using center-fire ammunition)
for the purposes of self defense.
10/26/2013
9:02:15 AM
Ronald Troia Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:06:49 AM
Eric Fisk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:06:59 AM
P Fomenko Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(c) and 26-
66-2

10/26/2013
9:08:48 AM
Erik Glastonbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and26-
66-2

10/26/2013
9:09:19 AM
Jonathan
Perry
BURLINGTON Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1c and 26-
66-2

10/26/2013
9:11:11 AM
Robert Nilsen Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2



10/26/2013
9:12:20 AM
Alfred M.
Tucci Jr
Seymour Energy and
Environmental
Protection, Dept Of
Carrying Hnadguns
in State Forest a
23-4-1(c) & 26-66-
2


10/26/2013
9:12:41 AM
Francis G
Zwierlein III
Bridgeport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:13:20 AM
Ralph Cook Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:14:35 AM
Joseph G
Pearlingi
NBPD Terryville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:14:55 AM
Russell Hehn Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Russell Hehn
10/26/2013
9:16:21 AM
John R.
Krupinski
Winsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:17:48 AM
David T Farris Marlborough Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you
10/26/2013
9:17:53 AM
Frank D
Scopino
Colchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:18:41 AM
Ralph Russo Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:18:46 AM
Mr John
Joseph
Gotowala
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:18:50 AM
Richard
Brousseau
Brooklyn Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/26/2013
9:18:55 AM
Tom Murray Southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:19:30 AM
Barbara
Davino
Terryville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:19:37 AM
Harlen Marks Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

and revolvers
(including handguns using center-fire ammunition) for the
purposes of self defense.
10/26/2013
9:20:08 AM
John S. Ciprus Essex Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:20:17 AM
Raymond
Mott
Mansfield Energy and
Environmental
Protection, Dept Of
Right to carry 23-4-1(c) and 26-
66-2



10/26/2013
9:20:31 AM
Ray Giannotti east haddam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:20:32 AM
Robert Drew Killingworth,
CT
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c), 26-66-2 Please modify the State Agencies Regulations to allow

10/26/2013
9:20:59 AM
Eric Schutz New Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:21:08 AM
Robert Hauta Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:21:28 AM
Vincent
Chrzanowski
Baltic Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:21:29 AM
Jim Boisverrt Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
9:22:14 AM
Vincent M Bridgeport Agriculture, Dept Of Guns in state parks
and forests


10/26/2013
9:22:33 AM
William
Daniels
Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:23:03 AM
Tim Howard Canton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:23:04 AM
Leonard
Benedetto
Vice President of
CCDL
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:23:13 AM
Scott Wilsion CCDL New London
CT
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Please Remove the prohibition on the 'carrying of firearms' in
Section 23-4-1(c) of the Connecticut Agencies Regulations.

Please Add an exemption to 26-66-2 to allow the carrying of
pistols and revolvers (including handguns using center-fire
ammunition) for the purposes of self defense.
10/26/2013
9:24:11 AM
Christopher
Byrne
GOshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:24:13 AM
Ray Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:24:17 AM
Angel Vega Seymour Energy and
Environmental
Protection, Dept Of
Carrying of
firemarms state
forest
23-4-1 and 26-66-
2
The right to protect oneself anywhere in the state should not be
taken away. I should be able to enjoy the beauty of our parks
and have the ability to defend myself if the need arises. Having
obtained the legal permit to carry a firearm means that I have
proven to be a law abiding citicent.
10/26/2013
9:24:37 AM
Jeffrey
Schwartz
East Lyme Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:24:43 AM
Cathy Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:25:01 AM
Jesse Pereira Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2
Forests. Specifically:- Remove the prohibition on the 'carrying of
firearms' in Section 23-4-1(c) of the Connecticut Agencies
Regulations- Add an exemption to 26-66-2 to allow the carrying
of pistols and revolvers (including handguns using center-fire
10/26/2013
9:25:47 AM
Christopher A.
Wilson
Voluntown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:26:06 AM
Jesse dinoia Middlefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2


We the people have the right to defend ourselves anywhere in
the state. These restrictions, if known by an attacker, makes us
as volnerable as in a gun free zone without the nearby
protection of law enforcement. Example: the heavily wooded
trails of wadsworth park in middlefield.
10/26/2013
9:26:27 AM
Scott norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
9:27:10 AM
roger bolduc naugatuck Energy and
Environmental
Protection, Dept Of
carry handgun in
state forest and p
23-4-1 Please modify the State Agencies Regulations to allow

for the purposes of self defense
10/26/2013
9:28:24 AM
Jennifer Derby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:29:04 AM
Ryan Burdge East Haven Energy and
Environmental
Protection, Dept Of
Concealed carry in
state parks
23-4-1(c) and 26-
66-2

10/26/2013
9:29:55 AM
Joel Begeron Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:29:58 AM
Dan Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests

10/26/2013
9:30:01 AM
Dan
Schnaufer
West Haven Energy and
Environmental
Protection, Dept Of
Restoration of pistol
carry
Restore right to
carry in state
parks


10/26/2013
9:30:27 AM
David
LaChance
Prospect Energy and
Environmental
Protection, Dept Of
Carry handguns in
state forest & pa
23-4-1(c) 26-66-
2

10/26/2013
9:31:02 AM
Michael A East Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 and 26-66-
2

10/26/2013
9:31:23 AM
Pablo Soto Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:31:24 AM
Kimberli
Carpenter
Shelton Energy and
Environmental
Protection, Dept Of
Carry handguns in
State forests/par
23-4-1(c) and 26-
66-2


10/26/2013
9:31:24 AM
George Scobie Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:31:42 AM
Ken Baylor Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:31:49 AM
Steven Long Energy and
Environmental
Protection, Dept Of
Carry handguns in
state forest


10/26/2013
9:31:53 AM
Kristen
McNulty
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 (c) and 26-
66-2


We want to be able to protect ourselves against threatening
wildlife!
10/26/2013
9:31:57 AM
Danielle
Keeley Gayda
Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:32:00 AM
J. Christian
grivalsky
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 and 26-66-
2


10/26/2013
9:32:05 AM
Jose Pansini Cromwell Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:32:08 AM
Stanley Speer east haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:32:09 AM
Kyle
Houghton
Democrat Thompson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:32:15 AM
Mark Battista North Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:32:27 AM
Thomas
Brown
Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:32:54 AM
Elizabeth
Scobie
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:33:19 AM
Russell
Bertrand
Thompson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:33:30 AM
Allan A.
Banyacsky
Beacon Falls Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1 Please allow permit owners to carry pistols in our state parks
and forests.
10/26/2013
9:33:39 AM
Andrew
Derbyshire
Ansonia Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2
Forests.Specifically:

10/26/2013
9:33:43 AM
David Dvorak Bozrah Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:35:06 AM
Dave VanWie Danbury Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.


10/26/2013
9:35:16 AM
Jesse Wisner Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:35:43 AM
Dominick
Agron
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:35:52 AM
Carl R Brown Griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forrests
23-4-1(c),26-66-2 Please modify the State Agencies Regulations to allow

10/26/2013
9:38:22 AM
George Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

for the purposes of self defense.g
10/26/2013
9:38:25 AM
Byron York Ridgefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:38:27 AM
Bert Begin Canton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:38:51 AM
Mark Pelkey Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you.
10/26/2013
9:39:46 AM
Waldemar
Demusz
Bolton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:39:54 AM
David
Cheesman
Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 (c) and 26-
66-2

10/26/2013
9:40:12 AM
Paul J Carmen Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:41:12 AM
Barry Farmington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:41:56 AM
Tom Corbett Uncasville,
CT
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1(c) & 26-66-
2
individuals with valid Permits to Carry Pitols and Revolvers to

-Remove the prohibition on the 'carrying of firearms' in section
23-4-1(c) of the Connecticut Agencies Regulations.

-Add an exemption to 26-66-2 to allow the carrying of pistols

Thank you for your time - Tom Corbett
10/26/2013
9:43:04 AM
Michael
MacCracken
Plainfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forest
23-4-1c 26-66-2 Please modify the State Agencies Regulations to allow


---------------------------------------------------------
10/26/2013
9:43:07 AM
Max
Rosenberg
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:43:14 AM
Robert
Chambers
Taxpayer Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2
I think this prohibition should be removed as it serves no useful
purpose. If poaching is an issue then the wardens can deal with
that directly. There are coyotes, bear, various wild cats out in
the woods and cell phone coverage is not always good. If a
person is lawfully carrying a handgun on their person, they
should be able to carry one in a state park as well.
10/26/2013
9:43:36 AM
David Delgado East
HARTFORD
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:43:48 AM
danny brandt iamaw cromwell Attorney General,
Office Of The
gun rights we are not all bad people 10/26/2013
9:44:07 AM
Thomas
Gallagher
North
Branford
Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state forests
23-4-1 and 26-66-
2

10/26/2013
9:44:13 AM
jim reilly oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
9:44:30 AM
Cody Rawling Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/26/2013
9:44:31 AM
RONALD
IACOBUCCI
SOUTH
WINDSOR
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Pistol Permit holders are law abiding citizens with not a blemish
on their record, that are required to go through training, and a
very extensive background check. It is very expensive and
requirements are very extreme to Qualify for a License and to
obtain this permit.
10/26/2013
9:44:48 AM
Samuel
Harding
Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:44:50 AM
Daniel L Miller East Lyme Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c) and 26-
66-2
Please modify the State regulations to allow individuals with
valid CT Concealed carry permits, to carry their handguns for self
defense, in our State Parks and Forests.
And, remove the prohibition of "Carrying of Firearms" in 23-4-
1(c) and add an exemption to 26-66-2 to allow for the carrying of
handguns (using center-fire ammunition) for self defense.
10/26/2013
9:45:00 AM
Michael
Hannan
Quaker Hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:45:14 AM
Andrew
Purchia
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1(c) and 26-
66-2

10/26/2013
9:45:27 AM
Shawna Zito-
Hannan
Quaker Hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:45:50 AM
Thomas
Keesler
Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:47:03 AM
Chris Thull Putnam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:48:56 AM
Eric vaughn Trumbull Energy and
Environmental
Protection, Dept Of
Carrying firearms in
state parks
Let us live. 10/26/2013
9:49:14 AM
Robert
Mattson
Newindton Energy and
Environmental
Protection, Dept Of
Carry handguns in
State Forests
23-4-1(c) & 26-
662


10/26/2013
9:49:33 AM
Michael
Lowell
Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2
ase modify the State Agencies Regulations to allow individuals
with valid Permits to Carry Pistols and Revolvers to carry a
handgun for self defense while in CT State Parks and Forests.
Specifically:

10/26/2013
9:49:47 AM
David Bochan East
Hampton
Energy and
Environmental
Protection, Dept Of
Handguns in State
parks and forests
23-4-1(c) and 26-
66-2


10/26/2013
9:50:03 AM
Jeremy Rooks Quaker Hill Energy and
Environmental
Protection, Dept Of
carrying hundgun in
state forest
23-4-1 (c) and 26-
66-2
10/26/2013
9:51:07 AM
Daniel
Forchielli
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:51:22 AM
Harold Bacon Plantsville Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:51:43 AM
Leon
Grossman
Ellington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
Please modify the state agencies regulations to allow individuals
with valid permits to carry pistols and revolvers to carry a
handgun for self defense while in CT State Parks and
Remove the prohibition on the 'carrying of firearms' in section
Add an exemption to 26-6-2 to allow the carrying of pistols and
revolvers (including handguns using center-fire ammunition) for
self defense.

Thank you
Leon Grossman

10/26/2013
9:52:41 AM
Fedele Volpe Orange Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/26/2013
9:53:40 AM
william hayes Old Saybrook Energy and
Environmental
Protection, Dept Of
Carrying of Firearms 23-4-1(c) and 26-
66-2

10/26/2013
9:53:48 AM
Anthony
Reccchia
Goshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:54:09 AM
Arthur
Gaignat
Energy and
Environmental
Protection, Dept Of
Carring handguns in
State Forests
23-4-1(c) & 26-66-
2

10/26/2013
9:54:23 AM
Wayne Manchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks an
23-4-1(c) 26-66-2 Please modify the State Agencies Regulations to allow


--------------------------------------------
10/26/2013
9:54:47 AM
craig szwed CCDL, CT CARRY,
DAV, PURPLE
HEART
union Firearms Permit
Examiners, Board Of
permit carry on
state lands
Current regs do not allow CT concealed carry permitees to carry
for protection in state forests and parks. Since the state has
already checked us out and licensed us to carry concealed it is
logical that we should not have our constitutional tights
infringed when on state property. All duly licensed permitees
have the constitutional right to carry without restriction, for
protection o of self and protection of the state.
10/26/2013
9:54:52 AM
Andrew
Martin
Willington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:55:05 AM
Ryan Duksa Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1; 26-66-2 Please modify the State Agencies Regulations to allow

10/26/2013
9:55:10 AM
Thomas
Sheehan
Griswold, Ct. Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 (c) & 26-
66-2
individuals with valid permits to carry pistols and revolvers to
carry a handgun for self defense while in Ct. state parks and
forests.

Specifically:

Remove the prohibition on the 'carrying of firearms'in section

Add an exemption to 26-66-2 to allow carrying of pistols and
revolvers ( including handguns using center-fire ammunition )for
the purposes of self-defense
10/26/2013
9:55:17 AM
Leonard
Kulicki, M.D.
Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c), 26-66-2 Federal law allows,legal, law abiding citizens who have passed
background scrutiny and possess pistol carry permits to carry
sidearms in federal parks and forests.
Please remove the prohibition in section 23-4-1(c) and add an
exemption to 26-66-2 to allow law abiding citizens who possess
state issued permits to exercise their rights given to them by the
state itself to carry sidearms on state land.
Thank you,

Len Kulicki, M.D.
10/26/2013
9:55:21 AM
Daniel
D'Apice
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:55:40 AM
Newell W Griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
lease modify the State Agencies Regulations to allow individuals
Specifically:

10/26/2013
9:55:56 AM
David Plainville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:56:46 AM
Steven Greco East
Hampton
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1-(c) and 26-
66-2
Please amend the laws to allow citizens with valid pistol permits
to carry handguns, including those that use center fire
ammunition, in state parks for the purpose of self defense.
Thank you for your consideration regarding this matter.
10/26/2013
9:57:58 AM
David F. Cyr
Jr.
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:58:39 AM
Stephen J
Savino
Burlington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:59:22 AM
Chris Chiappa Waterford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
10:00:08 AM
John Vincent Burlington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:00:34 AM
Martin
Emerson
Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:00:39 AM
John G. Krozer
Jr.
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in state parks
23-4-1(c) & 26-66-
2
Dear Mr. Governor,



Thank You
10/26/2013
10:00:47 AM
C Criswell Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:00:55 AM
Mark F
Wayne
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks an
I am permitted to carry a gun in the state of Connecticut. Hiking
the state parks and forests leave the hikers vulnerable to
criminal activity since they are away from the public and park
personnel. I have read of a number of serious crimes committed
in these areas. Being able to legally carry on these properties will
make for a safer public.

Thank you.

Mark F Wayne
10/26/2013
10:01:33 AM
William Starr Harwinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:01:33 AM
C Criswell Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:01:33 AM
William Starr Harwinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:01:49 AM
Emily Starr Harwinton Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:02:46 AM
Jeffrey
Phinney
Torrington Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:03:32 AM
Richard Zank Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:04:45 AM
H. Richard
Wisneski
ACLU Enfield Governor's Office weapons/hand in
state forest/parks
You have more unlawful people carrying hand guns in all your
city's,untrained in safty,illegal weapon and you want to stop a
person trained in firearm safty,with a pistol permit from carrying
his or her firearm to protect them and family member from said
gang bangers,who car jack,rape and kill unarmed people???I
voted for you,what was I thinking,I know you had personal
problems at home re firearms and it caused alot of pain,but
please don't punish others who have done no wrong ,If Doctor
Pettit was armed his family would still be alive!!!!!!
10/26/2013
10:05:50 AM
Bruce August East Hartford Energy and
Environmental
Protection, Dept Of
carrying hand guns
in a staye park
23-1-4(c) 26_66-2 Please modify the State Agencies Regulations to allow

10/26/2013
10:06:20 AM
John
Hermanson
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations - Add an exemption to 26-66-2 to allow the carrying
10/26/2013
10:06:21 AM
Alf Liljeros Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forrests
23-4-1(c) and 26-
66-2


10/26/2013
10:06:55 AM
Roger Teshera Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
10:08:12 AM
Jason Bell East
Hampton
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and
26-66-2


10/26/2013
10:08:27 AM
Francis Miele East Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank You,
Francis Miele
A responsible, trained permit holder
10/26/2013
10:09:16 AM
Lisa
Napolitano
Columbia Energy and
Environmental
Protection, Dept Of
Carry handguns,
State Forests/Parks
23-4-1(c) and 26-
66-2

10/26/2013
10:09:18 AM
Jim Reck Old Saybrook Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests. Specifically:- Remove the prohibition on the carrying of
firearms in Section 23-4-1(c) of the Connecticut Agencies
Regulations
Add an exemption to 26-66-2 to allow the carrying of pistols
10/26/2013
10:09:28 AM
Chris Lemos Stratford Energy and
Environmental
Protection, Dept Of
handguns in State
Parks/Forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:09:56 AM
Victor Duphily Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/26/2013
10:10:55 AM
James H. Day Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:10:55 AM
Jerry Sullivan Winsted Energy and
Environmental
Protection, Dept Of
Carry handguns in
State Forests and
23-4-1 (c) and 26-
66-2


10/26/2013
10:10:55 AM
Roger
Peterson
New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:12:52 AM
F. Peter Hall Bristol Energy and
Environmental
Protection, Dept Of
carrying handguns is
State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:13:16 AM
Andre Asprelli Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
10:13:28 AM
Robert Jochim Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
10:16:08 AM
Michael Cote Coventry Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/26/2013
10:16:57 AM
Lloyd
VanLanen
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
To whom it may concern:



Thank you,

Lloyd VanLanen
456 Pendleton Hill Rd.
Voluntown, CT 06834
10/26/2013
10:17:04 AM
Jonathan
Fowler
Environmental
Protection, Dept Of
Carrying handguns
in State parks
23-4-1(c) and 26-
66-2

10/26/2013
10:17:26 AM
Sean East Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:19:04 AM
Stuart Keating Durham Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:19:57 AM
Adrian Maung Woodbridge Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:20:41 AM
Arthur D.
Mazeau
Clinton Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:20:43 AM
Gerard A.
LeBlanc
Putnam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2

10/26/2013
10:21:44 AM
Frank Boutot Manchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 (c) & 26-
66-2

10/26/2013
10:21:54 AM
Kevin Healey Suffield Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks
23-4-1(c) and 26-
66-2

10/26/2013
10:21:57 AM
Mark Daigle West
Hartford
Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:22:22 AM
Travis
Spalding
putnam Firearms Permit
Examiners, Board Of
carrying in state
parks
I believe Connecticut citizens who obtain a carry permit legally
by taking training courses and paying a large sums of money
should be able to defend themselves in any place such as state
parks.
10/26/2013
10:22:43 AM
Paul Gruber Voluntown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:23:43 AM
Harry Finley Game Club
Member, avid
hunter and 2nd
Amendment
advocate.
Watertown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


I am trained in gun safety and would like to be protected in all
parts of the state, but particularly in CTR parks and forests.
10/26/2013
10:23:51 AM
harold new britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

10/26/2013
10:24:20 AM
Edward
Sutton
Morris Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits To Carry Pistols and Revolvers to
carry a handgun in CT State Parks and Forests. Specifically:

- Remove the prohibition on the "carrying of firearms" in Section
24-3-1(c)of the Connecticut Agencies Regulations.

for the purpose of self defense.
10/26/2013
10:26:26 AM
David A
Dojnia
Ansonia Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:26:42 AM
Paul A.
Ramsey
Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permit to Carry Pistols and Revolvers to


10/26/2013
10:27:03 AM
Robert
Wildermuth
Portland Energy and
Environmental
Protection, Dept Of
Carry of handguns in
State Forests
23-4-1 and 26-66-
2
Please remove the prohibition of 'carrying of firearms" in section
23-4-1 of the CT Agencies Regulations.

Add an exemption to 26-66-2 to allow the carrying of pistols or
revolvers
10/26/2013
10:27:25 AM
luc morin new britain Governor's Office right to own and
carry my guns
I should be able to own and carry my guns anyware in this State
and that in clude the state forest
and can you also realese all information on Sandy Hook shooting
if there is nothing to hide otherwise we are getting hose again by
your administration
10/26/2013
10:27:29 AM
Charles
Falzone
NA Fairfield, CT Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:27:34 AM
Donald
Gordon
Montville Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

Remove the prohibition on the carrying of firearms in Section
23-4-1(c) of the Connecticut Agencies Regulations;

Thank you.
10/26/2013
10:27:53 AM
Johan van
Achterberg
Resident East Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Thank you for your consideration. Please modify the State
Agencies Regulations to allow individuals with valid Permits to
Carry Pistols and Revolvers to carry a handgun for self defense
while in CT State Parks and Forests. Specifically:


Prohibition of firearms in state parks and forests is ineffective
(leaving law-abiding citizens whom the state has vetted and
authorized to carry firearms in public does not reduce crime or
add to public safety) and unnecessarily burdensome (requires
them to take pains to disarm and secure their firearms off of
their person whenever they enter a state park or forest).

Thank you.
10/26/2013
10:28:08 AM
Rebecca L
Johnson
Rockfall Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
10:28:49 AM
Kenneth Velez Fairfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
10:29:19 AM
Randy DaRos Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:29:19 AM
Jason Hart Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thanks Jason Hart.
10/26/2013
10:30:12 AM
DANIEL
RIVERA
MERIDEN Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.
Specifically:
10/26/2013
10:30:50 AM
Michelle
Velez
Fairfield Environmental
Quality, Council On
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
10:30:52 AM
William Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:31:12 AM
Shufeng ton Oxford I don't know pistol permit carry
in state forest
Hiking in state forests and parks. We as law abiding citizens with
a valid pistol permit should be allowed to carry our firearms. We
have gone thru the required safety training courses to carry our
firearm. Dangerous wildlife is present in CT. Denying our right to
carry is denying our right to protect ourselves and our loved
ones when hiking. Just imagine how you can react to a situation
where your wife, kids and the elderly are unable to fight off
these dangers and you will be limited in helping. Allowing lawful
carry will help ensure their safety.
10/26/2013
10:31:28 AM
Brett Stroke Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:32:15 AM
Philip B
Barbetta
Stratford Emergency Services
and Public
Protection, Dept Of
23-41-1 (c). 26-66-2

10/26/2013
10:32:20 AM
Blaine Morin Southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:33:04 AM
Robert D
Soule Jr
S New
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
As a police officer in the State of Connecticut for over 33 years
and still serving; the overwhelming evidence that lawful carry of
handguns by a citizenry does deter crime.

Therefore I am urging you to modify the Department of Energy
and Environmental Protection's Regulations to allow individuals
Specifically:


As a police officer, I am not exempted from these regulations in
an off duty capacity.

Respectfully,
Robert D Soule Jr.

Home:
81 Burwell Road
New Hartford, CT 06057-4109
Phone: (860) 379-7903

Work:
Simsbury Police Department
933 Hopmeadow Street
Simsbury, CT 06070
Email: RSoule@pd.simsbury-ct.gov
Phone: (860) 658-3116
10/26/2013
10:33:23 AM
Lawrence
Ganim
Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:
10/26/2013
10:33:47 AM
Jeffrey Patton Meriden Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1c and 26-
66-2

10/26/2013
10:34:51 AM
Cheryl Lemos Stratford Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:36:06 AM
Derek Anforth Sterling Energy and
Environmental
Protection, Dept Of
Handguns in State
Forest/Parks
23-4-1(c) and 26-
66-2
Regulations

10/26/2013
10:36:29 AM
Tony Cuomo Oxford Energy and
Environmental
Protection, Dept Of
Concealed weapons
by permit holders
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:36:34 AM
Mike Patton Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:38:22 AM
Hunter
Perkins
Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:39:11 AM
Rick OConnor Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:39:15 AM
michael
faucher
putnam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:39:19 AM
Edward
Josefow Jr
Colebrook Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1-(c), 26-66-2 Please modify State Agencies Regulations to allow individuals
with valid permits to carry a handgun for self defense while in
Connecticut State Parks and Forests.
Specifically: Remove the prohibition on the 'carrying of firearms'
in section 23-4-1 (c) of the Connecticut Agencies Regulations.
10/26/2013
10:39:25 AM
Michael
Aukstolis
Newington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:40:24 AM
Wayne DeRoy Avon Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:42:32 AM
Williwm
Zehrung
New Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:42:37 AM
William A.
Forbes
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
PLEASE MODIFY THE STATE AGENCIES REGULATIONS TO ALLOW
INDIVIDUALS WITH VALID PERMITS TO CARRY PISTOLS AND
REVOLVERS FOR SELF DEFENSE WHILE IN CT.STATE PARKS AND
FORESTS SPECIFICALLY;

REMOVE THE PROHIBITION ON THE 'CARRING OF FIREARMS' IN
SECTION 23-4-1(C)OF THE CONNECTICUT AGENCIES
REGULATIONS
-ADD AN EXEMTION TO 26-66-2 TO ALLOW THE CARRING OF
PISTOLS AND REVOLVERS (INCLUDING HANDGUNS USING
CENTERFIRE AMMUNITION) FOR THE PURPOSES OF SELF
DEFENSE.
10/26/2013
10:43:30 AM
David Hatlee Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:43:34 AM
Mike Burn Plymouth Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
I fully support the Right To Carry in
State Forests and Parks in Connecticut
10/26/2013
10:43:42 AM
David
Woodhouse
Milford Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:43:43 AM
Daniel
Kapustic
East Haven Energy and
Environmental
Protection, Dept Of
state forests
23-4-1(c) and 26-
66-2

10/26/2013
10:44:14 AM
michael
gallagher
Conn citizen prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and26-
66-2

10/26/2013
10:44:46 AM
Bobby Lee
Farris
Woodbury
CT
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:44:50 AM
Robert Stafford Energy and
Environmental
Protection, Dept Of
handguns in state
forests/parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:45:17 AM
Ken Johnson Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
10:45:27 AM
Robert
Tantillo
redding Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:45:27 AM
Philip
Churchill
Uncasville I don't know Concealed carry in
state forests
With the amount of killers, rapists and thieves in this state , me
or my wife can't carry or weapons legally when walking our dogs
in a state forest. A place where I can hunt but can't carry a pistol
for protection . This needs to change
10/26/2013
10:46:07 AM
Matthew
Gioia
Rocky Hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:47:06 AM
Joe Rainis Taxpayer in the
State of Ct. County
of Fairfield
Fairfield Energy and
Environmental
Protection, Dept Of
carrying hand guns
in forests/parks
23-4-1(c) and 26-
66-2

10/26/2013
10:47:34 AM
Ronald
Ingraham Jr
Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:47:50 AM
Byrne
Barrenger
Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Forests.

Specifically:- Remove the prohibition on the 'carrying of
10/26/2013
10:48:17 AM
Ryan
o'Connor
Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1-c Please modify the State Agencies Regulations to allow

10/26/2013
10:48:20 AM
Michael
Esposito
Roxbury Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in State Forests
23-4-1 (c); 26-66-2 Please modify the State Agencies Regulations to allow
10/26/2013
10:48:53 AM
Gino Lercara Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:49:09 AM
Pat Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:49:09 AM
Mark Hedrick Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:50:09 AM
Philip
Churchill
Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:52:04 AM
Pablo Torres new haven Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c and 26-
66-2

10/26/2013
10:52:25 AM
Daniel Trudel Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:52:52 AM
Gregory
Bembry
Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:53:01 AM
Kenia Torres new haven Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c and 26-
66-2

10/26/2013
10:53:08 AM
Colicci, Victor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:54:23 AM
RobertChristo
pher
CLINTON Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:54:30 AM
Colicci, Victor Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:54:42 AM
Timothy Arzt Stafford
springs
Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state parks
23-4-1(c) and 26-
66-2


10/26/2013
10:55:03 AM
Brian J Binette CCDL Unionville Energy and
Environmental
Protection, Dept Of
Carrying Hand Guns
in State forests
23-4-1c and 26-
66-2
individuals with valid permits to carry Pistols and Revolvers to
Forests Specifically:

Remove prohibition on the "carrying of firearms" in section 23-4-
1c of the state regulations
Also an exemption to 26-66-2 to allow the carrying of pistols and
revolvers including handguns using center fire ammunition for
the purpose of self defense.
10/26/2013
10:57:45 AM
James A.
Niedzialkoski
Thompson Energy and
Environmental
Protection, Dept Of
carry of firearms in
state parks
23-4-1 {c} 26-66-2 Allow the carry of firearms {pistols and revolvers} for personal
self protection in state parks and land
10/26/2013
10:57:59 AM
Jeffrey Kamen Westbrook Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:59:02 AM
Peter simard Rocky Hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:59:03 AM
Andrew Rule Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

I hike in State Parks. I love the Blue Trail System.


10/26/2013
10:59:50 AM
Timothy
Bernhardt
Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:00:16 AM
Ray Corchard Oxford Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
11:01:08 AM
Jonah Damon Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
11:02:05 AM
Mario
Richards
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:02:08 AM
Michael A.
Osga
Moosup Energy and
Environmental
Protection, Dept Of
Carrying Handguns
In State Forest &
23-4-1(C) & 26-66-
2
We Should Be Able To Protect Are Selfs On State Property 10/26/2013
11:02:21 AM
Henry Goerke Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:02:55 AM
Kenneth Boyd Ledyard Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:03:47 AM
David
Bauchiero III
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:05:26 AM
c w minerly farmington Energy and
Environmental
Protection, Dept Of
carrying handguns
in State forests
23-4-1(c) and 26-
66-2

10/26/2013
11:06:32 AM
Frank
McDonough
Plainville Energy and
Environmental
Protection, Dept Of
carring handguns in
state forests
23-4-1c 26-66-2 Please modify the state agencies regulations to allow persons
handgun for self defense while in ct state parks and forests.
Remove the prohibition on the carry of firearms in section 23-4-
1c of the connecticut agencies regulations-Add an exemption to
26-66-2 to allow the carry of pistols and revolvers(including
handguns using centerfire ammunition)for the purpose of self
defense.
10/26/2013
11:06:52 AM
Thomas
Drobena
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2
Forests. Specifically,
-Remove the prohibition on the "carrying of firearms" in section
-add an exemption to 26-66-2 to allow the carrying of pistols and
the purposes of self defense.
10/26/2013
11:07:05 AM
Walter
Megura
Truumbull Energy and
Environmental
Protection, Dept Of
23-4-1 & 26-66-2 Carrying of firearm for personal protection: Have you given any
thoughts when you disarm law-abiding citizens ,knowing that
criminals totally reject laws?? The four area's with the toughest
guns laws in the country are responsible for the highest rates of
gun death's!! Wake up! Walter Megura
10/26/2013
11:10:29 AM
Mark Wilson East Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:12:28 AM
Jeffrey Harrick Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
11:12:32 AM
Jeff Newington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:13:19 AM
RAYMOND
ROSSIGNOL
NEW BRITAIN Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:13:42 AM
Nathaniel
neville
Environmental
Protection, Dept Of
Carrying handguns
in state parks

10/26/2013
11:14:37 AM
Angel Ortiz West Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:15:30 AM
Dom Basile Oakville Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:16:26 AM
John Orazietti Wolcott Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks &
23-4-1 (c) & 26-
66-2
Please modify the State Agencies regulation to allow individuals
handgun for self defense while in CT. State Parks & Forests
Specifically:

- Remove the prohibition on the carrying of firearms in section
23-4-1 (c) of CT. Agencies Regulations.

-Add an excemption to 26-66-2 to allow the carrying of pistols &
10/26/2013
11:16:30 AM
Jason east lyme Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests

10/26/2013
11:16:47 AM
George
Bernklau
meriden Energy and
Environmental
Protection, Dept Of
hunting with
revolver and
muzzleloa
I would like to legalize revolver hunting on state land and also
allow a short muzzleloader season prior to shotgun season.
10/26/2013
11:18:09 AM
Shaun
Chapdelaine
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 (c) and 26-
66-2
10/26/2013
11:21:06 AM
Ashlee Leone Ellington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


I feel strongly about this proposal because I hike and run the
trails in my nearby State Forest alone, a few times a week. I
have my pistol permit and can legally carry my pistol, except to
protect myself while enjoying the outdoors in our State Forests.
Granted I usually have my fearless canine companion with me, it
would still be reassuring to have my own personal protection on
hand if needed. I am not as fearful of wildlife encounters as I am
of human ones. I do carry an i.d. on me, God forbid, in the event
something should happen to me I can be identified and I always
tell someone my intended route. Women especially can not be
too careful when it comes to protecting themselves. There was
a time when I stopped hiking the trails because I was fearful of
going out there alone. I have overcome that fear and decided I
can't be held prisoner in a gym, when the outdoors is where I am
really happiest. I think a lot of people, especially women, would
rather carry a pistol for personal protection while in the State
Forest alone and get in trouble for using if needed, than to not
have anything and be raped or dead. There are already hunting
laws in place, to prohibit people from using pistols for wildlife,
so why I ask you, is it not logical to change this law, for our
personal protection. Especially with budget cuts in the DEEP
department and fewer officers, these area's are not exhibiting a
strong or constant presence of DEEP officers.

I strongly encourage you to consider this change in our current
law. Thank you very much for you time.
10/26/2013
11:21:14 AM
Steven Loban Naugatuck Energy and
Environmental
Protection, Dept Of
handguns, carry
state forest parks
23-4-1c and 26-
66-2
Regulations
10/26/2013
11:22:50 AM
joe wonoski guilford I don't know sidearm carry in
state forests
I feel that I should be able to carry a concealed sidearm as a
pistol permit holder in state parks and forests. There are
poisonous reptiles and rabies is spreading among mammals.
Why can't I legally protect myself as a responsible and trained
permit holder?

Joe Wonoski
10/26/2013
11:23:43 AM
Thomas
Bavone
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

Remove the prohibition on the 'carrying of firearms' in Section
10/26/2013
11:24:53 AM
JESSE YEAGER CCDL MEMBER CANTERBURY Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:25:34 AM
Roger Chung West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:25:44 AM
Thomas
Bavone
Oxford Energy and
Environmental
Protection, Dept Of
Archery Hunting on
Sundays
Please allow the use of archery equipment for hunting on
Sundays during applicable hunting seasons.
10/26/2013
11:26:42 AM
Adrian
Mishtal
Suffield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:26:50 AM
Philip Kirsopp Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:27:15 AM
Kyle
Wengenroth
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:27:38 AM
gilman chasse bristol Governor's Office right to carry I`am a us vet and I believe in the right to carry. I fired every
weapon in the 7 years in the military, and had training with all to
them. from 72-79 in the infantry protecting our country. Now as
civilian I believe I have the right to carry. I went to the NRA
training I had my back ground check and all good
sincerely
gil chasse

PS I also think that people that kill without care of life need to
be put away for good not in prison but EXECUTED.
10/26/2013
11:27:40 AM
James Davis Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forest
23-4-1(c) and 26-
66-2

10/26/2013
11:27:43 AM
Roy Meyer Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:28:07 AM
Alan Shaw Stamford Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests & Parks
23-4-1(c) and 26-
66-2
In Connecticut pistol permit holders go through training,
background checks and pay a lot of money to obtain these
permits. Please modify the State Agencies Regulations by adding
an exemption to 26-66-2 to allow the carrying of pistols and
the purposes of self defense. Please also allow individuals with
valid Permits to Carry Pistols and Revolvers to carry a handgun
for self defense while in CT State Parks and Forests. Specifically:-
10/26/2013
11:28:46 AM
Brian Iacuone Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/26/2013
11:29:19 AM
joe wonoski I don't know sales tax when you passed the 6.35% sales tax you broke a solemn
promise made years ago by legislators that if the state income
tax were passed (which it did) that the sales tax would never
change. well, that promise was broken by you. how can conn.
citizens trust their elected officials when these promises are
broken?
10/26/2013
11:29:26 AM
ross marble mansfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State forest
23-4-1(c) and 26-
66-2

10/26/2013
11:29:31 AM
joe wonoski I don't know sales tax when you passed the 6.35% sales tax you broke a solemn
promise made years ago by legislators that if the state income
tax were passed (which it did) that the sales tax would never
change. well, that promise was broken by you. how can conn.
citizens trust their elected officials when these promises are
broken?
10/26/2013
11:29:31 AM
Ray LaChance Greenwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:


10/26/2013
11:30:20 AM
Harlan M.
Madnick
Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:30:28 AM
Tony Szpara East Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:31:47 AM
levy east hartford I don't know Carry pistol in state
parks and woo
I would like to be able to carry my firearm in state forest and
parks
10/26/2013
11:36:37 AM
David South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:36:51 AM
David Logan Glastonbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
11:38:33 AM
Michael
Mencel
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:40:04 AM
Jerry
Debrosky
Environmental
Protection, Dept Of
handguns in state
forests/parks
23-4-1(c) and 26-
66-2
Please modify the state agencies regulation to allow individuals
handgun for self defense while in ct state parks and forests.
Specifically:-remove the prohibition on the carrying of firearms'
in section 23-4-1(c) of the Connecticut Agencies Regulations-
revolvers ( including handguns using centerfire ammunition) for
10/26/2013
11:40:04 AM
John Romano Rocky Hill Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forrests
23-4-1(c) and 26-
66-2

10/26/2013
11:40:25 AM
Jack Kavanaugh Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
11:40:30 AM
William Suraci Seymour Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2


10/26/2013
11:40:34 AM
kyle richards Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:40:34 AM
Matthew
Wium
Cheshire Energy and
Environmental
Protection, Dept Of
Carrying Handguns
In State Forests
23-4-1(c) and 26-
66-2
Modify the State Agencies Regulations to allow individuals to

10/26/2013
11:40:35 AM
Charles
salvatore
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:42:11 AM
Alan Bardfield Ledyard Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
11:42:17 AM
Jerri
MacMillian
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
11:43:31 AM
Nick
Bolovinos
Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you
10/26/2013
11:43:45 AM
Seth Smith Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


23-4-1(c) of the Connecticut Agencies Regulations - Add an
exemption to 26-66-2 to allow the carrying of pistols and
10/26/2013
11:43:51 AM
Richard
Szentkuti
Ridgefield Energy and
Environmental
Protection, Dept Of
Carrying Handguns
State Forest/Park
23-4-1(c) and 26-
66-2

10/26/2013
11:44:08 AM
Jeremy
Hanson
Southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:45:12 AM
David
Phaneuf
Waterford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:45:50 AM
joe scatchell avon Firearms Permit
Examiners, Board Of
ability to carry
firearms in state
Dear Governor;
While you may want to dismiss the 2nd amendment for your
own political gains, the fact is carrying a firearm is legal and
should remain so. This is just as important in state parks and
forests as is it on the downtown streets of Hartford on a
weekend night. Numerous assaults have taken place in our parks
and forests. IN addition, large predatory animals reside in our
fair state. To deny people the ability to protect themselves is to
ask for trouble. The fewer the gun free zones, facts prove the
safer we citizens remain.
Do not impose any more firearms restrictions.

Joe Scatchell
licensed but do not own a gun
10/26/2013
11:45:57 AM
Bill Moshka Bristol Energy and
Environmental
Protection, Dept Of
Handguns in State
forests/parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
11:46:58 AM
Matthew W Norfolk Energy and
Environmental
Protection, Dept Of
hand guns in state
forestes
23-4-1(c) and 26-
66-2
Regulations
From a law abiding citizen Matthew W. Adamson
Thank you for yor time.
10/26/2013
11:46:59 AM
Thomas R
Violante
CCDL, NRA, CCS,
GOA, NHRC
New Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2


After all, it's our CONSTITUTIONAL right in the CONSTITUTION
STATE to bear arms in defense of my self and the state!
10/26/2013
11:47:14 AM
Luke G.
Gardner
Connecticut
Citizen
Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the State Agencies' Regulations to allow
individuals with valid CT Permits to Carry Pistols and Revolvers
to carry a handgun for self defense while in CT State Parks and


10/26/2013
11:47:46 AM
Edward
Grenier
Environmental
Protection, Dept Of
carrying of
handguns
23-4-1 Please remove from regulation prohibition on carrying handguns
in state forests and parks.
10/26/2013
11:48:00 AM
Harry Finley Game Club
Member, avid
hunter and 2nd
Amendment
advocate.
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


I am trained in gun safety and would like to be protected in all
parts of the state, but particularly in CTR parks and forests.
10/26/2013
11:48:29 AM
Donald
Cavanaugh
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:49:31 AM
Andrew coy Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks


------------------------------------
10/26/2013
11:50:26 AM
Michael
McHugh
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:51:59 AM
Wallis M.
Duarte
South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1, 26-66-2

10/26/2013
11:52:29 AM
Edward M.
Singleton
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:52:52 AM
William
Steinbacher
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:53:49 AM
Edward
Grenier
Environmental
Protection, Dept Of
carrying handguns 26-66-2 please modify regulation to allow for the carrying of pistols and
revolvers including centerfire ammunition.
10/26/2013
11:53:51 AM
Thomas Putnam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:54:01 AM
Carol Aldrich Goshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:54:20 AM
Thomas H
Stevens
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
11:55:20 AM
Ryan Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/26/2013
11:56:40 AM
Steve Puzycki Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Okay so if we can't protect ourselves in St forest who will.
Smokey the Bear?
10/26/2013
11:56:47 AM
Gary Laliberte Colchester,
CT
Energy and
Environmental
Protection, Dept Of
Handguns in state
forests
23-4-1c and 26-
66-2
Please adjust the regulations to allow persons with permits to
carry pistols and handguns in state forests.
10/26/2013
11:57:55 AM
Timothy
Benoit
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:59:11 AM
Laura Nunno Higganum Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 (c) and 26-
66-2
individuals with valid Permitd to Carry Pistols + Rebolvers to
carry a handgun for self defense while in Ct. State Parks and
Forests: specifically, remove the prohibition, the carrying of
firearms in Sect 23-4-1(c) of Ct Agencies Regulations. Add in
exemption 26-66-2 to allow carrying of pistols and revolvers
(including handguns and using center-fire ammunition) for the
purpose of self defense.
10/26/2013
12:00:00 PM
Tom Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:00:14 PM
Michael
Critser
Trumbull Energy and
Environmental
Protection, Dept Of
Carry handgun in
State Forest/parks
23-4-1(c) and 26 Please modify the State Agencies Regulations to allow

10/26/2013
12:01:08 PM
Jacob Vazquez
Jr.
Oakville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:01:08 PM
Ron Napoli Ridgefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:01:49 PM
Glen
Fongemie
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/26/2013
12:02:19 PM
Steve Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:02:19 PM
Roger
Harwood
Manchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits to Carry handguns to carry a
Specifically:

You still haven't figured out the bad guys don't care about gun
laws and this gives them another safe zone to rape and rob
people.
10/26/2013
12:03:16 PM
Gary
Anderson
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:03:48 PM
Jim zaiko Naugatuck I don't know Legal carry of
firearms in state
We as legal citizens should be able to carry weapons on state
and a moped federal forests
10/26/2013
12:04:47 PM
Jim zaiko Naugatuck I don't know Legal carry of
firearms in state
We as legal citizens should be able to carry weapons on state
and federal. federal forests.
10/26/2013
12:05:38 PM
Lazarus
Alperovich
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
12:05:58 PM
John Koenig Marlborough Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:07:05 PM
Craig Donacki Stonington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:08:49 PM
Jose Nieves new britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.
10/26/2013
12:09:24 PM
Brian Green Lebanon Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2
Governor Malloy,



and


Thanks very much.
Brian Green
10/26/2013
12:09:57 PM
James D.
Iannone
West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forest a
23-4-1(c) and 26-
66-2

10/26/2013
12:10:11 PM
Ryan Nobrega West
Hartford
Emergency Services
and Public
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
12:10:11 PM
Ryan Nobrega West
Hartford
Emergency Services
and Public
Protection, Dept Of
Hunting on Sunday Please pass a law to allow for hunting on Sunday's during the
states regular hunting seasons.
10/26/2013
12:11:03 PM
Christopher
Dyer
Ashford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:11:16 PM
Joseph Locke Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:11:31 PM
ransey bridgeport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:12:37 PM
Cindy
DeAngelis
Marlborough Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:13:43 PM
Jeff Daricek Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
We should be allowed to carry a firearm with in the state parks
for personal protection. I for one hike all over the state forests
and bring my camera which is worth alot of money. I would feel
safer when i am alone in the middle of the woods with my pistol
to protect me from all things wild. On top of that with all the
local reports and all the sounds the packs of coyotes have been
making lately i am less likely to hike in the woods with no
protection now.
10/26/2013
12:13:58 PM
Matthew Woodbury Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/26/2013
12:15:44 PM
Nick Meriden Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/26/2013
12:15:57 PM
John B. Sterry,
Jr.
Ye Connecticut
Gun Guild
Portland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
12:16:09 PM
Steven zA
Bruno
Governor's Office carry in parks and
STATE FORESTS
Should be legal 10/26/2013
12:16:15 PM
Richard
Zlotnick
Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
State Forests/Pa
23-4-1(c) and 26-
66-2
- Remove the prohibition on the "carrying of firearms" in
Section 23-4-1(c) of the Connecticut Agencies Regulations
and revolvers (including handguns using center fire ammunition)
10/26/2013
12:17:15 PM
Raffaele
LaPietra
Greenwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:18:51 PM
Michael
Prince
Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:20:17 PM
David Butler North Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 and 26-66-
2

10/26/2013
12:22:08 PM
Kristopher
Kauffman
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:22:31 PM
Peter Levanti East Lyme Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:23:25 PM
Lyle Sendlein Marlborough Emergency Services
and Public
Protection, Dept Of
Carry of handguns
on state lands
I would like to respectfully request that the prohibition on
carrying handguns for personal protection in state parks and
forrest be repealed. CT has an excellent permitting process for
handguns that requires significant training in the laws and safe
use of handguns. Pistol permit holders are subjected to state
and federal background checks. They also, in many cases, are
interviewed and approved by their local police chiefs. These are
the people who represent the least threat to public safety and
are the most likely to obey the regulations prohibiting carry on
state lands. The criminals that we need to protect ourselves
from, on the other hand, won't obey the rules (which is what
makes them criminals). This makes this just another example of
nonsensical "gun free zones" that benefit noone but the
criminals. Please repeal this well intentioned, but absolutely
pointless and harmful policy.

Thank you,
Scott Sendlein
10/26/2013
12:26:04 PM
Colin Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:26:46 PM
Colin Bristol Energy and
Environmental
Protection, Dept Of
Sunday Hunting The regulation prohibiting hunting on Sunday is outdated and
services no purpose. It is extremely hard for hardworking 9-5
citizens to find the time to hunt, especially when you cut out one
day the majority of the public has free. Please make this right.
10/26/2013
12:33:15 PM
THOMAS
COLE
Windsor
Locks
Energy and
Environmental
Protection, Dept Of
CARRYING
HANDGUNS IN
STATE FORESTS.
23-4-1(c) AND 26-
66-2

10/26/2013
12:34:46 PM
Paul Weiss Monroe Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2


10/26/2013
12:37:24 PM
Jonathan
Fillion
west hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:39:32 PM
Michael
Folsom
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:40:33 PM
Jeffrey
Sanborn
East Haddam Energy and
Environmental
Protection, Dept Of
handguns in state
forests & parks
23-4-1(c) &26-66-
2

10/26/2013
12:42:11 PM
Roger Bohan Harwinton Energy and
Environmental
Protection, Dept Of
State parks

10/26/2013
12:42:23 PM
Mike Sharrio Oakdale Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:45:08 PM
Chris Demisch Stamford Energy and
Environmental
Protection, Dept Of
Legal Concealed
Carry in State Park
23-4-1(c) and 26-
66-2


This change would allow trained, licensed, background-checked
individuals to carry a concealed firearm into state parks and
forests for the purposes of self-defense. There is no reason why
simply being in a park should mean giving up the right of self-
defense, especially in a location where predatory animals (bears
etc) may be present and there may be little or no cell phone
service to call for help.
10/26/2013
12:46:05 PM
Sean Kaplan Wolcott Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1c and 26-
66-2


10/26/2013
12:47:30 PM
Shawn Strauss Southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
12:48:33 PM
Luciano B.
Cabral
naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
12:50:38 PM
James L.
Russell
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Respectfully I ask that The State Please modify the State
Agencies Regulations to allow individuals with valid Permits to
Carry Pistols and Revolvers to carry a handgun for self defense
while in CT State Parks and Forests. Specifically:

10/26/2013
12:52:05 PM
Jon Quint Energy and
Environmental
Protection, Dept Of
Handguns in State
parks and Forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
12:52:12 PM
Patrick James
Devine
Independent Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:53:23 PM
Roger
Waterhouse
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:54:25 PM
Mark C Poulin
Jr
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:55:07 PM
Stephanie
Rice
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:56:28 PM
joe busher east haddam Environmental
Quality, Council On
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:56:54 PM
Robert & Toni
Flanigan
Energy and
Environmental
Protection, Dept Of
conceal carry in
state parks
We go through a lot to obtain our permits and now you are
dictating what we can and can not do. There is a reason for
conceal carry and especially in state parks. Its for protection not
only from the two legged predators out there but for unforeseen
4 legged ones. We go have to jump through hoops of fire to get
them and would like to exercise our right to carry them. Face
too many people are being attacked everyday and all it takes is
for one person to try and attack the wrong person. In most
cases the police will not get there in time and I would rather
save my life then lose it waiting for law enforcement. So Gov
Malloy stick to issues at hand that are more important like the
economy and leave us law biding citizens alone.
10/26/2013
12:57:05 PM
Jeffrey O.
Lockwood
Plantsville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
12:57:07 PM
Matthew
Zangari
Berlin Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2


10/26/2013
12:58:16 PM
Ralph J
DeStefano
Thomaston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2



Sincerely,
Ralph J DeStefano
10/26/2013
12:58:20 PM
Brian
Sokolowski
Seymour Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
1:01:36 PM
Manuel
Medina
manchester Energy and
Environmental
Protection, Dept Of
Regulations to allow
individuals wi
23-4-1(c)26-66-2 Please modify the State Agencies Regulations to allow
firearms in Section of the Connecticut Agencies Regulations
Add an exemption to to allow the carrying of pistols and
the purposes of self defense. 23-4-1(c)26-66-2
10/26/2013
1:03:09 PM
Robert C
Boughner
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:05:10 PM
Michael
Scaduto
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks
23-4-1(c) and 26-
66-2
Forests.Pistol Permit holders go through training, background
checks and pay a lot of money to obtain these permits. Simply
being in a State Forest or Park does not protect someone from
being the victim of a crime. In fact, individuals in these Parks and
Forests are more vulnerable due to there vast size and lack of
law enforcement presence.

Specifically:


Thank you for your consideration,
10/26/2013
1:06:25 PM
Joseph P
Birkenberger
Litchfield ct Energy and
Environmental
Protection, Dept Of
Pistol permit valid in
state forest
23-4-1(c), 26-62-2 The state needs to remove the restrictions on personal
protection in these areas. Unless the the state can guarantee my
safety in these areas it should not restrict my ability to do so as a
pistol permit holder. The states,(misguided, ignorant and week)
legislators, along with govoner McGoo have given the media and
deranged criminals more power to create legislation than the
law abiding citicens of this state.If they would inforce the laws
allready on the books there would be less problems. Bad people
doo bad things, this will never change. The lawes recently
enacted have only restricting law abiding citicens ability to
protect themselves. Bad people dont abide by laws.
10/26/2013
1:07:35 PM
Joseph Tonski Rockville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:08:06 PM
Russell E.
Cutler Sr.
Killingly Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and26-
66-2
individuals with valid permits to carry pistols and revolvers, to
carry a handgun for self defense, specifically.
1)Remove the prohibition on the carrying of firearms in Section
23-4-1 (c) of the Ct. Agencies Regulation.
2) Add an exemption to 26-66-2, to allow the carrying of pistols
and revolvers. ( including handguns using center-fire
ammunition ) for the purposes of self defense.
10/26/2013
1:09:01 PM
Robert Moore Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:10:10 PM
elvis celebic wethersfield Energy and
Environmental
Protection, Dept Of
23-4-1 (c) and 26-
66-2
Regulations
10/26/2013
1:11:51 PM
steve mcq Energy and
Environmental
Protection, Dept Of
carry handguns in st
forest & parks
23-4-1(c) and 26-
66-2

10/26/2013
1:12:34 PM
Terry Lyons Oakdale Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
23-4-1(c) of the Connecticut Agencies Regulations,
10/26/2013
1:12:36 PM
Michael Golas Plantsville Energy and
Environmental
Protection, Dept Of
Carry
Handguns/State
Forest/Parks
23-4-1 (C) Please modify the State Agencies Regulations to allow

10/26/2013
1:13:54 PM
Dain
Vanderminde
n
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:17:09 PM
Brett Small Energy and
Environmental
Protection, Dept Of
carry handguns in
state forests
23-4-1(c) and 26-
66-2


10/26/2013
1:17:46 PM
Kit
Vanderminde
n
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:17:53 PM
Richard K.
Massini
North Haven,
CT
Energy and
Environmental
Protection, Dept Of
Carring handguns-
State Forest&Parks
23-4-1(c) and 6-
66-2

-Remove the prohibition on the 'carrying of firearms' in Section

for the purposes of self protection.
10/26/2013
1:17:57 PM
Joshua
Beaulieu
Tolland Energy and
Environmental
Protection, Dept Of
handguns in state
parks
23-4-1c, 26-66-2 Please modify the State Agencies Regulations to allow
Regulations Add an exemption to 26-66-2 to allow the carrying

10/26/2013
1:19:22 PM
Ken Main Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:21:24 PM
Alexander
welford
torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 and 26-66-
2
of pistols and revolvers (including handguns using centerfire
ammunition) for the purpose of self defense.
10/26/2013
1:23:23 PM
Terry A Birt Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits to carry pistols and revolvers to a
carry a handgun for self defense while in CT State Forests and
Parks> Specifically:

- Remove the prohibition on the "carrying of firearms" in section
- Add exemption to 26-66-2 to allow the carrying of pistols and
revolvers(including handguns using center fire ammunition) for
the purpose of self defence.
10/26/2013
1:24:36 PM
William Sprague Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:24:44 PM
Gregory Funk Marlborough Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:25:18 PM
Frank
Vumbaca
meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:27:20 PM
Edgar Ramirez Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:27:45 PM
William
Talarico
Plantsville I don't know allow individuals
with valid Permit
10/26/2013
1:27:50 PM
John
Mazzotta
Old Lyme Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) &26-66-
2

10/26/2013
1:33:24 PM
Justin Wiggins Waterford Energy and
Environmental
Protection, Dept Of
Handguns in state
forests and parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
1:36:14 PM
John
Kornegay
Barkhamsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:36:32 PM
Patrick Mike Wethersfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
1:36:46 PM
Scott E Berg Shelton Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in CT forests
23-4-1(c) and 26-
66-2

10/26/2013
1:40:53 PM
thomas
petrunti
east granby Energy and
Environmental
Protection, Dept Of
carrying hand guns
in state forest
23-4-1(c) 26-66-2 please modify the states agencies regulations to allow
carry a handgun for self defense while in CT state parks and
forest. please remove the prohibition on the 'carry of firearms'in
section 23-4-1(c) of the connecticut agencies regulations -add
an exemption to 26-66-2 to allow the carry of pistols an
revolvers for the purposes of selfdefence
10/26/2013
1:41:22 PM
Jon Hibbard East Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks an
23-4-1(c) and 26-
66-2
23-4-1(c) of the Connecticut Agencies Regulations. Many people
are mugged, raped and assulted in State parks and forests.
Registered gun owners should be able to carry. In addition to the
criminals that rome the parks and forests, there is always the
possiblity of someone running into a bear or other animal, that
may feel threatened by the human and deside to attack. Law
abiding guns owners are not the problem in this state.
10/26/2013
1:42:41 PM
Ismael New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:43:13 PM
Dennis
Golden
Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1 c & 26 66 2 Please modify the State Agencies Regulations to allow


D Golden
10/26/2013
1:45:59 PM
Donald Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:50:32 PM
Karin Blaschik East Haddam Energy and
Environmental
Protection, Dept Of
Carrying handguns
state forest-park
23-4-1(c) and 26-
66-2


Thank you
10/26/2013
1:51:18 PM
Jeffrey
Bertholf
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
1:51:29 PM
Salvatore &
Frances
DeSimone
Washington
Depot
Elections
Enforcement
Commission, State
carrying handguns
in State Forests
23-4-(c) &26-66-2 Before securing a handgun permit we must qualify to shoot,
therefore, why can't we carry in State Forests and Parks.
10/26/2013
1:53:20 PM
Carl E.
Passafiume
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and
26-66-2


10/26/2013
1:53:57 PM
Matt Odishoo Berlin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
1:56:00 PM
Carl
Ornowski
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
2:03:24 PM
Walter
Radziszewski
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
As a former Marine and licensed pistol permit holder, I earned
the right to carry anywhere within the state of Connecticut!
10/26/2013
2:06:54 PM
Warren
Bierwirth
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:07:07 PM
Nicholas
DuBaldo
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:07:45 PM
Thomas Grady Ledyard Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:09:12 PM
Ben Walker Bridgeport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
2:15:31 PM
William P.
Keller
Bethel Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:16:53 PM
Alex Faulkner Bethlehem Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests

10/26/2013
2:18:39 PM
Robert Avery Colchester Energy and
Environmental
Protection, Dept Of
Hand guns in State
forests and park
23-4-1(c) and 26-
66-2
carry a handgun while in CT State Parks and Forests.
Specifically:- Remove the prohibition on the carrying of
Regulations. The Connecticut Constitution (Article First, 15)
gives every citizen the right to bear arms in defense of himself
and the state.
10/26/2013
2:18:48 PM
John Torrington Energy and
Environmental
Protection, Dept Of
Handguns in state
forest
23-1-4c and 26-
66-2
Regulations
10/26/2013
2:18:54 PM
John
Hennessey
Democrat Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
Parks & Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:20:23 PM
Wade
Frechette
Putnam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you Governor Malloy
10/26/2013
2:21:24 PM
santo
mazzarella
canton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:23:02 PM
Ronald Fairfield Energy and
Environmental
Protection, Dept Of
Carry pistol in parks
an State fore
23-4-1 The right to carry pistol in State forest and parks 10/26/2013
2:27:35 PM
Tahra
Erickson
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:31:39 PM
Timothy R
Ryan
Ellington Energy and
Environmental
Protection, Dept Of
Carry in State Parks 23-4-1 c & 26-66-2 Please modify the State Agencies Regulations to allow

10/26/2013
2:32:01 PM
Joseph F.
McVety Jr
Environmental
Protection, Dept Of
Handguns in State
Forests and Parks
23-4-1(c) and 26-
66-2In
10/26/2013
2:33:21 PM
Judah Thomas Energy and
Environmental
Protection, Dept Of
arrying handguns in
State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:34:26 PM
Luke R
Nearine
R South
Windham
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:35:09 PM
Stephen
Scarpa
Oakdale Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
2:37:12 PM
Thomas
Phelps
Lisbon Energy and
Environmental
Protection, Dept Of
Carry Handguns in
State Forests and
23-4-1(c) and 26-
66-2


These locations are managed and funded through tax dollars
from citizens who should have the choice weather or not to
carry a firearm for protection in these locations.
10/26/2013
2:38:53 PM
Stephen
Bennett
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Currently someone who is licensed to carry pistols/revolvers
cannot legally carry a handgun/revolver in Connecticut state
parks and state forests. Please modify the State Agencies
Regulations to allow individuals with valid Permits to Carry
Pistols and Revolvers to carry a handgun for self defense while in
CT State Parks and Forests. Specifically:

10/26/2013
2:39:32 PM
Scott Bailey Enfield Energy and
Environmental
Protection, Dept Of
10/26/2013
2:42:54 PM
Phil Lang South Kent Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:43:16 PM
Aaron
Freeman
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


I do not want the animals to know I'm unarmed,
but I've no objection to their civil obligation of marksmanship.
10/26/2013
2:44:13 PM
Gregory
Boivin
Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
As someone licensed and qualified to carry a firearm in the State
of Connecticut, I see no reason why it should be unlawful to
carry my handgun in a State Forest or State Park.


10/26/2013
2:46:18 PM
KAROL
DEPTULA
ELLINGTON Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:46:42 PM
Gary B
Coburn
Roxbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:52:40 PM
Edward Carle Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
with valid permits to carry pistols and revolvers, to carry a
handgun for "self defense" while in Ct state parks and forests.
Specifically:

Remove the prohibition on "carrying of firearms" in section 23-4-
1(c) of the Ct agencies regulations.

Add an exemption to 26-66-2 to allow the carrying of Pistols and
Revolvers (including handguns using center-fire ammunition) for
the purposes of Self Defense.

Thank You.
10/26/2013
2:53:15 PM
George Coyle Branford Energy and
Environmental
Protection, Dept Of
carry handguns in
st. parks and for
23-4-1(c) 26-66-2 Allow those with permits to carry to carry in State Parks and
Forest. Remove all regulations against it.
10/26/2013
2:53:54 PM
Dewey Brooks Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:59:25 PM
joe pugliese southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
2:59:42 PM
Armand
Maniccia, Jr.
Environmental
Protection, Dept Of
Carrying handguns
in State Forests


10/26/2013
3:00:39 PM
Adam Czepiel Old Saybrook Energy and
Environmental
Protection, Dept Of
Handgun carry
regulations in state
Handgun permit holders should be able to 'carry'
In state parks

Thanks for the oportunity to comment
10/26/2013
3:05:16 PM
Joseph Lipsky Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying kandguns
in State Forests
23-4-1(c) and 26-
66-2
Respectfully request that you modify the State Agencies

10/26/2013
3:06:09 PM
Matthew
Jorgensen
Columbia Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/26/2013
3:09:20 PM
Lauren
Jorgensen
Columbia Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/26/2013
3:10:16 PM
Amy Kelly Madison Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
3:12:43 PM
john middletown Energy and
Environmental
Protection, Dept Of
handguns in state
forests/parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
3:16:11 PM
Jeffrey
Roberts
Winsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
3:18:11 PM
Linda Combe Rocky Hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
As a woman who likes to hike alone, a lonely state forest or park
is the FIRST place I would want to be able to protect myself.



Thank you.
10/26/2013
3:19:11 PM
Merrill Brown Ridgefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
State Forests & P
23-4-1(c) & 26-66-
2
Regulations
10/26/2013
3:22:26 PM
Anthony
Perrelli
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Modify the State Agencies Regulations to allow individuals with
for self defense while in CT State Parks and Forests. Specifically:
10/26/2013
3:26:44 PM
Edward J.
Carson Jr.
Hamden Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2
23-4-1(c) and 26-
66-2

10/26/2013
3:31:04 PM
Jose L
Santiago
Environmental
Protection, Dept Of
Carrying handguns
state forest/park


Thank you for your time
10/26/2013
3:32:18 PM
Allen Egerton Waterford Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
3:34:37 PM
Paul Reilly Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
3:36:16 PM
Rick
Weinberger
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
3:36:34 PM
Carl Kniess Wallingford Energy and
Environmental
Protection, Dept Of
carry handguns in
state parks
23-4-1(c) and 26-
66-2
with a valid permit to carry pistols and revolvers to carry a hand
gun for selfdefense while in ct state parks and forest .
Specifically

-Remove the prohibition on the carrying of firearms in section

and revolvers ( including handguns using centerfire ammunition
10/26/2013
3:37:55 PM
Norman
Breed
Ledyard Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
3:38:12 PM
william prospect Energy and
Environmental
Protection, Dept Of
carrying firearms for
self protecti

10/26/2013
3:40:05 PM
Alexander
Tabak
CCDL Milford Energy and
Environmental
Protection, Dept Of
Carry a Handgun in
Forests and Park
23-4-1(c) and 26-
66-2

10/26/2013
3:43:33 PM
william prospect Governor's Office Firearms Please modify the State Agencies Regulations to allow

for the purposes of self defense. Remember and i don't think
you do. We are all good citizens and No Honest hard working
Citizen is looking for Gun Violence. in fact it is just the opposite.
However, by taking our ability to carry a gun for self
preservation. is wrong in mine and many others opinions. The
Police are not there when Violent Crime's are committed against
Good citizens. they Usually arrive after all is said and done. . I
know this as FACT I am an innocent victim of a Robbery and
Shooting which almost left me dead. I still do not understand the
Logic of taking a person's right to carry a gun to help them
protect against Criminals that carry guns. I do carry a gun and so
does my wife. The furthest thing from our minds is to commit
Violent acts against a fellow citizen. I hope you find it in this
reading it does make common sense.
I know you hate guns I know you cant stand people that carry
guns for protection. I am not sure why? You have body guards
that are armed for your protection. WHY? same reason we feel
the need to carry a Firearm. We/You do not want to to be a
victim of gun violence. Just like you. You have the same right as I
do please consider. looking at things differently rather than
blaming the good citizen's that want nothing more than to
protect themselves.
Unless it is true that this taking guns out of the hands of all of
the Model citizens is truly just about controlling them. I hope
that is false. thank you very much.

Sincerely
William L. Kuhns
10/26/2013
3:45:50 PM
Joseph A.
McNally
Life member NRA ,
North American
Hunter
Environmental
Protection, Dept Of
carrying handguns
in state parks an
23-4-1 26-66-2 Please modify the State Agencies Regulations to allow

10/26/2013
3:48:18 PM
Mahesh
Reddy
Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
What's this, is it true that we cannot carry a concealed weapon
on State Park property. Why would you like to introduce a new
permit to carry a permit so additional charges can be levied on
the Citizens of CT.

Let America be, don't turn it into a Soviet State, they (Soviet
States) don't work!
10/26/2013
3:48:44 PM
Stephen
Crowley
Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
3:51:35 PM
Michael
Goode
Berlin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/26/2013
3:51:46 PM
Francis
Valente
Shelton Energy and
Environmental
Protection, Dept Of
Carring handguns in
State Forests a
23-4-1(c) and 26-
66-

10/26/2013
3:53:07 PM
Byron &
Theresa Tillett
Windsor Banking, Dept Of Predatory Banking
Practices
Make these banks process payments as they come in - we have
been making payments every 2 weeks so that we'd end up
paying the mortgage off 7 years early on our 30 yr mortgage
(currently 5.25% started at 6.5% prior to the streamline) & when
Freedom Mortgage did the stream line to lower our interest
rates in late 09 they stopped processing our payments as they
went in electronically to them & now they are trying to charge
us over $6,000 + even though we've been making these
payments all along from the start in Feb 09 with our Initial
Mortgage & they told us to stop making the payments until the
streamline was completed because it was changing the numbers
during the processing - at the Housing Help Event at the
Convention Center this Tuesday Oct 22 the Urban league Worker
told us to be late & not make our customary payment while she
tries to get Freedom Mortgage to come to the table but she
does not think that they will cancel out the fees they are wrongly
trying to force upon us even though we've been making
payments all along & FHA loans Do Not Have Pre-Payment
Penalties the way that Freedom Mortgage is not processing the
payments & charging fees they are acting in a predatory manner
& imposing upon us Pre-Payment Penalties & this is just wrong
10/26/2013
3:53:58 PM
william
connole
granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Fore
23-4-1(c) and 26-
66-2

10/26/2013
3:54:09 PM
David J.
Ribnicky
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c) and 26-
66-2

10/26/2013
3:54:19 PM
Steven R.
Urbanski
Suffield Energy and
Environmental
Protection, Dept Of
Carrying Handguns
State Forest/Park
23-4-1 (c); 26-66-2 Hi-
I request our state modify our agency regulations to allow
carry a handgun for self defense and protection of others while
in CT State Parks and Forests.



Our state permit holders have already been under review and
from my experience are serious, responsible, and an asset to our
communities. Having legal permit holders unarmed protects no
one but the criminals who do not obey our laws. In addition,
many parks/forests are often isolated areas placing those on site
in greater jeopardy if trouble arises.

Respectfully,

Steven R. Urbanski
Suffield, CT 06078
10/26/2013
3:55:48 PM
Cathy
Bloxsom
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1 (c) & 26-
66-2
please modify state agencies regulations to allow individuals
handgun for self defense while in Connecticut State Parks and
Forests .Specifically: remove the prohibition on the carrying of
firearms in section 223 -4 -1 (c) of the Connecticut agencies
regulations and add an exemption 26-66-2 to allow the carrying
of pistols and revolvers( including handguns using centerfire
ammunition) for the purposes of self defense. thank you for your
time. sincerely ,Cathy Bloxsom
10/26/2013
3:57:31 PM
Garry Satula Bethlehem Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:00:00 PM
Steven Palmer Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2

10/26/2013
4:02:15 PM
Pat De Filio Cheshire Energy and
Environmental
Protection, Dept Of
carry handguns in
state forest
Please allow people with gun permits to carry handguns in state
forests.

Remove the prohibition on Section 23-10
10/26/2013
4:03:05 PM
Ray Bevis Wolcott Energy and
Environmental
Protection, Dept Of
Firearms in state
parks and forest
Please change the prohibition on carrying an legal firearm while
in state parks and forest.
10/26/2013
4:07:03 PM
Robert
Simeone
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Connecticut residents should be able to defend themselves
anywhere. Our lives are just as valuable outside the home as
they are inside the home.
10/26/2013
4:09:06 PM
Kristopher
Smith
Brooklyn Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:11:31 PM
Timothy New
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the State Agency's Regulations to allow individuals
Specifically:

10/26/2013
4:14:12 PM
CJ Hoppi Canton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:15:50 PM
Bob Erickson Energy and
Environmental
Protection, Dept Of
carrying handgun in
state forests
23-4-1(c) and 26-
66-2
I do a lot of hiking with my family at state forest and town trails
and have had a ct hunting lic. that a require hunter safety state
classes. Also have my ct. pistol permit and how can it be
questioned about me carrying a pistol in any state forest or park.
10/26/2013
4:21:15 PM
Ryan Mateyov Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:23:54 PM
Frank bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:25:02 PM
James Miller wilton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please allow individuals with valid Pistol Permits to carry a
Specifically:


Sir,
we are law abiding middle class citizens and should not be
punished nor denied our rights. Please direct your efforts to
removing guns possessed by criminals. A close inspection would
reveal we are very different groups of people.

Thank you for listening.
10/26/2013
4:25:46 PM
Todd R. Smith Woodstock Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:26:51 PM
Philip
Einsmann Jr
Westbrook Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:27:14 PM
Stephen
Shuttleworth
Ledyard Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1 (c) and 26-
66-2
-Remove the prohibition on the "carrying of friearms" in Section
and revolvers( including handguns using center fire ammunition)
10/26/2013
4:27:34 PM
Mike Middlefield Energy and
Environmental
Protection, Dept Of
carrying pistols in
state parks
23-4-1c & 26-66-2 Please modify the State Agencies Regulations to allow

and revolvers
10/26/2013
4:28:56 PM
Frank
Holleran
Environmental
Protection, Dept Of
Carring handguns in
state forests a
23-4 26-66-2 please modify the state Agencies Regulations to allow indivduals
handgun for self defense while in CT state parks and forests.
Specifically
Remove the prohibition on the carring of firearms in Section 23-
4-1(1) of the Connecticut Agencies Regulations
add an exemption to 26-66-2 to allow the carrying of pistols and
revolvers including handguns using center fire ammunition for
10/26/2013
4:29:38 PM
Dave Zyjewski Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
26-66-2. 23-4-1(c) Please modify the State Agencies Regulations to allow
10/26/2013
4:31:01 PM
Bill Hansen North Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:31:59 PM
Brian Gaynier Higganum Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state Forests
23-4-1(c) & 26-66-
2

10/26/2013
4:32:04 PM
Anthony
Dilorenzo
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:35:09 PM
Faustino
Barlan
Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
on State Forests
23-4-1(c) and 26-
66-2
Text 10/26/2013
4:35:19 PM
Eugene R.
Pino
Meriden Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2


As a Senior I still enjoy the open state parks and forest. But
feeling safe is one thing I want. Carrying a firearm makes me
feel that way. Without the option of carrying I would not feel
safe in the state parks or forest.

Thank you

10/26/2013
4:36:34 PM
Carl Barone Trumbull CT Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State
23-4-1(c) and 26-
66-2

10/26/2013
4:37:33 PM
Rod Doyon Moodus Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:39:03 PM
Tom Miller East Haddam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:42:28 PM
Elizabeth
Johnson
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:42:35 PM
Jim Bartlett Scotland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the States Agencies Regulations to allow
individuals with valid Permits to carry Pistols and Revolvers to
carry a handgun for self defense while in CT state Parks and

- Remove the prohibition on the 'carrying of firearms' in section
- Add an Exemption to 26-66-2 to allow the carrying of Pistols
and Revolvers (including handguns using center-fire
ammunition)for the purpose of self defense.
10/26/2013
4:43:30 PM
Jarod Lojeck Stamford Energy and
Environmental
Protection, Dept Of
Firearms in state
parks
23-41c & 26-662 Please modify the State Agencies Regulations to allow

10/26/2013
4:43:53 PM
Daniel J.
Cewe, Jr.
Glastonbury Energy and
Environmental
Protection, Dept Of
Carrying hHndguns
in State Forests
23-4-1(c) and 26-
66-2
I would like to see the State Agencies Regulations modified to
allow individuals with valid Permits to Carry Pistols and
Revolvers to carry a handgun for self defense while in CT State
Parks and Forests. Specifically:

10/26/2013
4:46:36 PM
Frank C Van
cleef
North Haven Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Please change the State Agencies Regulations to allow
carry a handgun for self defense while in Connecticut State Parks
and Forests. Specifically:- Remove the prohibition on the
carrying of firearms in Section 23-4-1(c) of the Connecticut
Agencies Regulations
10/26/2013
4:46:51 PM
Brian
Mongeau
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:47:57 PM
James Ritchie Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:52:36 PM
Ryan nichols New Britain Emergency Services
and Public
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
4:53:16 PM
Leo Gregoire CCDL Meriden Energy and
Environmental
Protection, Dept Of
enter Carrying
handguns in State
Fo
23-4-1(c) and 26-
66-2

10/26/2013
4:54:50 PM
Richard
Weatherstone
Norwalk Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
4:59:43 PM
Francisco
Pires
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
There should be no difference in our ability to legally carry in our
state forests and or our state parks versus any other open public
land.


10/26/2013
5:01:37 PM
Arthur Daigle Plymouth Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:02:10 PM
Lawrence
Turner
Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:02:26 PM
John
Mulrooney
Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:04:58 PM
Ramon
DeJesus
Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
5:05:09 PM
William
Shields
Enfield Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you!
10/26/2013
5:09:06 PM
Leonard
Mausteller
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:12:22 PM
Eduardo
Torrealba
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:15:02 PM
robert simeone famington Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:20:47 PM
William
Hillman
Bethel Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


As a permit holder, I have been checked out by my local police,
state police, FBI reports. I am a responsible firearm owner, and
as the author of several emails to my Senators, for all practical
use, the originator of some of the changes to storage
requirements enhanced this past year, I am well aware of safety.

Should I be out in the woods, so to speak, I see no good reason
that I should be prohibited from lawful and safe carry.
10/26/2013
5:21:39 PM
John
O'Luanaigh
Concerned citizen Cheshire Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests & Parks
23-4-1(c) and 26-
66-2
Please modify the State Agencies Regulations to allow law
abiding individuals with valid Permits to Carry Pistols and
Parks and Forests.

Specifically:
10/26/2013
5:21:57 PM
Gregory
Michael
Zenger
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:22:36 PM
Albert LaTour Plainfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:24:59 PM
Rosellen
Daddario
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:25:44 PM
Ted Carnevale Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please revise the State Agencies Regulations so that individuals
with valid permits are allowed to carry handguns for self defenxe
in Connecticut State Parks and Forests. In particular, please
(1) remove the prohibition on "carrying of firearms" in Section
23-4-1(c) of the Connecticut Agencies Regulations,
and
(2) add an exemption to 26-66-2 to allow carrying of pistols and
revolvers (including handguns that use center-fire ammunition)
10/26/2013
5:26:51 PM
Philip Lang Willington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Due to the fact that criminals will not follow the subject
regulations......


10/26/2013
5:28:51 PM
Edward P.
Aldrich Jr.
Goshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 (c) and 26-
66-2

10/26/2013
5:28:58 PM
Aaron Succow Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:39:13 PM
Edward
Seymour
Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:39:53 PM
Dan Kean Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2
Specifically:

10/26/2013
5:40:45 PM
Dominic Rea West Haven Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2
enough is enough get the illegal handguns off the street you are
taking the easy route by going after the law abiding citizens, get
the criminals I know it is a tougher job but it is one that needs to
be done.
Dominic Rea
10/26/2013
5:41:20 PM
Michael Asid Oxford Energy and
Environmental
Protection, Dept Of
handguns in State
Forests and Parks
23-4-1(c) & 26-
66-2
Regulations
10/26/2013
5:41:36 PM
alex
colombrito
hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
5:45:54 PM
Tom Conti Weston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:45:59 PM
Edward D Lee
Jr
Bristol Energy and
Environmental
Protection, Dept Of
carry of handguns in
state forests
23-4-1 c , 26-66-2 Please modify the State Agencies Regulations to allow

10/26/2013
5:46:00 PM
Chris Conti Weston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
5:46:27 PM
Garrett Foley North
Canaan
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/26/2013
5:49:14 PM
Matthew
Malecot
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks
3-4-1(c) and 26-
66-2

10/26/2013
5:50:38 PM
Claude LaRock Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state Forests
23-4--1(c)and 26-
66-2
10/26/2013
5:53:34 PM
Douglas Frost Independent Rocky hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
6:00:39 PM
Cheryl
Marcinko
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
6:06:01 PM
Cristie Brady Hamden Energy and
Environmental
Protection, Dept Of
Carrying Hand Guns
in State Forests
23-4-1(C)26-66-2 Please modify the State Agencies Regulations to allow

10/26/2013
6:17:47 PM
FRANCES CCDL milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

and (including handguns using center-fire ammunition) for the

I carry only to protect myself and child. I would not feel safe in
woods or secluded areas without my firearm. I want to enjoy all
the state has to offer and feel safe.
10/26/2013
6:21:51 PM
John Ludovico U.S. Citizen Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-
66-2

10/26/2013
6:27:20 PM
Jeffrey Joy Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please remove the prohibition against carrying legal handguns
by permit holders in Connecticut State Parks. Obviously, carrying
a firearm does not endanger the environment or other persons.
A permit to carry for personal protection.

Jeff Joy
10/26/2013
6:29:40 PM
Eric Barkhurst Moosup Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
6:32:45 PM
John M
Donald
Hartford Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest
23-4-1(c) 26-66-2 please modify the state agencies regulations to allowindividuals
Specifically:
Remove the prohibition on the 'Carrying Of Firearms'in section
revolvers (including handguns using center-fire ammunition)for
10/26/2013
6:34:16 PM
Dennis
Cottrell
Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:


10/26/2013
6:38:42 PM
Devin Miles Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
6:40:56 PM
Jennifer
Martinsen
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
6:43:07 PM
Brian Elliott West Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
6:46:21 PM
Michael
Ritucci
Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2

10/26/2013
6:51:23 PM
Michael
F.Cassidy Jr
meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(c) and 26-
66-2

- Remove the prohibition on the 'carrying of firearms'in
section23-4-1(c) of the Connecticut Angencies Regulations
and revolvers
(including handguns using center-fire ammunition)for the
10/26/2013
6:51:35 PM
Gary Jones Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in St Forests&Pks
23-4-1(c) and 26-
66-2



10/26/2013
6:53:27 PM
Jeff Palazzo Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
6:55:37 PM
Vaughn
Powell
Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
6:59:49 PM
William J
Carriere
Norwalk Energy and
Environmental
Protection, Dept Of
Handguns in state
forests/parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
7:01:10 PM
Antone
Goulart III
Bozrah Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:02:30 PM
Joseph Papa,
Jr.
Derby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State parks

10/26/2013
7:03:29 PM
David Russ Thomaston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:04:14 PM
Heather
Wolny
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:05:32 PM
Rocco Toce Thomaston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:05:56 PM
Brian Russ Thomaston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:06:14 PM
Nicholas
Antonucci
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
7:06:36 PM
Michael Silva East Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
7:12:33 PM
christine gray tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:15:00 PM
John
Mclaughlin
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2


10/26/2013
7:16:29 PM
David Cornet Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:18:54 PM
Francis
oneglia
Winsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1c and 26-
66-
Remove the prohibition on the "carrying of firearms" in section
23-4-1c of the Connecticut agencies regulations.
revolvers (including handguns using center fire ammunition) for
the purpose of self defense
10/26/2013
7:19:46 PM
Francis
oneglia
Winsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1c and 26-
66-
23-4-1c of the Connecticut agencies regulations.
10/26/2013
7:23:37 PM
Gregory D
Edge
Stafford
Springs
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:23:52 PM
Anthony
Kronkaitis
Danbury Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
7:24:57 PM
Joshua
Stevens
Southbury CT Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:26:00 PM
Alfred H
Comeau
Concerned citizen
CT PISTOL PERMIT
holder
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
7:26:21 PM
Kenneth
Heidkamp
Middlebury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:46:16 PM
Christopher
Sieranski
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/26/2013
7:49:04 PM
Vyto
Konkulevicius
Brooklyn Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
7:49:49 PM
Brett
Ostapowicz
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1 (c) and 26-
66-2
handgun for self defense while in Connecticut state
parks and forests. Specifically:
-remove the prohibition on the'carrying of firearms' in section
23-4-1 (c) of the Connecticut Agencies Regulations
and revolvers (including handguns using center fire ammunition)
10/26/2013
7:56:34 PM
Joseph
Markim
Environmental
Protection, Dept Of
Handguns in state
forests & parks
23-4-1(c) and 26-
66-2

10/26/2013
7:59:49 PM
Wayne Covill Newtown Energy and
Environmental
Protection, Dept Of
Handguns in state
parks/forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
8:00:14 PM
Joshua Wrinn Norwalk Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) & 26-66-
2
10/26/2013
8:02:43 PM
Joseph
Amirault
East Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 (c) & 26-
66-2


10/26/2013
8:06:13 PM
Joshua Wrinn Norwalk Energy and
Environmental
Protection, Dept Of
Sunday Hunting Please review the law that says there is no hunting on Sundays.
The deer population is way over crowded, and lime disease is
getting worse and worse. I know multiple people who have been
hospitalized multiple times with lime. Hunting could fix both
these problems, but with a normal mans work schedule, there is
never a time to hunt.

There is no reason that we are now allowed to sell alcohol on
Sundays, but law abiding citizens can't hunt. Please change this
law already!
10/26/2013
8:08:32 PM
Steven
D'Onofrio
Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:13:36 PM
Glenn
McIntyre
Weatogue Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:15:11 PM
Allen Patnode Willington Energy and
Environmental
Protection, Dept Of
enter Carrying
handguns in State
Fo
23-4-1(c) and 26-
66-2

10/26/2013
8:15:49 PM
Dean Gould Brooklyn Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/26/2013
8:16:09 PM
phillip
lundgren
greenwich Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
8:18:58 PM
michael
sawrun
connecticut state
resident
easthartford Governor's Office gun control 23-4-1 (c) governor malloy please remove 23-4-1 (c) from CT. state law
books . it is it is useless and contrary since other firearms are
permitted for hunting. also there are people who need to have
protection from would be criminals in the forest. please add #
26-66-2 to the books to allow us law abiding citizens to have the
right to protect ourselves when we and our families enjoy these
beautiful places.
10/26/2013
8:19:24 PM
Kristy
D'Onofrio
Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:19:28 PM
Paul Ferrante Unionville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


I regularly hike with my dog in areas that have coyotes, bobcats
and rabid racoons, not to mention bears. I am always worried
that something might try to attack my dog and I will not have
any way to protect her or myself. I do not want to hunt with a
pistol, I just want it for personal protection.
10/26/2013
8:21:55 PM
Dawn Norris Tolland Energy and
Environmental
Protection, Dept Of
e Forests & Parks 23-4-1(c) and 26-
66-2


10/26/2013
8:24:41 PM
Dwayne
Boulden
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
8:27:12 PM
William Fritch Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/26/2013
8:27:22 PM
Jason lucia Willimantic Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:32:31 PM
Robert Lee CCDL East Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:35:06 PM
Juan Carlos
Santoro
putnam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:38:03 PM
Thomas
Brummett
Canterbury Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State forest/p
23-4-1(c) and 26-
66-2
individuals with valid permits to carry Pitols and Revolvers to
forests. specifically:
23-4-1(c) of the CT Agencies Regulations.
10/26/2013
8:38:40 PM
Collin Sembler Madison Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:39:56 PM
SHARYL
MARINO
NORFOLK Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
8:40:14 PM
Gary Marino NORFOLK Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/26/2013
8:42:01 PM
Bill Bowden Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please also remove the prohibition on the carrying of firearms in
Section 23-4-1(c) of the Connecticut agencies regulations.
revolvers including handguns using center-fire ammunition for
10/26/2013
8:42:13 PM
Vincenza
Carey
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:43:14 PM
David Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:43:29 PM
Dan Fournier Ellington Energy and
Environmental
Protection, Dept Of
Handguns in state
parks/forests
The right to self defense should be allowed in all areas in ct. 10/26/2013
8:46:47 PM
Joaquin
Repollet
CCDL Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
8:47:18 PM
Raul Garcia Simsbury Emergency Services
and Public
Protection, Dept Of
carrying handguns
in state forests
10/26/2013
8:50:29 PM
Jonathan
Rousseau
Environmental
Protection, Dept Of
Carrying handguns
in State Forests


With the amount of money I've spent and background checks
I've gone through to obtain my permit I believe I should have the
right to protect myself and those I care about in state forests.
10/26/2013
8:54:13 PM
Roland
Loranger Jr
Bristol Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests and Parks
23-4-1(c) and 26-
66-2

10/26/2013
8:58:30 PM
William
Grace
East Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1-c 26-6-2

10/26/2013
8:58:34 PM
Christopher
Thiesing
Somers Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state Forrest
23-4-1(c) and 26-
66-2
I often bring my family into the state forests for hikes.
Unfortunately while I am a pistol permit holder and military
officer, I am not allowed to defend myself against wild animals
or criminals that might take advantage of the seclusion to prey
on my family.


10/26/2013
8:59:43 PM
Steve Small Southington Governor's Office State Park Firearm
Regulations

I have a carry permit and, while I hardly ever actually carry my
pistol, I was surprised to hear that I may not legally carry in a
State Parks. It just doesn't make sense. I understand banks for
robberies, governments buildings to keep the whackos easily
detained, or hospitals because they're full of intense situations.
State Parks just don't seem to make common sense to me. Best
regards, Steve
10/26/2013
9:00:22 PM
peter salisbury Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2
individuals with valid permits to carry handguns and revolvers
for self defense while in Connecticut State Parks and Forests,
Specifically:
-Remove the prohibition on the carrying of firearms in section
and revolvers (including handguns using center-fire
10/26/2013
9:01:29 PM
Patrick Brady Manchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:03:34 PM
Hank Altman N/a Killingworth Energy and
Environmental
Protection, Dept Of
Handguns in State
Parks/forests
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
9:05:31 PM
rick baldwin Hartford Aging, Connecticut
Commission on
pistol permits I do have a "carry"permit & my gun probably saved my life on
10-10-13 when I was attacked by two young men,as I got it out
they ran away.I'm 69 & just left St Augustine's Church MARG
meeting.I want to be able to carry wherever I go,including to &
from & even in state parks & beaches.
10/26/2013
9:06:47 PM
Vin Soares Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:07:45 PM
Richard Hiller Tolland Energy and
Environmental
Protection, Dept Of
State Parks With the bear and possibly the mountain lion population
increasing, I would hate to be walking along in my fishing gear
smelling like fish without protection! I also work in corrections
where the clientel really get to know you. Some of them don't
appreciate my line of work. Do I have to spell it out for you!?
10/26/2013
9:07:57 PM
John
Johannemann
North
Stonington
Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/26/2013
9:11:15 PM
F W baldwin Hartford Firearms Permit
Examiners, Board Of
carry permits My gun probably saved my life on 10-10-13 when I was attacked
by two young men on Campfield Ave,just getting my gun out
caused them to flee but not until I was badly injured.
Perhaps permits for honest men over 60 could be relaxed so as
to be easily attainable.
10/26/2013
9:13:42 PM
Joel
Weinstein
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:15:15 PM
David Zeppieri Hamden Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/26/2013
9:18:21 PM
rick baldwin Hartford Governor's Office gun permits I was attacked by two young men on 10-10-13 & escaped more
grievous injury only by getting my gun out,which caused them to
flee. Perhaps permits for the elderly could be expedited & made
much easier for those over 60 without a felony.
10/26/2013
9:18:24 PM
John Harmon weatogue Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Because of the criminal and wildlife dangers possibly faced when
hiking, please modify the State Agencies Regulations to allow

thank you
10/26/2013
9:25:13 PM
Richard
DeWick
Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Carrying handguns in State Forests and Parks
10/26/2013
9:39:24 PM
William
BArbour
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:40:33 PM
Dean
Johnston
Litchfield Energy and
Environmental
Protection, Dept Of
carring handguns in
state forests a
23-4-1(c) and 26-
66-2
10/26/2013
9:42:04 PM
Matt Jensen MANSFIELD Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:43:50 PM
Richard E
Panzella
Haddam Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1 (c) 26-66-2 Please modify the state agencies regulations to allow persons
handgun for self defense in state parks and forests. Specificly:
Remove the prohibition on " carrying of firearms" in section 24-
4-1 (c) in Conneticut Agencies Regulations.
revolvers (including hanguns using centerfire ammunition) for
10/26/2013
9:46:58 PM
Matthew
McBrien
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
9:51:40 PM
ANDRE
BOURASSA
CDDL BRISTOL Emergency Services
and Public
Protection, Dept Of
23-4-1(c) and 26-66-
2
Section 23-4-1(c) Please modify the State Agencies Regulations to allow

- Remove the prohibition on the 'carrying of firearms' in the
Connecticut Agencies Regulations
10/26/2013
9:52:04 PM
Douglas
Sharafanowic
h
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:


Thank you for your consideration.

Sincerely,
Douglas Sharafanowich
Milford, CT
10/26/2013
9:53:02 PM
edward s.
maccio
Bristol Energy and
Environmental
Protection, Dept Of
enter Carrying
handguns in State
Fo
23-4-1(c) and 26-
66-2

10/26/2013
9:54:42 PM
Raymond
Gietler
Woodstock
Valley
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/26/2013
10:05:47 PM
ken brauer Energy and
Environmental
Protection, Dept Of
carrying handgun in
state forrest
23-4-1(c) and 26-
66-2
with the increased sightings of bear and other threatning
animals why cant a person who has gone thru the checks and
training needed to get a ct pistol permit be permitted to carry
there weapon
10/26/2013
10:07:31 PM
Mark Norko North Haven Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state forest

10/26/2013
10:10:34 PM
Tim Roberts Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:10:46 PM
Jack Cook Bethlehem Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in state parks
23-4-1c and 26-
65-2


10/26/2013
10:10:48 PM
anthony
falanga
north
branford
Energy and
Environmental
Protection, Dept Of
carrying handguns
in State forests
23-4-1(c) and 26-
66-2
10/26/2013
10:19:56 PM
Robert T Kelly
II
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:23:10 PM
Cory Duksa Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:24:49 PM
George
Robinson
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

for the purposes of self defense. Attacks by coy dogs and
Coyotes on people are happening more and more often and the
basic right of a hiker or explorer to protect themselves against
these attacks should be considered a personal right.
10/26/2013
10:30:18 PM
Rich Berlin Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks
23-4-1(c) and 26-
66-2

10/26/2013
10:30:53 PM
Michele
McBrien
Environmental
Protection, Dept Of
Carrying pistols in ST
Forests & Pa
23-4-1(c) and 26-
66-2


10/26/2013
10:32:00 PM
Jeffrey C Hall Stonington Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:33:19 PM
Keith Soucy Tolland Energy and
Environmental
Protection, Dept Of
Carry Handguns in
State Forests and
23-4-1(c) and 26-
66-2

10/26/2013
10:43:40 PM
Hector Torres Bridgeport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
10:51:35 PM
Nicholas
Lupacchino
Eastford Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations

As a law abiding and permitted carry citizen we have passed all
training and background requirements to be able to carry our
handgun responsibly in most of CT. It is ridiculous that we are
forbidden to carry in secluded and rural areas of the state parks
and forests.
10/26/2013
10:55:14 PM
Louis Cipriano Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:03:14 PM
GAIL
WHITRIGHT
MIDDLETOW
N
I don't know GUN CONTROL THERE SHOULD BE A TOTAL ANALYSIS OF ALL GUN CONTROL
LAWS IMPLEMENTED BY THIS ADMINISTRATION AND NOT
SUPPORTED BY THE MAJORITY OF CONNECTICUT RESIDENTS -
YOU HAVE ENDANGERED ALL OF US
10/26/2013
11:03:23 PM
Donna
Cipriano
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:03:34 PM
Dan Burton Ledyard Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/26/2013
11:18:05 PM
Joseph E.
Kushner
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2


Respectfully,
Joseph E. Kushner
10/26/2013
11:20:39 PM
Ilya Korman Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
CT Forests/parks
23-4-1(c) and 26-
66-2

10/26/2013
11:40:49 PM
William New London Energy and
Environmental
Protection, Dept Of
Carry Handguns
StateForest & Parks
23-4-1(c) and 26-
66-2

10/27/2013
12:00:35 AM
William New London Energy and
Environmental
Protection, Dept Of
Carry Handguns
StateForest & Parks
23-4-1(c) and 26-
66-2

10/27/2013
12:00:35 AM
Anna
Bongiorno
Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/27/2013
12:02:20 AM
Brad Strogoff Vernon Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/27/2013
12:37:32 AM
Edward Seder Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
12:38:25 AM
Robert N.
Starr
Environmental
Protection, Dept Of
Handguns in State
Forests and Parks
23-4-1(c) and 26-
66-2
Forests.
Specifically:
Remove the prohibition on the "carrying of firearms" in Section

10/27/2013
12:47:55 AM
Wesley Moss Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
12:56:54 AM
Jonathon L.
Ensign
Wethersfield Energy and
Environmental
Protection, Dept Of
handguns in state
forests and park
Reg. Sect. 23-4-
1(c) 26-66-2
Please modify the state agencies regs. to allow persons with
valid permits to carry pistols and revolvers to carry handguns for
self defence while in state parks and forests.
Specifically:
Remove the prohibition on carrying firearms in Sect. 23-4-1(c) of
the Ct. State Agencies Regulations.
Add an ezxemption to 26-66-2 to allow the carrying of pistols
and revolvers (including handguns using center fire ammunition
10/27/2013
1:25:45 AM
John
Desrosiers
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Sir,

Forests.

Specifically:


This regulation violates the second amendment to the United
States constitution in that it infringes on the citizen's right to
keep and bear arms to defend him or herself. It also violates
section 15 of the Connecticut constitution for the same reason.

Please remember your oath to defend the constitution. There is
no reason why the actions of a single criminal should ever be
used to negate the rights of millions of law abiding citizens.
10/27/2013
2:49:28 AM
John
Desrosiers
Environmental
Protection, Dept Of
Carrying handgunsin
Forests/parks
23-4-1(c) and 26-
66-2
Sir,

Forests.

Specifically:


This regulation violates the second amendment to the United
States constitution in that it infringes on the citizen's right to
keep and bear arms to defend him or herself. It also violates
section 15 of the Connecticut constitution for the same reason.

Please remember your oath to defend the constitution. There is
no reason why the actions of a single criminal should ever be
used to negate the rights of millions of law abiding citizens.
10/27/2013
2:52:32 AM
Scott
braunstein
Environmental
Protection, Dept Of
3-4-1(c) and 26-66-2 Please modify the State Agencies Regulations to allow

10/27/2013
2:53:19 AM
Douglas
Sanderson
Moodus Energy and
Environmental
Protection, Dept Of
carring handguns in
state forestsan
23-4-1(c) 26-66-2

10/27/2013
4:25:38 AM
Lisa Nilsen Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
4:27:07 AM
Shawn K Acri North Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State forests

10/27/2013
6:27:52 AM
Patricia
Nearine
South
Windham
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
6:33:45 AM
Frank Papa CCDL Newington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
6:40:33 AM
Eric Horgan Beacon falls Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
6:45:49 AM
Richard
DiTullio Jr
Roxbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
6:49:32 AM
Karen Crisci Roxbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
6:52:33 AM
Richard
Lalumiere
Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
r 23-4-1(c) and 26-
66-2

10/27/2013
7:03:33 AM
Nick Provost Brooklyn Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:04:52 AM
Peter Santoro South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:06:09 AM
Shawn Ruest Energy and
Environmental
Protection, Dept Of
Handgunsfor
defense
CTparks/forests
23-4-1(c) and 26-
66-2
10/27/2013
7:18:59 AM
Rod Bedard Pomfret Energy and
Environmental
Protection, Dept Of
Carrying Handgun in
State Forests
23-4-1(c) and 26-
66-2

for the purposes of self defense. Stop making law abiding
citizens seem like criminals.
10/27/2013
7:23:50 AM
Travis Mingo Energy and
Environmental
Protection, Dept Of
Carrying if firearms
in state parks
Section 23-4-1(c)

10/27/2013
7:24:35 AM
Michael Ryan Ellington Energy and
Environmental
Protection, Dept Of
Carry in State Parks 23-4-1 c & 26-66-2 Please modify the State Agencies Regulations to allow

10/27/2013
7:43:37 AM
Frank m
Funaro
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:46:59 AM
Lorenzo
Quijano
Branford Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/27/2013
7:47:48 AM
Paul B.
Kozikowski
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4=1(c) and 26-
66-2

10/27/2013
7:48:09 AM
Michael
Ninteau
Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
for the purposes
10/27/2013
7:57:38 AM
Sean Cahill Shelton Governor's Office right to carry
firearms
Dear Governor Malloy, As a law abiding permit holding gun
owner, I respectfully ask that you would consider legislation that
would allow lawful citizens to carry firearms for protection in our
beautiful state forests and parks.
10/27/2013
7:57:54 AM
James Ward Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Enter 23-4-1(c)
and 26-66-2

10/27/2013
8:01:25 AM
James virgulto Higganum Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4 and 26-66-2 Please modify the State Agencies Regulations to allow

10/27/2013
8:14:10 AM
Noreen
virgulto
Higganum Energy and
Environmental
Protection, Dept Of
Carrying handgun in
ST forest/parks
23-4(c) and 26-66-
2

10/27/2013
8:19:38 AM
michael
merrow
middletown Energy and
Environmental
Protection, Dept Of
carrying handguns
in st forest and
23-4-1(c) and 26-
66-2
the one place we are completely alone is when we are in the
state forest and parks. we should be allowed to protect
ourselves just the same as walking down the street or in our
homes. with the resurgence of coyotes and black bears as well
as the crazy people that seem to be everywhere we should be
able to retain the right to carry in the woods that our permits
allow us to do on the streets. the people that have pistol permits
have already passed all the background checks
required to prove their upstanding citizens. let us protect
ourselves as the law should allow.
10/27/2013
8:30:28 AM
Debra
Iaconiello
Salem Energy and
Environmental
Protection, Dept Of
Carry Handguns-
State Forest/Parks
23-4-1(c) and 26-
66-2
There are many women who visit state parks and forests. We are
either alone, or in small numbers, or with our children. Some of
us are victims of domestic violence and stalking. We are in large
part unable physically to fend off one or more attackers should
we be approached. We should not be prohibited from enjoying
the beautiful parks and forests of Connecticut because we have
lost the right to defend ourselves. As some will suggest, we can't
always "find a man to defend us when we want to go there." We
need the right to protect ourselves. Please remove the
prohibition on the 'carrying of firearms' in Section 23-4-1(c) of
the Connecticut Agencies Regulations. Also, add an exemption to
26-66-2 to allow the carrying of pistols and revolvers (including
handguns using center-fire ammunition) for the purposes of self
defense. Thank you!
10/27/2013
8:33:37 AM
Andrew Bell Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests


10/27/2013
8:42:51 AM
Michael
Gordon
Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:43:03 AM
Susan
Reardon
Windsor
Locks
Energy and
Environmental
Protection, Dept Of
Carry Handguns in
State Forest/Park

10/27/2013
8:51:40 AM
Jorge
Rodriguez
Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:11:23 AM
Jane Kirk Southbury Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
9:11:54 AM
Ross T. Kirk Southbury Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
9:13:45 AM
Lisa Kirk Southbury Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
9:15:59 AM
Daniel Kirk Southbury Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
9:17:42 AM
Andrew
Celinski
Portland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
I am a responsible gun owner, and I hold a valid CT Pistol Permit.
Why does this not apply to State Forest/Parks? This makes no
sense. I must forfeit my right to protect myself and family if I
want to go on a hike? If the goal of this is to reduce poaching,
this is not even close to the least restrictive approach to this.
This regulation conflicts with the CT Constitution.

Please:

10/27/2013
9:20:11 AM
suzanne
ninteau
lebanon Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1c and 26-
66-2
Please adjust regulations to allow individuals with valid permits
to carry pistols and revolvers to carry a handgun for self defense
in state parks and forests, specifically remove the prohibition on
the carrying of firearms in section 23-4-1c of the connecticut
agencies regulations and add an exemption to section 26-66-2 to
allow the carrying of pistols and revolvers, including handguns
using centerfield ammunition, for the purpose of self defense.
10/27/2013
9:23:18 AM
Kevin Ripley Energy and
Environmental
Protection, Dept Of
carry handguns-
state forests/parks
23-4-1(c) & 26-66-
2

10/27/2013
9:24:26 AM
Keith
Hathaway
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:26:07 AM
Joseph Duarte Energy and
Environmental
Protection, Dept Of
Handguns in state
forests/ parks
Regulations
10/27/2013
9:28:21 AM
adam bridgeport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:29:42 AM
Gerald
Barnett
Enfield Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
9:29:45 AM
William
Doucette
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

Help Return The Right To Carry in
State Forests and Parks in Connecticut
Governor Malloy is asking for a wide variety of input from the
public on current regulations that affect Connecticut citizens in
numerous ways.
It is currently a violation of state regulations to carry a firearm
for personal protection in state parks and state forests. Pistol
Permit holders go through training, background checks and pay
a lot of money to obtain these permits. Since the Governor is
asking for change recommendations, please take this
opportunity by using the instructions below.

Visit http://www.governor.ct.gov/malloy/cwp/view.asp...
.

Fill out your Name, Email Address and Town.

field Regulations Agency drop-down, Select "Energy and
Environmental Protection, Dept of"

field Regulation Subject Matter: enter Carrying handguns in
State Forests and Parks

field Regulation Section Number: Enter 23-4-1(c) and 26-66-2

In the Comments enter the following text:


10/27/2013
9:30:10 AM

Kathleen W.
Lauretano
Lakeville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Enter 23-4-1(c)
and 26-66-2


Law-abiding citizens who have gone through the laborious
educational requirements, background checks, paperwork and
fee process should not have their right to carry limited the way it
currently is in State Parks and Forests. They are no more prone
to misusing a firearm there than any place else out in the public
so the restriction is illogical and absurd.
10/27/2013
9:34:35 AM
Michael
Davitt
Emergency Services
and Public
Protection, Dept Of
Handguns in state
forests/parks
Regulations
10/27/2013
9:35:12 AM
mark wootten meriden ct Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Regulation Section
Number: Enter 23-
4-1(c) and 26-66-2


10/27/2013
9:35:50 AM
Bruce Towers Morris Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Those of us who have taken the required safety courses and
successfully passed background investigation have never
constituted a threat to anyone historically and should be able to
exercise our rights under the Constitution of The United States
of America and the Constitution of the State of Connecticut,
should we deem exercising that right necessary within the
confines of Connecticut State Parks and Forests.
10/27/2013
9:36:01 AM
Scott R Norris Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/27/2013
9:40:51 AM
Keith benson East haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:42:15 AM
Jo Ann Roeter A Shelton Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:42:18 AM
Murvin
Tackling
New britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Number: Enter 23-
4-1(c) and 26-66-2

10/27/2013
9:46:13 AM
james
dempsey
enfield Energy and
Environmental
Protection, Dept Of
State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:47:12 AM
Kary Daley Watertown Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests & Parks
23-4-1(c) and 26-
66-2

10/27/2013
9:49:47 AM
Patrick
Smedick
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
individuals with valid Permits to Carry Pistols and Revolvers for
self defense while in CT State Parks and Forests. Specifically:

10/27/2013
9:51:27 AM
Robert
Bamberg
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:54:58 AM
Brian
Duquette
Windsor
Locks
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:59:00 AM
Joseph
Piechowski
Winchester Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest
23-4-1 (c) 26-66-2 Please modify the state agencies regulations to allow individuals
handgun for self defense while in Connecticut state parks and
forest.
Thank You,
Joseph Piechowski
10/27/2013
10:03:16 AM
Wayne
Courtemanch
e
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
10:03:46 AM
Stephen
Bukowsky
independent Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
10:04:00 AM
rebecca
littmann
woodstock Energy and
Environmental
Protection, Dept Of
carry handguns in
state forests and

10/27/2013
10:05:13 AM
Robert
Danaher
Milford Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2



It makes no sense that we can go armed on "Main St." but not in
our forests. This is especially silly given increasing populations of
bears, not to mention the ever numerous human predators.
10/27/2013
10:05:19 AM
Stephen
Benzon
Oxford Energy and
Environmental
Protection, Dept Of
Carry handguns in
State Forests and
23-4-1(c) and 26-
66-2

10/27/2013
10:09:11 AM
Ted Kuracz Windsor
Locks
Energy and
Environmental
Protection, Dept Of
Carry handguns in
CT Forest & Park
23-4-1(c) and 26-
66-2

10/27/2013
10:10:35 AM
Douglas
Pelkey
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
St Forests/Parks
23-4-1(c) & 26-66-
2
carry a handgun for self defense while in ct state parks and
forests. Specifically:

Remove the prohibition on teh carrying of firearms in section 23-
4-1(c) of the Connecticut agencies regulations

Add an exemption to 26-66-2 to allow teh carrying of pistols and
10/27/2013
10:15:19 AM
John Canning Wallingford Energy and
Environmental
Protection, Dept Of
handguns in state
forests & parks
23-4-1(c) and 26-
66-2

10/27/2013
10:17:23 AM
Cynthia
Pelkey
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
St Forests/Parks
23-4-1(c) & 26-66-
2
carry a handgun for self defense while in ct state parks and

Remove the prohibition on teh carrying of firearms in section 23-
4-1(c) of the Connecticut agencies regulations

Add an exemption to 26-66-2 to allow teh carrying of pistols and
10/27/2013
10:17:35 AM
Roger Peters Colchester Energy and
Environmental
Protection, Dept Of
carrying of
handguns in state
fores
23-4-1(c)26-66-2 Please modify the State Agencies Regulations to allow

10/27/2013
10:19:47 AM
ROBERT E.
NIESYN
CROMWELL Energy and
Environmental
Protection, Dept Of
Carring handguns in
State Forests &
23-4-1(c) AND 26-
66-2

10/27/2013
10:22:27 AM
Matthew J
Disbrow
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
10:30:52 AM
Brian Walker Fairfield Energy and
Environmental
Protection, Dept Of
handguns in state
forests and parks
23-4-1(c) and 26-
66-2


Thank you.

Sincerely,
Brian Walker
10/27/2013
10:31:30 AM
Christoper
Lockwood
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks
23-4-1(c) and 26-
66-2

10/27/2013
10:31:30 AM
Jonathan
Kittredge
Energy and
Environmental
Protection, Dept Of
carry in state forests
and parks
23-4-1(c) and 26-
66-2

10/27/2013
10:40:19 AM
Francis
Niwinski
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
10:40:52 AM
S. Alan Shimp Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
10:45:00 AM
Stephen
Bordieri
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/27/2013
10:47:53 AM
Stephen
Bordieri
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/27/2013
10:48:45 AM
Gary R.
Wheeler
North
Stonington
Energy and
Environmental
Protection, Dept Of
The Right To Carry
in State Forests
23-4-1(c) and 26-
66-2
Forests. Specifically, remove the prohibition on the carrying of
Regulations

10/27/2013
10:52:46 AM
Geoffrey
Wozny
Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
11:02:36 AM
Seth Walter South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
11:18:02 AM
mike
stratigakis
bridgeport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
11:21:46 AM
Luis Rodriguez Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/27/2013
11:28:59 AM
ROBERT
KUCINSKAS
BRISTOL Energy and
Environmental
Protection, Dept Of
CARRYING OF
HANDGUNS IN CT
STATE PA
23-4-1 (c) and 26-
66-2
carry a handgun for self-defense while in CT State Parks and
Forests, specifically: Remove the prohibition on "Carrying of
firearms" in Sec 24-4-1(c)of CT Agencies Regulations and add an
the purposes of self-defense.
10/27/2013
11:36:13 AM
Bob Dragon Energy and
Environmental
Protection, Dept Of
23-14-1 and 26-66-2 Please modify the State Agenices Regulations to allow
carry a handgun for self defense while in CT Stste Parks and
Forest Specifically.

Remove the proibition on the carrying of firearms in Section 23-
4-1(c) of the CT Agencies Regulations.

revolvers (including handguns using center fire ammuninition)
for the purpose of self drfense.
10/27/2013
11:40:34 AM
Winston A.
Campbell
Bloomfield Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests and Parks
23-4-1(c) and 26-
66-2
Forests.

Specifically, remover the prohibition on the "carrying of
firearms" in Section 23-4-1(c) of the Connectictut Agencies
Regulations. Add an exemption to 26-66-2 to allow the carrying
10/27/2013
11:40:58 AM
Yevgeniy
Printsev
Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
11:59:48 AM
Gerald D.
Hopkins
Dayville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) 26-66-2 Please change the regulations to allow individuals with valid
permits to carry a handgun in state parks and state forests for
Remove the prohibition on carrying firearms in section 23-4-1(c)
and add an exemption to 26-66-2 to allow the carrying of pistols
and revolvers using center fire ammunition for purposes of self
defense.
10/27/2013
12:06:47 PM
Richard
Collette
Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
12:21:52 PM
Fred M.
Adkins
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

- Remove the prohibition on "carrying of firearms" in Section

10/27/2013
12:24:06 PM
Mike Demo norwalk Energy and
Environmental
Protection, Dept Of
Handguns in state
parks
23-4-1(c) / 26-66-
2

10/27/2013
12:41:09 PM
Andrew
Hooper
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
12:41:12 PM
Horatio John
DeLuca
Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
1:04:43 PM
Aaron Dean Terryville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the prohibition on the 'carrying of firearms' in


Valid Pistol Permit holders go through training, background
checks, and pay a lot of money in the State of Connecticut to
exercise their Constitutional right to carry handguns in our State.
That right should not be infringed in our State Forests and Parks
where law enforcement officers are less readily available to
protect us from harm.
10/27/2013
1:04:55 PM
Ian McQuade Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
1:10:09 PM
ZACHARY
WILEY
CT TAX PAYER NEW
MILFORD
Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
Pistol Permit holders go through training, background checks
and pay a lot of money to obtain these permits and pay for the
upkeep of CT state parks. It is our right to use them while using
our state issued CT carry permit
10/27/2013
1:14:49 PM
Melanie
Maher
Canton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state Forrest
23-4-1(c) 26-66-2

10/27/2013
1:16:08 PM
John Martin North Haven Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) &26-66-
2
Please modify the State Agencies REgulations to allow
carry a handgun for self defense while in Ct State Parks and
Forests Specifically: Remove the prohibition on the "carrying of
firearms" in section 23-4-1(c) fo the Connecticut Agencise
Regulations, and: Add an exemption to 26-66-2 to allow the
carrying of pistols and revolver (including handguns using
center-fire ammunition) for the purposes of self defense.
10/27/2013
1:29:56 PM
Geoff
Viscount
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
The State of Connecticut cannot guarantee the safety of it's law -
abiding citizens in it's State Parks and Forests. The current law
prohibits those of us who are law - abiding from carrying
handguns in parks and forests. This does absolutely nothing,
however, to stop criminals bent on committing a crime, or a
rabid wild animal, such as a coyote, or even the possibility of a
bear from attacking you. Please modify the State Agencies



Thank you in advance for taking the time to read this.
10/27/2013
2:11:11 PM
Robert
Staurovsky
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
2:16:38 PM
Cathy
Staurovsky
Stratford Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
2:19:11 PM
Alejandro
Sanchez
Environmental
Protection, Dept Of
Carry handguns in
State Parks&Fores

10/27/2013
2:21:51 PM
Adam
Hummel
Berlin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
2:31:07 PM
Mark Vanasse Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
2:41:47 PM
Thomas
Roybal
Energy and
Environmental
Protection, Dept of
Rocky hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Regulation Section
Number: Enter 23-
4-1(c) and 26-66-2


10/27/2013
2:49:25 PM
Eric Letizia East Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


-Eric
10/27/2013
3:13:40 PM
Robert Bonin
Paramedic
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
3:13:59 PM
Jesse Roman Weth Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests. These are common sense changes that should have
never been prohibited in the first place.

Specifically:


10/27/2013
3:14:47 PM
Barry Potter Meriden Energy and
Environmental
Protection, Dept Of
handguns in state
forests & parks
23-4-1(c) & 26-66-
2
Please modify the regulations to allow individuals with a valid
pistol permit to carry handguns in CT state parks and forests for
10/27/2013
3:25:07 PM
Anthony
takacs
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1c , 26-66-2 Please modify the State Agencies Regulations to allow

10/27/2013
3:33:09 PM
Robert
McCarney
Oxford Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
3:46:57 PM
Michael J
Malaro
Retired Public
School
Administrator
Clinton I don't know Firearms in State
Parks/Forests
As that I am trained in the safe and reasonable carry of firearms
(Civilian and Military Training/CT Pistol Permit to Carry Pistols
and Revolvers), the State mandate that I am not allowed to
legally carry in State Parks and Forests is not reasonable and
practical.
10/27/2013
3:53:34 PM
Aaron Maitz Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits to carry a handgun for self defense
while in CT State Parks and Forests.
Specifically:

23-4-1(c) of the CT Agencies Regulations
10/27/2013
3:57:41 PM
Mark Cataldi Ashford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1 (C) 26-66-
2


10/27/2013
4:22:39 PM
Donna Lord Higganum Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
4:24:47 PM
Bob Burton Chester Energy and
Environmental
Protection, Dept Of
Handguns in state
parks
Regulations
10/27/2013
4:26:28 PM
Bennett
Prescott
CCDL New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
4:27:21 PM
Kyle Bates Windsor
Locks
Energy and
Environmental
Protection, Dept Of
Handguns in state
forests/parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
4:36:51 PM
Cameron Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests


-Add and exemption to 26-66-2 to allow the carrying of pistols
and revolvers (including handguns using centerfire ammunition)
10/27/2013
4:40:17 PM
Orlando
Gerena
Danbury Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
4:49:42 PM
David M.
Pontbriand
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 & 26-6-2 Please modify the State Agencies Regulations to allow

10/27/2013
4:53:45 PM
Gregg Beaty Madison Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
4:56:10 PM
Alexander
Gust
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c) and 26-
66-2

10/27/2013
4:56:53 PM
Jason
Puchalski
Hartland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest a
23-4-1(c) and 26-
66-2
Forest. Specifically:
10/27/2013
4:58:27 PM
Frank M.
Dawidowicz
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/27/2013
5:03:49 PM
alfonso
mascolo
berlin ct Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c)and 26-
66-2

10/27/2013
5:04:58 PM
Joe Donahue thomaston Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest
23-4-1[c] , 26-66-2 please modify the state agencies regulations to allow individuals
with valid permit to carry pistols and revolvers to carry handguns
in state forest and parks. specifically: remove the prohibition on
the carrying of firearms in section 23-4-1[c] of the ct. agencies
regulations. -add an exception to 26-66-2 to allow the carrying
of handguns for the purpose of self defense. Thank you.
10/27/2013
5:35:18 PM
Michael
Diakostavrian
os
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/27/2013
5:39:54 PM
Robert Hauser
Jr
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
5:40:38 PM
chad mason Stafford Spg. Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/27/2013
5:47:59 PM
Christopher
Sutton
Durham Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
5:55:06 PM
Victor
DeCiucis Jr
Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
5:55:50 PM
Ryan Dugan Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
5:56:18 PM
Robert
Roberge
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(C) and 26-
66-2

10/27/2013
5:56:35 PM
James
Ellsworth
Pomfret Energy and
Environmental
Protection, Dept Of
state forrests and
parks

10/27/2013
6:00:42 PM
Drew Covell NRA Life member
supporter of 2nd
Amendment and
concerned citizen
of CT
Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
6:21:54 PM
Robert Harris Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
I find it problematic to leave my handgun in my vehicle at state
parks, and a loss of an asset to the protection of the state that I
cannot take the handgun I have trained with into state forests.
This reduces the security of hiking trails and I personally find it
worrisome during hunting pre-season, when I and other hunters
are scoping out game trails, and risk attack of wild animals while
doing so.

Please allow individuals with valid Permits to Carry Pistols and
Revolvers to do so while in CT State Parks and Forests.
Specifically:

10/27/2013
6:30:47 PM
r rudolph new hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/27/2013
6:32:44 PM
William Unger Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State parks an
23-4-1(c) and 26-
66-2
That would be a good thing because of the increase of coyotes
around which do attack humans and pets. I no longer walk in
State areas because of the law, I now walk in town area's,
which don't have that law.
10/27/2013
6:36:21 PM
Christina M
Boisits-
O'Keefe
Southbury Energy and
Environmental
Protection, Dept Of
Handguns in State
parks and forests
23-4-1(c) and 26-
66-2
In Connecticut pistol permit holders go through training,
background checks and pay hard earned money to obtain these
permits. Please modify the State Agencies Regulations by adding
an exemption to 26-66-2 to allow the carrying of pistols and
the purposes of self defense. Please also allow individuals with
for self defense while in CT State Parks and Forests. Specifically:-
Remove the prohibition on the carrying of firearms in Section

Thank you.
10/27/2013
6:37:32 PM
Darrell York Colchester Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in ST forests &
23-4-1(c) and 26-
66-2

10/27/2013
6:44:34 PM
Paul Mallia Kensington Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
6:59:45 PM
Joseph
Morabito
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:02:59 PM
Roger
Bourque
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1 (c) & 26-
66-2


10/27/2013
7:04:04 PM
Paul Somers Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/27/2013
7:12:56 PM
Roger J Naldi
Sr
Energy and
Environmental
Protection, Dept Of
Ccw on state forest
and parks
23-4-1(c). And 26-
66-2
Allow carry in the above location..thank you ...Expand carry
locations for HR-218 (LEOSA ) Card holders
10/27/2013
7:28:31 PM
John J. Bear Colchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:37:11 PM
William J.
Srodulski
Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/27/2013
7:46:10 PM
Andrew Bosse New
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:48:42 PM
Dallas
DeMichael
Stafford
Springs
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Thank you.
10/27/2013
7:49:18 PM
Robert Dillon Voluntown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:51:40 PM
Edward Chute Burlington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/27/2013
7:51:42 PM
Marie
Norman
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:56:10 PM
Michael Testa Plantsville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
7:57:12 PM
Eric Ashford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:04:53 PM
William
Bachlechner
Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1and 26-66-2

10/27/2013
8:06:15 PM
Ronald
Benedict
Uncasville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:10:42 PM
Natasha Saez New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/27/2013
8:13:18 PM
Jody Winslow Farmington Energy and
Environmental
Protection, Dept Of
Sidearm carry in
State Forests
23-4-1(c) and 26-
66-2

for the purposes of self defense. Thank you
10/27/2013
8:20:50 PM
Dane Wider Newington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-41-1(c) & 26-
66-2


10/27/2013
8:25:09 PM
Bryan
Neumann
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:25:15 PM
Peter A
Wilson
Sterling Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:29:01 PM
Nelson
Goewey
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:32:04 PM
Gary Stango Jr Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:34:28 PM
Mark
Lauretano
Salisbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:42:21 PM
Michael Lynch shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
8:56:09 PM
Stefan
Zavatone
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:00:19 PM
Dennis rose Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:23:24 PM
Gary Kendall Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:29:16 PM
Dave Enfield Energy and
Environmental
Protection, Dept Of
Carry handgun in
State Forests Park
23-4-1(c) and 26-
66-2

10/27/2013
9:32:25 PM
Edwin Fiallos Derby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
9:49:35 PM
EDWARD MYSTIC Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4(c) and 26-66-
2

10/27/2013
10:02:18 PM
William W
ONeill Jr
East Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
for self defense while in CT State Parks and Forests.

Specifically:
10/27/2013
10:09:04 PM
Brian Morey Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2


Regards,
Brian Morey
10/27/2013
10:23:45 PM
Milan Kupka waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
10:24:11 PM
m. marek windsor locks Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1(c) and 26-
66-2

10/27/2013
11:02:23 PM
Justin Bradley Southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
11:22:03 PM
KEITH OLSEN Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/27/2013
11:44:14 PM
Andrew
Kulasenski
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c)and 26-
66-2
please modify the state agencies regulations to allow

-remove the prohibition on the 'carrying of firearms' in section
10/28/2013
12:16:38 AM
Nicholas
Viccione
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
on State Forests
Please modify the State Agencies regulations to allow individuals
handgun for self defense while in State parks and forests.
Specifically.Remove the prohibition on the carrying of pistols
and revolvers(including handguns using center-fire ammunition)
for the purposes of self defense. Thank You.
10/28/2013
1:43:07 AM
Paul Garre Bail Enforcement
Agent
Torrington,C
T
Emergency Services
and Public
Protection, Dept Of
Carry in State
Forests and Parks
We the pistol license holder should not be banned to carry in
state Parks and State Forests. Not only is it our Constitutional
right to bare arms ,but it's for our protection for ourselves and
our families. Only criminals are the ones who shouldn't carry,
felons etc, Paul Garre CT BEA #23
10/28/2013
2:48:46 AM
Jonathan
Mazza
Farmington Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
3:22:44 AM
Forrest
Andrews
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
3:27:44 AM
Carl Passaro Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
5:39:52 AM
tom brien Democrat Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in forests&parks
23-4-1(c) 26-66-2

10/28/2013
6:15:33 AM
Michael
Caisse
woodbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
6:20:42 AM
Michael
Eastland
Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
6:22:29 AM
Marino A
Limauro Jr.
Guilford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
6:45:31 AM
Phillip Carucci Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2

10/28/2013
6:46:05 AM
Gary J. Sweet Dayville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
-Remove the prohibition on the 'carring of firearms' in section
10/28/2013
6:46:40 AM
Tom Maloney North
Stonington
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
10/28/2013
6:55:05 AM
Stanley A
Drauss Jr
Energy and
Environmental
Protection, Dept Of
Carrying handgunsin
state forests a
23-4-1(C) 26-66-2 Please modify the state agencies regulations to allow individuals
with valid Permits to carry Pistols and revolvers to carry a
handgun for self defence while in CT State Parks and Forests.
Specifically:

Remove the prohibition on the `carrying of firearms' in section
23-4-1(C) of the Connecticut Agencies Rugulations.
Add an exemption to 26-66-2 to allow the carrying of Pistols and
the purpose of self defence.
10/28/2013
6:56:18 AM
Nancy Provost Woodstock Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forset p
23-4-1(c) and 26-
66-2

10/28/2013
7:05:18 AM
Rob Davis Gales Ferry Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2
10/28/2013
7:31:47 AM
Jesse Casey Burlington Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:32:12 AM
Geoffrey
Willis
Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you,
Geoffrey Willis
10/28/2013
7:39:32 AM
thaddeus
jones
rocky hill Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest
23-4-1(c) and 26-
66-2
handgun for self defense while in CT Remove the prohibition on
the 'carrying of firearms' in Section 23-4-1(c) of the Connecticut

10/28/2013
7:43:22 AM
Michael St
Pierre
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:46:16 AM
george
nowosielski
griswold Energy and
Environmental
Protection, Dept Of
carrying a handgun
in state forest
23-4-1(c)and 26-
66-2
allow individuals with valid handgun permits to carry for self
protection in state parks
10/28/2013
7:49:19 AM
Leonard
Bergeron
Tariffville Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/28/2013
7:51:02 AM
Wang Yu Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:51:08 AM
Arthur
Abronzino, Jr.
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:54:36 AM
Michael Sterling Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State parks,fo

10/28/2013
8:16:46 AM
Kevin Dougan Fin, Fur & Feather
Club, Chaplin CT
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2


Thank you
10/28/2013
8:19:13 AM
Tanggol Caes REDDING Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/28/2013
8:19:33 AM
David Lee
Volz
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:20:05 AM
Ryan Delp CT resident Newtown Energy and
Environmental
Protection, Dept Of
Personal protection-
State lands
23-4-1(c) and 26-
66-2
Forests.

Specifically:

- Please remove the prohibition on the 'carrying of firearms' in
- Please also add an exemption to 26-66-2 to allow the carrying

10/28/2013
8:23:45 AM
Steven Fritsch Cromwell Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:28:24 AM
Jeremiah
McElligott
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/28/2013
8:32:00 AM
Joseph C.
Benanti
West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:34:51 AM
Donald
Hayden
CCDL New Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits to Carry Pistols and Revolvers and

10/28/2013
8:38:13 AM
Fred Hutton sharon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:38:18 AM
Kirby Hawkes Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:38:54 AM
Lynn Kessler Winsted Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
8:39:50 AM
Richard
Palmer
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1-(c) & 26-
66-2

10/28/2013
8:44:56 AM
Neil Caton Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:57:19 AM
Elizabeth
Esterley
Uncasville Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1 c & 26-66-2 Please modify the State Agencies Regulations to allow
carry a handgun for self defense while in State Parks and Forests.

Thank You
10/28/2013
8:58:35 AM
Lee Di Fabbio Sherman Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:59:47 AM
Thomas
Hallihan Jr.
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests

10/28/2013
9:02:35 AM
Michael
Majeski
Newtown Energy and
Environmental
Protection, Dept Of
Carry handguns
inState Forsts/Prks
23-4-1(c) and 26-
66-2

10/28/2013
9:03:13 AM
Mary C.
Succow
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:06:06 AM
anna Colchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:07:22 AM
robert sawyer griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:09:18 AM
Matthew
Mihaly
Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:10:39 AM
robert sawyer griswold Agriculture, Dept Of Raw Milk Please restore the right of farms to sell food directly to
consumers without the burden of government
oversight/regulation. Specifically, allow raw milk sales or farm
share programs to enable consumers and farmers to work
together.
10/28/2013
9:11:26 AM
Todd Davis West Suffield Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in state forest
23-4-1(c) & 26-66-
2

10/28/2013
9:16:29 AM
Russell Gagain South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2



Thank you
10/28/2013
9:18:39 AM
William J
Kayfus III
Newtown Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/28/2013
9:19:12 AM
David
Mathew
Jakubowski
eastford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:19:13 AM
Charles R.
Naumec
Mansfield
Center
Energy and
Environmental
Protection, Dept Of
Carring handguns in
State Forests a
23-4-1(c) Please modify the State Agencies Regulations to allow
individuals with valid Permits To Carry Pistols and Revolvers to
23-4-1(c) of the Connecticut Agencies Requirement.
-Add an exception to 26-66-2 to allow the carrying of pistols and
10/28/2013
9:19:42 AM
Daniel
Watson
Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2


10/28/2013
9:25:55 AM
Richard Clavet Cheshire Energy and
Environmental
Protection, Dept Of
Handguns in State
Forest/Parks
23-4-1(c) and 26-
66-2
Regulations
I am a proud member of the Connecticut Citizens Defense
League and avid Constitutionalist.
10/28/2013
9:30:51 AM
tim kollars mansfield Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2
Change these regulations to allow law abiding citizens to carry
their firearms wherever they choose.

These laws only affect the law abiding in a negative way and
create "gun-free zones". As we have seen all too horrifically in
the past few years in Newtown, the Washington DC naval yard,
Aurora Colorado, and so on, these laws do nothing to stop
violence.

Remove the prohibition on 'carrying of firearms' in Section 23-4-
1(c) of the Connecticut Agencies Regulations
10/28/2013
9:30:54 AM
Keith Webb Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
self defense while in CT State Parks and Forests. Specifically:

10/28/2013
9:41:58 AM
Luke Mihaly Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(C) and 26-
66-2

10/28/2013
9:42:09 AM
Mark Lloret Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 and 26-66-
2
Forests, Specifically:
23-4-1 (c)of the Connecticut Agencies Regulations
and revolvers (including handguns using center-fire ammunition
10/28/2013
9:49:50 AM
J. Koblosh Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) & 26-66-
2
Please modify the state agencies regs to allow individuals with
valid Permits to Carry pistols and revolvers to carry a hand gun
for self defense while in CT state parks and forests.
SPECIFICALLY:
-Remove the prohibition on the 'carrying of firearms' in section
23-4-1(c) of the CT agencies regs.
and
revolvers (including handguns using CENTER-FIRE ammunition )
10/28/2013
9:50:06 AM
James Hackett Citizen Tax Payer Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/28/2013
9:50:25 AM
Matthew
Nowak
Hebron Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1. 26-66-2

10/28/2013
9:51:38 AM
Glenn
Anderson
Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you!
10/28/2013
9:54:29 AM
Richard
Whitman
Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:56:59 AM
James
Thibeault
Norwich Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forest a
23-4-1(c) and 26-
66-2


10/28/2013
9:58:37 AM
David
Bouchard
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:58:57 AM
David
LaFleche
Lisbon Energy and
Environmental
Protection, Dept Of
Carrying in State
Forests and Parks
23-4-1(c) and 26-
66-2

10/28/2013
10:00:39 AM
ed jacobsen southington Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) Please modify the State Agencies Regulations to allow

10/28/2013
10:03:59 AM
Lee
Cavanaugh
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
10:04:32 AM
ed jacobsen southington Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests

10/28/2013
10:05:29 AM
Thomas Fin, Fur, Feather
Club
Chaplin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
10:05:35 AM
James E
Michaud
Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
10:09:04 AM
Douglas
DeMars
Meriden Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1 and 26-66-
2
I am asking that you modify state regulations for state pistol
permit holders to carry for self defense, in all state parks and
forests.
10/28/2013
10:09:32 AM
KENNETH
HALL
Washington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
10:13:40 AM
Matthew
Bartlett
Thompson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


My family and I have been hiking on state land and in parks for
years. Growing up in the Town of Woodstock we had the
tradgedy of loosing a public figure years ago now. She was
raped and beaten to death while walking on a local road. If any
of my family or I were hiking or walking on state land I would like
to afford the opportunity to defend ourselves against those that
could overpower us by brute force. Please keep this in mind
while making your decisions.
10/28/2013
10:30:12 AM
Robert Smith Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/28/2013
10:37:07 AM
William
Walker
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
10:37:12 AM
Kenneth Nagy Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forrests
23-4-1(c) and 26-
66-2

10/28/2013
10:54:04 AM
Julie Parola Newington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
234-4-1(c); 26-66-
2

10/28/2013
11:01:41 AM
Roy Bolieau Stafford
Springs
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 16-
66-2

10/28/2013
11:04:31 AM
Laura Bolieau Stafford
Springs
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
11:08:43 AM
john s chartier East Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
11:17:08 AM
Gregory
Cohen
South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/28/2013
11:24:37 AM
Anthony A.
Ganz
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
11:28:41 AM
Steven L. Roy Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
11:28:48 AM
Adam
Andrusia
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
11:33:57 AM
Zane Dargaty Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
11:37:25 AM
John Reilly East
Hampton
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in Parks- Forest
23-4-1(c) and 26-
66-2

10/28/2013
11:53:19 AM
John F.
Beidler
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Regulations.

10/28/2013
11:53:51 AM
Michael
Valentine
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
12:06:33 PM
Robert
Snelgrove
Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/28/2013
12:08:21 PM
Andrija Jukic Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
12:08:38 PM
Garnet
Drakiotes
South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
12:16:16 PM
alex vazquez Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1&26-66-2 Please modify the State Agencies Regulations to allow

10/28/2013
12:30:16 PM
Elaine Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2



10/28/2013
12:30:23 PM
Philip L.
Cypher Jr.
Plymouth Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/28/2013
12:42:02 PM
gil kelly wallinford Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/28/2013
12:44:51 PM
Thomas Patch Hamden Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1c and 26-
66-2


Please note - Nationally concealed carry permit holders are less
likely to commit a crime with a firearm than is a duty trained and
sworn police officer.
10/28/2013
12:45:56 PM
David
Fernandez
Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

10/28/2013
12:48:21 PM
Dennis
Kendall
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
12:57:32 PM
Joel
Hryniewicz
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations

Joel Hryniewicz
10/28/2013
1:05:38 PM
keith lestage danielson Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1 (c) and 26-
66-2
handgun for self defense while in ct state parks and
forests.Specifically: remove the prohibition on the carrying of
firearms in the section 23-4-1 (c)of the Connecticut agencies
regulations-add an exemption to 26-66-2 to allow the carrying of
10/28/2013
1:07:36 PM
Corey
Veneziano
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
1:09:25 PM
Anthony
Correia
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
1:12:29 PM
Serge Mihaly
Sr
Trumbull Energy and
Environmental
Protection, Dept Of
carring handguns in
State forests
23- 4- 1(c) & 26 -
66-2
Remove prohibition on carrying of firearms in Sec 23 -4 -1-c) of
the Ct Agency regulations. Add exemption to 26 66 -2 to allow
the carrying of pistols & revolvers ( including handguns using
center fire ammunition) for the purpose of self defence.
10/28/2013
1:15:18 PM
Alan
Boudreau
N/A Stafford
Springs
Energy and
Environmental
Protection, Dept Of
carrying handguns
witn state forest
23-4-1(c) and 26-
66-2

10/28/2013
1:22:25 PM
Jaroslaw
Sejdor
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
1:23:03 PM
Wayne
Hopkins
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
1:25:20 PM
Daniel Yungk stonington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
1:30:28 PM
Nicholas
Lucas Jr
Windham Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest a

10/28/2013
1:49:27 PM
Eric Lee
Rousseau
Oakdale Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
1:56:25 PM
James A
Markus, Jr.
Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
1:57:31 PM
Thomas
Thivierge
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
2:07:02 PM
Fred stark Emergency Services
and Public
Protection, Dept Of
Carry handguns in
parks
Folks with permits should be allowed to carry in state forests
and parks
10/28/2013
2:17:06 PM
Jeremy M
Krasij
Canton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
2:28:50 PM
Michael
Scrivano
Columbia Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
2:30:10 PM
david Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
2:33:31 PM
Tom Pugliese Rocky Hill Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
2:34:28 PM
Don
Cieslukowski
Jr.
Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
2:52:05 PM
Christopher
Trudeau
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
2:57:40 PM
Harold J
Pantely
Environmental
Protection, Dept Of
State Forest
Please reconsider the ban on carrying a firearm/handgun in a
state forest for personal protection and/or self defense.
While simply walking in woods near my home, I was cornered by
a rabid racoon. Luckily, he did not attack but I was armed and
able to defend myself if necessary, as I was on private land. But
such things happen anywhere, state forests are not exempt from
dangers.
Firearm owners in this state are licensed and pass safety courses
in order to carry a firearm for personal defense. They should not
be penalized by laws not recognizing that fact.
10/28/2013
3:01:33 PM
Eric
Steinkraus
Newtown Governor's Office Term Limits A one term limit for every elected office in the state including
the Governor.
10/28/2013
3:01:39 PM
Richard
DeSerio
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
3:08:54 PM
Joseph A.
Cappello
Member Kensington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) 26-66-2 Please modify the State Agency Regulations to allow individuals
Specifically: Remove the prohibition on the 'carrying of firearms'
in Section 23-4-1(c) of the Connecticut Agencies Regulations -
revolvers (including handguns that use center-fire ammunition)
10/28/2013
3:11:21 PM
Matthew
Terwilleger
Plymouth Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/28/2013
3:34:16 PM
Theodore W
Bogucki
Andover Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
3:38:09 PM
Charles
Clayton
Gales Ferry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
3:43:23 PM
ROBERT
KAROSY
FAIRFIELD COUNTY
FISH AND GAME
FAIRFIELD Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
3:55:09 PM
James Danielson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
4:01:02 PM
Bernard
Sippin
Fairfield Fish and
Game Association
Monroe Energy and
Environmental
Protection, Dept Of
Permit gun Holders
right
23-4-1 26-66-2 Please modify the State Agencies Regulations to allow
Forests. Specifically: I have held a pistol permit since, 1953. I am
a hunter, and use my guns for hunting deer, and birds. I have my
pistol permit for protection and safety. I have to carry a certain
amount of money on me for business purposes. Bernard Sippin
10/28/2013
4:03:10 PM
Arthur R
Calabrese III
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

10/28/2013
4:06:30 PM
JOSEPH SIMEK NEWTOWN Energy and
Environmental
Protection, Dept Of
CARRYING
HANDGUNS IN
STATE FORREST
23-1(C) and 26-
66-2
please modify the state agencyies regulations to allow
carry a handgun fot self defense in ct state parks and forest
specifically:
- remove the prohibition on the 'carrying of firearms' in section
23-4-1(c) of the connecticut agencies regulations.
- add an examination to 26-66-2 to allow the carrying of pistols
10/28/2013
4:15:47 PM
John A. Naim Danbury Energy and
Environmental
Protection, Dept Of
Carrying hand gun in
state forest a
23-4-1(c)26-66-2 Please modify the stere agency regulation to allow individual
with a valid state permit to carry a pistol or revolver for self
protection while in state forests and parks specifically

Thank you
10/28/2013
4:16:10 PM
Donald
Germain Jr
Energy and
Environmental
Protection, Dept Of
Carrying of
handguns in state
parks
24-4-1(c) and 22-
66-2

10/28/2013
4:16:52 PM
Peter J.
Hylenski
Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
forests.

Specifically:
1) Remove the prohibition on the 'carrying of firearms' in
2) Add an exemtion to 26-66-2 to allow the carrying of pistols
10/28/2013
4:22:04 PM
Randall
Kaufman
Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
4:27:47 PM
James G.
Davis
Stamford Energy and
Environmental
Protection, Dept Of
Carring hand guns in
state parks
23-4-1 and 26-66-
2



10/28/2013
4:37:34 PM
Brian J.
Thibodeau
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c) 26-66-2 Please modify the State Agencies Regulations to allow law
abiding permit carrying individuals the right to carry handguns
and revolvers in state forests and parks.
10/28/2013
4:40:01 PM
Kurtis Martel Old Saybrook Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2
Governor Malloy,

I enjoy walking my dog in state approved parks with my
girlfriend. I would feel more confident if I, a fully licensed
concealed pistol permit carrier, would be able to carry my
firearm for our protection.

Forests.

Specifically:


Thank you,

Kurtis Martel
10/28/2013
5:03:22 PM
George
Arasimowicz
Bristol CT Energy and
Environmental
Protection, Dept Of
Carrying in State
Forests & Parks
23-4-1(c) and 26-
66-2

10/28/2013
5:25:39 PM
Jens Larsen Scotland Emergency Services
and Public
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/28/2013
5:43:07 PM
JAMES R
WHELAN
new haven ct Energy and
Environmental
Protection, Dept Of
carrying guns in
state forrest and
23-4-1(c) please modify the state agencies regulations to allow individuals
with valid permits to carry pistols and revolvers, to carry a hand
gun for self defense while in state parks and forests,specificially:
remove the prohibition on carrying of firearms in section 23-4-
1(c) of
the Connecticut agency regulations. add an exemptiom to 26-66-
2 to allow the carrying of pistols and revolvers including
handguns using centerfire ammunition for the purpose of self
defense
10/28/2013
5:52:12 PM
james a
roberts
higganum Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
please modify the state agencies regulations to allow individuals
handgun for self defense while in ct state parks and forests
remove the prohibition on the carry of firearms in section 23-4-
1(c) of the Connecticut agencies regulations add an exemption
to 26-66-2 to allow the carrying of pistols and revolvers for the
purposes of self defense
10/28/2013
5:54:25 PM
Gary W. Carlin South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c) 26-66-2 Please Modify the State Agencies Regulations to allow
carry a handgun for self defense while in Connecticut State Parks
and Forests. Specifically:
-Remove the prohibition on the carrying of firearms in Section
and revolvers
(Including handguns using centerfire ammunition)for the
purpose of self defense.
10/28/2013
6:04:47 PM
Mark Mitchell Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
6:07:15 PM
Dan I don't know Carrying of firearms Please modify the State Agency Regulations to allow individuals
with valid permits to carry pistols and revolvers for defense
while in Connecticut state parks and forests.
10/28/2013
6:14:46 PM
Albert
Magnani
Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
6:34:49 PM
Donald
Burdick III
Griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
6:39:21 PM
Jason
Morrocco
Bristol Emergency Services
and Public
Protection, Dept Of
23-4-1(c) & 26-66-2

10/28/2013
6:47:09 PM
Robert k
Mann
Thompson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1. 26-66-
2


10/28/2013
6:54:07 PM
Scott
Sanderson
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/28/2013
6:58:09 PM
Eric Shanahan Monroe Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:02:19 PM
richard
bourbeau jr.
ellington Energy and
Environmental
Protection, Dept Of
carrying hand guns
in state forest
23-4-1(c) & 26-
66-2


10/28/2013
7:11:27 PM
Scott Leming Mystic Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:14:17 PM
George
Caruthers
South
Windsor
Energy and
Environmental
Protection, Dept Of
Gun Control P.A. 13-3 and 13-
220
Please review P.A. 13-3 as amended by P.A. 13-220 in regard to
the laws banning "assault" weapons and large capacity
magazines. The requirement for registration is way out of line
and these bans will do little to reduce crime.
10/28/2013
7:14:38 PM
John Antosik Fin, Fur & Feather
Sportsmans Club
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Regulations
10/28/2013
7:19:25 PM
Ron McGuire Easton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:33:08 PM
Dr. Gerald
Strassberger
Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and26-
66-2
carry a handgun for self defense while in CT State Forests and
Parks, and remove the prohibition on the "carrying of firearms"
in Section 23-4-1(c) of the CT Agencies Regulations. Also, please
add an exemption to 26-666-2 to allow the carrying of pistols
and revolvers (including handguns using centerfire ammunition)
for the purpose of self-defense.
10/28/2013
7:36:51 PM
Mark Cannon Burlington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:42:44 PM
Tom Ward Energy and
Environmental
Protection, Dept Of
carrying handguns
in State Forests
23-4-1[c] and 26-
66-2

10/28/2013
7:45:52 PM
RICHARD West Haven Energy and
Environmental
Protection, Dept Of
the right to carry
state parks
We want the rights to cargy in state parks and forest for
personal protection
10/28/2013
7:50:09 PM
Colleen Papa Derby Energy and
Environmental
Protection, Dept Of
carrying handguns
in state parks

10/28/2013
7:51:00 PM
Michael Dion Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:55:26 PM
Patrick Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
7:55:31 PM
ron serianz newington I don't know weopons posisson 29-28e this section states that that if you carry a firearm in a building
that is posted no firearms allowd you are now commiting a
felony even if you have the proper permit.sec 29-37 spells out 3
years in prision.if a business post a sign no guns allowd and you
do not see it it puts you in a bad place.i am not talking about
schools ore courts but like meridan mall.this should be classifed
as an infraction
10/28/2013
8:06:40 PM
Ron Pearsall Cheshire Energy and
Environmental
Protection, Dept Of
Carry handguns in
state forest/park
23-4-1(c) and 26-
66-2

10/28/2013
8:11:08 PM
Frank
Diterlizzi
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/28/2013
8:17:29 PM
Matt Halloran Ashford Energy and
Environmental
Protection, Dept Of
carring of handguns
in state fores
23-4-1(c) and 26-
66-2

10/28/2013
8:28:04 PM
Robert
Fountaine
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the State agencies regulations to allow individuals
with a valid Permits to Carry Pistols and Revolvers to carry a

- remove the prohibition on the carrying of firearms in Section

- add an exemption to 26-66-2 to allow the carrying of pistols
10/28/2013
8:32:23 PM
Gerald
Manion
Sandy Hook Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:35:22 PM
Michael
Nowosielski
scotland Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2
Forests,specifically Remove the prohibition on the'carrying of
firearms' in section 23-4-1 (c)of the Connecticut Agencies
Regulations- add an exemption to 26-66-2 to allow the carrying
ammunition for the purpose of self defense
10/28/2013
8:38:22 PM
Michael Gates Citizen Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the State Agencies Regulations to allow law
abiding citizens with valid Permits to Carry Pistols and Revolvers


Thank you.
10/28/2013
8:44:07 PM
Michael
Thompson
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:49:06 PM
Domenic
Latella Jr
CCDL Guilford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
8:56:12 PM
Gary J. Knapik Naugatuck Energy and
Environmental
Protection, Dept Of
carryinghandgunsins
tateforests&park
23-4-1(c) and 266-
66-2
please modify state agencies regulations to allow individuals
Specifically: Remove the prohibition on the carrying of firearms
in section 23-4-1(c) of the CT Agencies Regulations. Add an
10/28/2013
9:03:31 PM
Marion
McIntyre
weatogue Energy and
Environmental
Protection, Dept Of
carrying handguns
in stateforests
23-4-1 (c) 26-66-2 Please modify the State Agencies Regulations to allow

10/28/2013
9:11:43 PM
John
Laibrandt
Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2
Modefy the State Agencies Regulations to allow Individuals with
valid permits to carry pistols and revolvers to carry a hand gun
for self defence while in Ct state parks and forests. Remove the
prohibition on the carrying of firearms, in Section 23-4-1(c)of the
Connecticut Agencies Regulations. And add an exemption to 26-
66-2 to allow the carrying of pistols and revolvers( inclueding
hand guns using center fire ammunition)for the purpose of self
defense.
10/28/2013
9:18:54 PM
Todd Moler Firearms Permit
Examiners, Board Of
Right to carry in
State Parks
I would like the right to carry in state parks for personal
protection.

Thank you.

Todd
10/28/2013
9:29:32 PM
David Bailey Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:35:16 PM
Todd Pajonas Easton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests



This is common sense so I am hopeful you will strongly consider
making these changes.
10/28/2013
9:41:33 PM
Andrea
McClanaghan
TORRINGTON Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


As a mother and a woman, being able to protect my children is
my first priority. Being able to protect myself falls in line with
protecting my children. Whether it be from a dangerous/injured
animal, or someone who wishes to do them or me harm. Please
modify this regulation, so that I may enjoy our public rural parks
in safety and with peace of mind.

Thank you,
Andrea McClanaghan
10/28/2013
9:45:37 PM
William P.
Healey
Milford CT. Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
9:51:29 PM
Cameron
Duplessis
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
10:09:17 PM
Alfonso
D'Antonio
Storrs Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/28/2013
11:06:14 PM
michael saar north
branford
Energy and
Environmental
Protection, Dept Of
handguns in state
forests
26-66-2 and 23-4-
1 (c)
Please allow gun carry permit holders to carry a handgun in state
forests.
I can can carry a handgun on a crowded city street, but not all
alone in the woods?
I can hunt with a shotgun in the state forest,but i cant carry a
handgun?
What if i am attacked by a wild animal? Do you expect me to talk
to the animal in a calm , soothing voice and tell him how i am
very disappointed in him for chewing on my leg?
10/28/2013
11:10:25 PM
Rui DeSousa Sandy Hook Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
As a law-abiding citizen, Im growing tried of the continued
unjust oppressive laws targeted at gun owners.


10/28/2013
11:13:19 PM
Greg
Hildebrand
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
11:18:21 PM
Luis
Hernandez
HARTFORD Energy and
Environmental
Protection, Dept Of
HANDGUNS IN
STATE
FOREST/PARKS
23-4-1(C) AND 26-
66-2
Regulations
10/28/2013
11:47:06 PM
Edward
Sullivan
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/28/2013
11:48:21 PM
Robert
Mather
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

10/29/2013
2:50:23 AM
Gerard Beck Middletown Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations

Thank you.
10/29/2013
3:51:17 AM
Robert Isleib Bolton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:55:52 AM
Jeremiah
Borsoi
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/29/2013
6:01:41 AM
Albert Turro Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
6:05:26 AM
Doug Ricci Plainfield I don't know carring for personal
protection in
I am in favor of being able to carry for personal protection I am
a senior citizen and live in a location surrounded by State forest
I feel I need the protection, its wild out there and who knows
who or what you can encounter. Thanks Doug Ricci
10/29/2013
6:10:37 AM
Robert Nelson Redding Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
6:15:00 AM
David Hyatt Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Have you ever been attacked by a rabid animal before?
We thats My wife and I hike in the woods all the time and have
come face to face with wild life. In most cases we were safe but
that one time a rabid fox was with in eye sight. We knew that
we needed to move out of the way. The next time this
opportunity should arise We need to be able to protect our selfs
If the state turns this law into affect then we the people will
have no protection from this our any other type of event that
should arise.

Please consider this as a good reason to allow carry in the state
and federal forests..

Thank you

David and Susan Hyatt
1881 Mountain Road
Torrington CT
06790
10/29/2013
6:35:35 AM
Donna Latella Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2

10/29/2013
6:38:17 AM
Jonathan E
Long
Riverton Energy and
Environmental
Protection, Dept Of
Carrying guns in
Sate forests
23-4-1(c) 26-66-2
individuals with valid permits to carry pistols and revolvers in
Stat Parks and Forests.

Remove the prohibition on the "Carrying of Firearms" in section
23-4-1(c) of the Ct. agencies regulations.

revolvers, including hand guns that use centerfire ammunition
10/29/2013
7:13:31 AM
Philip
McDonald
Environmental
Protection, Dept Of
carrying Handguns
in state Lands
23-4-1(c)&26-66-2 Please Modify the state Agencies Regulations to allow indivduals
with valid Permits to Carry Pistols and revolvers
to carry a handgun for self defense in CT State Parks and Forest.
Specifically;
Remove the prohibition on the carrying of firearmes in Section
23-4-1 (c) of
the Connecticut Agencies Regulations
Add an exemption to 26-66-2 to allow the carrying of pistals and
revolvers(including handguns using center-fire
ammunition) for the purpose of self defense
10/29/2013
7:24:30 AM
Levere F
Starner
Ashford Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in Connecticut St
23-4-1(c),26-66-2 Please modify the State Agencies Regulations to allow

10/29/2013
7:25:12 AM
Thomas
Buccieri
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
7:33:33 AM
Dr George
Heinemann
Redding, CT Energy and
Environmental
Protection, Dept Of
Carrying handguns
concealed in Stat
23-4-1(c) and 26-
66-2
I request modification to allow valid CT Pistol Carry Permit
holders to be allowed to carry a handgun in state parks and
forests for self defense.
10/29/2013
8:06:02 AM
Scott
Melancon
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
carry a handgun, for self defense, while in CT State Parks and
Forests.

Specifically

-Remove the prohibition on 'carrying of firearms' in Section 23-
4-1(c) of the Connecticut Agencies Regulations
ammunition)for the purposes of self defense.
10/29/2013
8:11:54 AM
Kevin O'Brien Lisbon Energy and
Environmental
Protection, Dept Of
Firearms in State
forests and parks
23-4-1(c) and 26-
66-2


10/29/2013
8:40:16 AM
mark g
gosselin
meriden Energy and
Environmental
Protection, Dept Of
carry handguns in
state forres,park

10/29/2013
8:41:28 AM
Troy
Musacchio
Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1 (c) and 26-
66-2

10/29/2013
8:44:37 AM
Paul D.
Stiephaudt
Stonington Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) & 26-66-
2

23-4-1(c) of the CT Agencies Regulations.

10/29/2013
8:53:55 AM
Alan J Amato Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


10/29/2013
8:54:03 AM
melanie
mcguire
naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
8:54:28 AM
Ellen Amato Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
8:56:56 AM
Terrence J.
Grella
Harwinton Energy and
Environmental
Protection, Dept Of
carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
carry a handgun for self defense while in Ct State Parks and
Forests.
Specifically:
10/29/2013
9:01:38 AM
Thomas Gallo Energy and
Environmental
Protection, Dept Of
23-4-1 and 266-
66-2

10/29/2013
9:05:47 AM
Casey Nunez Stamford Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2


It is nonsensical to prohibit law abiding pistol permit holders
from carrying a firearm. Anyone willing to do harm will be
unphased by a regulation prohibiting firearms.
10/29/2013
9:12:04 AM
Leo North Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 (c) and 26-
66-2

10/29/2013
9:18:12 AM
Dan Devin East
Hampton
Energy and
Environmental
Protection, Dept Of
Firearms in State
Parks
I am a 33 year military veteran having served twice with the
Connecticut Air National Guard as well as many other military
units. I support allowing concealed carry permit holders to carry
a firearm in state parks and forests. Limiting our second
ammendment rights does not make us safer. It only emboldens
the criminal who knows that law abiding citizens will be
unarmed and unprotected. Keep the bad guys guessing and
allow firearms in state forests and parks. Besides, how many
incidents have we had of legal and licensed permit holders
shooting up parks? Is this a solution looking for a problem???
10/29/2013
9:19:03 AM
James
Reynolds
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
- Remove the prohibition on 'carrying of firearms' in Section 23-
4-1(c)of the Connecticut Agencies Regulations
10/29/2013
9:20:56 AM
Dr George
Heinemann
Redding, CT Energy and
Environmental
Protection, Dept Of
Carrying handguns
concealed in Stat
23-4-1(c) and 26-
66-2
I request modification to allow valid CT Pistol Carry Permit
holders to be allowed to carry a handgun in state parks and
forests for self defense.
10/29/2013
9:31:43 AM
Donald
Feuerstein II
Orange Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


The reasoning being that our state parks are full of wild animals
and in some case sick persons. There have been several cases in
where bears have been sighted and or Coyote dogs have been
present in these environments and have been threatening to
persons and in some cases killed. As a state pistol permit holder,
carrying a psitol in the woods and state parks is key to keeping
people safe in these environments. I am not saying that folks
should be willy nilly firing at animals, but if there is a real
situation with a hungry animal or animals i sure want to be able
to protect myself and family. Thank you
10/29/2013
10:03:26 AM
Michael Wolf South
Windsor
I don't know MDC charges The MDC serving the Hartford metropolitan area imposes a
surcharge on the accounts of water consumers from "NMT"s,
which are non-member towns. In addition, it wants to install
electronic-sensor-containing meters in our homes in lieu of the
consumer self-reporting system that has been in place for at
least the twenty one years that I have lived with MDC water.
And in order to apply pressure to those who do not want
electronic reporting devices in their homes, they refuse to
review their bills, even when it is reported that they are too low.
But the MDC is not overseen by anyone, not even the DPUC,
because it is a government agency...not even when it functions
outside its charter as when providing water to consumers in
non-member towns. If indeed the MDC is a government agency-
-and case law at least imbues it with the powers and duties of
municipalities--it is constitutionally required to redress the
grievances of those under its authority. This is an area in which
MORE regulation is needed, not less.
10/29/2013
10:13:33 AM
James Hill Granby Energy and
Environmental
Protection, Dept Of
Carry in state
forests
It is a clear violation of carry rights for citezens with valid carry
permits to be denied that right on state parks and forests. Please
remove that restriction. Than you.
10/29/2013
10:14:26 AM
James Hill Granby Energy and
Environmental
Protection, Dept Of
Carry in state
forests
It is a clear violation of carry rights for citezens with valid carry
permits to be denied that right on state parks and forests. Please
remove that restriction. Than you.
10/29/2013
10:15:01 AM
Field Marshall
John C.
Seymour
Brookfield Militia Brookfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forrests
23-4-1 and 26-66-
2


10/29/2013
10:32:29 AM
Michael
Friedman
Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/29/2013
10:36:24 AM
jim fantoli jr franklin Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) & 26-66-
2

10/29/2013
10:41:31 AM
Chris Gorley new haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
10:44:40 AM
Richar Garner Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
10:50:41 AM
Don
Feuerstein
Southbury Governor's Office Right To Carry in
State Forests
Governor Malloy,
People who are properly permitted to carry firearms should
not be barred from carrying in state parks and forests. We all
share the grief of what happened at Sandy Hook. I happen to
live a short distance from there. But the firearms restrictions
passed since are nothing but attempts by politicians who want
to make it seem like they have done something. In fact they
have not attacked the real problem at all. The right to bear arms
is a sacred right given us by our founding fathers and it was done
so for a reason. Very little has been done to protect the public
from the criminals and emotionally ill people who are the real
problems that need to be addressed. It is not the guns but the
people who are the problem. Don
10/29/2013
10:51:24 AM
John Glynne Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Allow pistol permit holders to carry in state forests and parks. 10/29/2013
10:53:55 AM
Paul S.
McNamara,
Ph.D.
Monroe Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

-Add an exemption to 26-6-2 to allow the carrying of pistols and
revolvers (including habndguns using center-fire ammunition)
10/29/2013
10:57:38 AM
kenton mystic Energy and
Environmental
Protection, Dept Of
handguns in state
forest, parks
23-4-1(c) 26-66-2 please modify the state agencies regulations to allow individuals
handgun for self defense while in CT state parks and forest.
specifically:
-remove the prohibition on the "carrying of firearms" in section
23-4-1 (c) of the Connecticut agencies regulations
10/29/2013
11:02:40 AM
Lou
Chavenello III
Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/29/2013
11:10:53 AM
David Larson New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
11:20:47 AM
Randall
Dumais
North
Windham
Energy and
Environmental
Protection, Dept Of
carry handguns in
State Forests an
23-4-1(c)and26-
66-2
Forests. Specifically;

- Remove the prohibition on the 'Carry of firearms' in Section

- Add an exemption to 26-66-2 to allow the carry of pistols and
revolvers (including handguns that carry center-fire ammunition)
10/29/2013
11:24:32 AM
Ethan Seitz New
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
11:27:26 AM
Giovanni
Sanzo
SHELTON Firearms Permit
Examiners, Board Of
Handguns in state
park restrictions
23-4-1(c) and 26-
66-2
I respectfully request you modify the State Agencies Regulations
to allow individuals with valid Permits to Carry Pistols and
Revolvers (handguns) for self defense/protection while in CT
State Parks and Forests.

Specifically requested:

Completely Remove the prohibition on the 'carrying of firearms'
in Section 23-4-1(c) of the Connecticut Agencies Regulations
Also to add an exemption to 26-66-2 to allow the carrying of

while using these beautiful park areas there is no one there to
protect me or my family. My only safety & protection would
come my ability to carry a firearm. The Governor would have an
armed security detail with him today to protect him should he
visit these "gun free zoned" parks, yes? Then why should I be
left disarmed? His life is no more or less worth protecting than
mine or my families. That also further proves that a sign stating
"gun free zone" do no work for if they did an armed security
detail is not needed. Please allow me to protect myself and my
family in said parks. Thank you
10/29/2013
11:30:51 AM
Eugene Seitz New
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
11:34:23 AM
Stephen
James
Environmental
Protection, Dept Of
Carrying Handguns
St. Forest/Parks
23-4-1(c) and 26-
66-2

10/29/2013
11:44:18 AM
Mike Testa Bridgeport Energy and
Environmental
Protection, Dept Of
Right to Carry State
Lands and Park

10/29/2013
11:46:25 AM
Daniel Kopp Wilton Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/29/2013
11:49:29 AM
Frank M.
Kessler III
Somers Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/29/2013
12:12:56 PM
Steven Hahn Avon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in forest/parks
23-1-1(c) and 26-
66-2


I ask that you listen to the voices of Connecticut's responsible,
law abiding citizens in this matter. We have the right to protect
ourselves and our families, given to us my the 2nd Amendment
to the US Constitution.
10/29/2013
1:03:20 PM
David Tiago Monroe Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
1:10:55 PM
ricky willis west haven Energy and
Environmental
Protection, Dept Of
carrying guns in
state parks


10/29/2013
1:13:31 PM
Scott Shultz East Lyme Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State
23-4-1(c) and 26-
66-2

10/29/2013
1:14:11 PM
Kyle Geick Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2

10/29/2013
1:14:29 PM
Theocdore M.
Antonitis
Environmental
Protection, Dept Of
23-4(c) and 26-66-2 Please modify the State Agencies Regulations to allow


10/29/2013
1:17:45 PM
Bernard
Krieger
Stamford Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23 4 1 (c) I ask that you please remove the prohibition on the carrying of
firearms in section 23 4 1 (c) of the Connecticut agencies
regulations.

Also please add an exemption to 26 66 2 to allow the carrying
ammunition) for the purposes of self-defense.
10/29/2013
1:39:38 PM
Scott Auten Shelton Energy and
Environmental
Protection, Dept Of
Carry handgun State
Forests & Parks
23-4-1(c) and 26-
66-2


- Remove the prohibition on the 'carrying of firearms' in
10/29/2013
1:40:32 PM
David
Andrade
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Carrying handguns
in State Forests
and Parks

10/29/2013
1:48:07 PM
Jesse Parris Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
2:17:08 PM
martin scuderi Ellington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
2:36:07 PM
Eileen Auten STRATFORD Energy and
Environmental
Protection, Dept Of
Carry handgun State
Forests & Parks
23-4-1(c) and 26-
66-2

10/29/2013
2:36:37 PM
John
Chiaradio
Bristol Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in state forests
23-4-1(c) and 26-
66-2

10/29/2013
3:04:27 PM
Oran J
Spaulding Jr
Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
3:11:54 PM
harland
christofferson
guilford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
3:47:23 PM
Jay Jones Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
4:05:10 PM
Joseph Evola Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
4:06:50 PM
Fred W.
Hopkins
Beacon Falls,
CT
I don't know Carrying firearms in
State Parks an
Sec. 23-4-1(c) I strongly urge the Governor and the Legislature to review and
reverse the regulations forbidding carrying of firearms in State
parks and Forests. I urge them to allow permit holders to carry
handguns for personal protection. Eliminate the prohibition on
the 'carrying of firearms' in Section 23-4-1(c) of the Connecticut
Agencies Regulations - Add an exemption to 26-66-2 to allow the
carrying of pistols and revolvers (including handguns using
center-fire ammunition) for the purposes of self defense.
10/29/2013
4:12:52 PM
Michael
Callahan
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:05:28 PM
Leigh Standish Wethersfield Energy and
Environmental
Protection, Dept Of
Concealed Carry in
State Parks
23-4-1(c) and 26-
66-2

10/29/2013
5:14:33 PM
Eric G.
Brickner
Environmental
Protection, Dept Of
Carrying Handguns
In State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:15:49 PM
Eileen J.
Brickner
Environmental
Protection, Dept Of
Carrying Handguns
In State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:17:12 PM
Edward J.
Brickner
Environmental
Protection, Dept Of
Carrying Handguns
In State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:17:37 PM
Paticia Pfile Glastonbury Energy and
Environmental
Protection, Dept Of
Carrying Handguns
In State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:18:33 PM
Dean Davis West Suffield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:35:53 PM
Gary A. Taylor Energy and
Environmental
Protection, Dept Of
Carring handguns in
State Forests a
23-4-1(c) and 26-
66-2


10/29/2013
5:38:10 PM
Salvatore
Bonito
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 and 26-66-
2

10/29/2013
5:40:01 PM
beth switser naugatuck Energy and
Environmental
Protection, Dept Of
carry hand guns
state forest
23-4-1 26-66-2 i would like to be able to carry a hand gun on state land, if u are
out in the middle of the forest you don't know what might
happen. I have taken hand gun classes and pay for permits and i
think it is my right.
10/29/2013
5:45:08 PM
Steven Valys Killingly Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
5:51:08 PM
Adam Santoro Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
6:27:17 PM
Scott Munger Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
6:52:54 PM
Richard
Pieczarka
coventry I don't know The new gun laws Are you kidding? Governor Mallow: In April you signed S.B. 1160 into law. You
gave an answer regarding to the very gun law that you signed
into law that did not agree with advice given to that same gun
owner by one of your law enforcement agencies.

You used e-cert and rushed S.B. 1160 into law. There is
confusion among law enforcement agencies concerning the new
law and even you gave information to a gun owner that was not
in accord with the very law that you signed.

My question to you: How long will it take for you to put in plain
English so legal gun owners can understand what you intended
with S.B. 1160? How soon can I hear from you regarding this
very important matter?
10/29/2013
6:59:22 PM
Lee Howell East
Hampton
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
6:59:29 PM
Raymond
Kelly
Retired Police
Officer
Monroe Lieutenant Governor,
Office Of The
Pistol Carry . I think it would be impractical to forbid Law Abiding Citizens
within the scope of their rights to not carry a self defense
weapon in a state forest . Forests are not immune to crime ,
weather helping to protect another citizen or you and your
Family .
10/29/2013
7:23:59 PM
Lorant
Matyasovsky
I don't know Carrying firearms in
state parks
23-4-1
Remove this section 23-4-1
Add section 26-66-2 for pistol permit holders
10/29/2013
7:38:27 PM
John Fritz Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
34-4-1 (c) & 26-
66-2

10/29/2013
7:46:30 PM
James Hall Wethersfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/29/2013
7:52:01 PM
Charlie
Eisenhofer
CCDL New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state and Fore
23-4 - (c) 266-66-2 Remove the prohibition on the carrying of firearms in section 23-
4-(c) of the Ct agencies Regulatiions

Add an exemption to 26-66-2 to allow carrying of pistols and
revolvers ( including handguns using center - fire ammunition)
10/29/2013
9:26:04 PM
Linda
Czaplinski
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest/P
23-4-2c, 26-662 Please modify the State Agencies Regulations to allow

10/29/2013
10:03:08 PM
Claudio
Mejias jr.
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in forest/parks
Please modify the state Agencies Regulations to allow individuals
with valid Permits to Carry pistols and revolvers to carry a
handgun for self defense while in CT State Parks and Forest.
Specifically: Remove the prohibition on the carrying of firearms
in section 23-4-1(c) of the Connecticut Agencies Regulations.
revolvers(including handguns using centerfire ammunition) for
10/29/2013
11:33:20 PM
Paul Czyz Manchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you.
10/30/2013
12:10:04 AM
Kelsey
Maloney
voluntown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
12:12:51 AM
Terry Toth Monroe Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
handgun for self defense while in ct state parks and
forests.specifically:remove the prohibition on carrying of
firearms in section 23-4-1(c) of the Connecticut agencies
regulations.add an exemption to 26-66-2 to allow the carrying of
pistols and revolvers (including handguns using center fire
10/30/2013
6:13:22 AM
Michael
Gargano
Environmental
Protection, Dept Of
Carryin handguns in
state forests &
23-4-1(c) and 26-
66-2

10/30/2013
6:56:42 AM
Howard M.
Mills
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
9:19:44 AM
carl speaks Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
9:21:10 AM
Unnecessary State
Rules
To whom it may concern, the following was taken from the DEEP
web site; "Can I continue to hunt deer or small game with my
Bushmaster AR-15 rifle?It depends on where you hunt, since
possession is restricted. There are new requirements for the
possession of certain types of center-fire assault style
semiautomatic rifles and some shotguns which will require the
owner to register those firearms with the Department of
Emergency Services and Public Protection prior to January 1,
2014 (Download Registration Form). Once registered, those
specific firearms still cannot be used on any public lands but they
may be used for hunting on the owner's own property or on
private lands with express permission of the landowner.
Download a complete listing of the restricted firearms which
require DESPP registration and can only be possessed under
certain conditions." First off, to hunt deer in Connecticut you
have to use a 6mm round or larger, an AR-15 is made in two
calibers, the .223 or know as 5.56mm and the .308 caliber, so
how is it that whom ever wrote this did NOT put in there that
the .223 or 5.56mm can NOT be used for deer hunting, only
6mm or larger. It seems that alot of misinformation is being
given out on state weapons and hunting laws or are people at
the DEEP just making up laws as they feel ?Robert Staurovsky34
Rockland AvenueStratford, CT. 06614Cell 1-203-449-4321
10/29/2013
6:59:13 AM
Vanessa
Brown
marlborough Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
10:16:19 AM
Pete Volkmar Waterford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
10:23:32 AM
Eric Baj Energy and
Environmental
Protection, Dept Of
Handguns in State
Forrests / Parks
23-4-1(c) and 26-
66-2
Forests.
Specifically:
- Remove the prohibition on the carrying of firearms in Section
10/30/2013
10:34:02 AM
Wesley Smith Somers Energy and
Environmental
Protection, Dept Of
handguns in state
forests and parks
23-4-1(c) and 26-
66-2

10/30/2013
10:34:20 AM
Robert
Lamson
Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
10:54:17 AM
Patricia
Lamson
Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
10:56:14 AM
Laura Day Goshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2

Thank you!
10/30/2013
11:00:45 AM
michael
brown
Energy and
Environmental
Protection, Dept Of
right to carry in
state parks and f
would like the right to carry personal protection in state forest
and parks
10/30/2013
11:14:06 AM
Robert
Schacht
Bethel Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
11:17:21 AM
Jeffrey
McGurk
Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
11:28:07 AM
Tony Bolton West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
11:49:46 AM
John Bristol Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests and Parks
23-4-1 and 26-66-
2
Regulations
- We need the right to protect ourselves unencumbered by laws
that criminals disregard. We have passed state scrutiny and
should be allowed to carry for personal protection and to
protect our families, friends, neighbors and fellow citizens at
large from the evil deeds of the very few.
10/30/2013
11:53:43 AM
Ira Feinberg The Plant Group,
Inc
Franklin I don't know DEP Water
Diversion Permitting
Public Act 02-102 The Plant Group is a grower of perennial plants and uses over
head irrigation for our crops. The following is what we went
through to get our permit to withdraw water from our pond.
and two wells.
I personally spent over 10 hours filling out a multiple page
application and was determined to do so without hiring a
consultant. There were one or two questions that I filed that the
DEP said required a consultant.
I hired a consultant (approx $10,000) who proved incapable
of securing the permit. I hired a second consultant at a cost of
$35,000 and our application was accepted.
As a requirement of the permit we pay an annual fee of $940
and are required to record and submit our daily water
consumption from each of our three water sources. Since the
wells (and water meters) are separated by about one-quarter
mile there is also a labor cost to keep daily records of these
three readings.
I have a nursery competitor in Massachusettes who told me
they had nothing like these requirements and expenses. In,
addition in a few more years I have to go through the permitting
process again in order to renew my permit.
While the permitting process provides the DEP with every
apprpriate fact I think a less burdensome procedure is possible.
I would also like to point out that during my permitting
process all DEP personal were helpful, couteous and pleasant to
deal with.
10/30/2013
12:21:41 PM
Jason Pepin Southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 (c) and 26-
66-2

10/30/2013
12:23:58 PM
Robert Magri Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
12:30:30 PM
Mark
Wierzbicki
enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
12:39:11 PM
Jon Popoli Hamden Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/30/2013
12:43:52 PM
Gary Fox Monroe Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
12:53:12 PM
Kenneth
Salisbury
Wethersfield,
Ct.
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in st. forrests.
23-4-1(c)&26-66-2 Please modify the states agencies regulations to allow
individuals with valid permits to carry pistols and revolvers, to
carry a handgun for self defence while in ct. st. parks and
forrests.Specifically: Remove the prohibition on the`carrying of
firearms'in section 23-4-1(c)of the ct.agencies regulations.
10/30/2013
12:53:29 PM
William Papp Goshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Many areas of our state forests are quite isolated and I would
very much like to have the ability to defend myself should the
need arise.
10/30/2013
1:03:15 PM
Steven
Murtha
Energy and
Environmental
Protection, Dept Of
carrying handguns
in State Forests
23-4-1 and 26-
66-2

10/30/2013
1:12:09 PM
Gabriel
Penagaricano
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
1:22:34 PM
Marie A.
Robert
GLASTONBU
RY
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
1:24:48 PM
Justin
Ankerman
West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying
handguns/state
park/forest
23-4-1(c) and 26-
66-2

10/30/2013
1:26:52 PM
Donna
Bacchiocchi
Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
State Forest/Park
23-4-1(c) and 26-
66-2


10/30/2013
1:27:13 PM
James
Bacchiocchi
Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
State Forest/Park
23-4-1(c) and 26-
66-2


10/30/2013
1:28:24 PM
jill craft harwinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
1:51:06 PM
Bill Knapp Unaffiliated (looks
like it is asking my
political party
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Recommend repeal of this regulation. I can carry a shotgun -
why not a handgun? Of course I mean only if I have the required
permit(carry handgun permit). More background checking goes
into that permit than into hunting license which is all I need to
carry shotgun in forest.
10/30/2013
1:59:35 PM
David Lamson Wethersfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
2:10:54 PM
Kevin Guite Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
2:11:58 PM
William
Dennis
Berlin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
2:12:08 PM
Timothy
Levasseur
East Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
2:15:08 PM
Kenneth Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
2:18:01 PM
Jeffrey
Perkins
Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
2:18:22 PM
Deborah
Foehr
Environmental
Protection, Dept Of
Real Estate Please modify the State Agencies Regulations to allow

10/30/2013
2:39:50 PM
Charles Grey Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
2:40:34 PM
Ryan Sternal Berlin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

10/30/2013
4:06:18 PM
Lisa A Jansson Southington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
From a woman who would like to exercise the right I already
have to protect myself without worry of prosecution for simply
surviving....



Thank you,
Lisa A Jansson
10/30/2013
4:41:49 PM
Brian Vogel Stratford Emergency Services
and Public
Protection, Dept Of
handguns in State
Parks and Forests
23-4-1(c) and 26-
66-2
Regulations
10/30/2013
4:59:21 PM
david m
sanford
groton Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2
Please modify the state agencies regulation to allow individuals
Specifically:

-Remove the prohibition on the 'carry of firearms' in Section 23-

10/30/2013
5:27:02 PM
Jim Gagosz Wethersfield Energy and
Environmental
Protection, Dept Of
Carrying pistols in
State Forests
23-4-1(c) and 26-
66-2
Dear Governor Malloy,

Please allow individuals with valid permits to carry a handgun for
self defense while in CT State Parks and Forests.

I use our states parks for hiking and fishing. In the last several
years I have had many interactions with wildlife that have
included:
- being tracked by a feral dog (size of a wolf) for about 20
minutes before 3 coyotes chased after it (a very dangerous
situation),
- finding ourselves in the midst of 2 black bears, presumably a
mother and large cub,
- an encounter with a rabid raccoon that kept pursuing us and
others,
- a bobcat challenged us, and
- a near tangle with a fisher cat.

My only options for self defense in these situations was woefully
inadequate, I and or someone else could have been a seriously
hurt or worse.

The environmental improvement and conservation efforts are
working well. Wildlife is returning throughout the state with
some species becoming abundant. The number of predators
and large animals are also increasing as are the number of
potentially dangerous encounters with people.

for personal protection in state parks and forests. With the
increasing presence of wild animals this is contradictory to
common sense. Federal parks allow firearms for self defense.
Forestry classes teach the need for firearms for self protection.
A permit holder has been trained and vetted at state and federal
levels. The regulations must be changed. Agreements with our
neighboring states should also be pursued to cover situations
where a trail briefly crosses state lines.

Please modify the States Regulations to allow individuals with
10/30/2013
6:04:32 PM


Thank you,

Jim Gagosz
F Majewski NONE Montville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Enter 23-4-1(c)
and 26-66-2

10/30/2013
6:49:29 PM
Gary Todd East Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
6:52:26 PM
Becky Sinosky Willington Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state forest
23-4-1(c) and 26-
66-2

-Remove the prohibition on the'carrying of firearms' in Section
for the purposes of self defence.
10/30/2013
7:28:59 PM
Paul Johnson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state park etc
23-4-1 and 26-66-
2

10/30/2013
7:30:03 PM
Richard Claus Willington Energy and
Environmental
Protection, Dept Of
Carring handguns in
CT Forests\park
23-4-1(c) & 26-66-
2

-Remove the prohibition on the'carrying of firearms' in Section
for the purposes of self defence.
10/30/2013
7:31:46 PM
Joseph Ament Colchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
8:29:54 PM
Robert
Kosicki
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
10/30/2013
8:30:17 PM
Anthony Larry Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
8:51:45 PM
Leslie Laing Ansonia Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
8:52:43 PM
Damian Sowa New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
8:58:35 PM
Jeff Robbins East Haddam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/30/2013
9:57:51 PM
Ron Powers Old saybrook Energy and
Environmental
Protection, Dept Of
Handguns in state
forest/ parks
23-4-1(c) & 26-66-
2
Regulations
10/30/2013
10:16:58 PM
Robert
Giuliani
Shelton Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests & Parks
23-4-1(c) and 26-
66-2

10/31/2013
12:35:51 AM
Edward
Donini
Milford Energy and
Environmental
Protection, Dept Of
Carry in State Forest Please modify the State Agencies Regulations to allow

10/31/2013
12:42:30 AM
Richard K.
Strobel
Environmental
Protection, Dept Of
Carrying handguns
in State Forrests
23-4-1(c) 26-66-2 Please modify the State Agencies Regulations to allow legally
permited and trained Citizens to carry handguns in State
Forrests and Parks.
10/31/2013
4:08:55 AM
Thomas
Armstrong
North Havem Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks



Sincerely,
Tom Armstrong
10/31/2013
7:06:05 AM
Walter
Hagedorn
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you
10/31/2013
8:13:06 AM
Joe Salemi Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/31/2013
8:20:56 AM
Matthew
Mucci
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Governor Malloy,

We have had our differences of late in regards to the new
firearms legislation, but I come to you once again as part of our
governmental process regardless of those differences. I ask that
you support allowing open or concealed carrying of a firearm for
purposes of self defense by those legally permitted to do so in
CT within our state parks and forests. The current regulation
that prohibits this is one that makes little sense given the ability
to carry virtually everywhere else in CT and the fact that carrying
a firearm for defense in an isolated area is desirous.


10/31/2013
8:32:58 AM
Cody Pereira Monroe Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/31/2013
8:51:29 AM
Bruce Heine Ansonia Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests & Parks
23-4-1(c) and 26-
66-2
Specifically:

10/31/2013
9:11:49 AM
jason howard Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
10/31/2013
11:57:58 AM
scaring businesses
away
The states and especially towns and cities have too many rules,
red tape that deter business form beginning or staying in Ct. This
hurst out economy. Some rules make no sense at all. Business
owners can not devote a majority of their time filling out paper
work for the state.
10/17/2013
1:34:00 PM
Sick of State
Government red
tape
Hurting small business:

New reformed Gun law P.A. 13-3

This has hurt weapon and ammunition manufactures all over the
Nation.
It created a false sense of need to buy a new gun, your first gun
and others to purchase just because they would be banned. Now
we have dealers unable to sell certain guns and all peripheral
accessories that go along with the sale. There are so many
people buying ammunition to hoard that (many don't own a
weapon) it's impossible to just go to your local dealer and make
a purchase. How many million's of dollars are being lost. Loss
equals tax dollars lost as well.

I am a sportsman and all I do is shoot at paper or bowling pins.
Belong to two well established ranges NRA Certified. I am
concerned for my suppliers unable to do just that-supply.

I also realize that this message will be mute to all, but I had to
write and voice my opinion anyway.

Sincerely,

Thomas W. Grieco

Ct. Infragard member
10/17/2013
2:19:00 PM
regulations The State of CTs regulations are overwhelming and drive
businesses and wealth away. Specifically, its sales tax laws are
exorbitantly complex and nearly impossible to follow, especially
for construction contractors. Services should not be subject to
sales tax in CT, but if they are going to be, the rules should be
simplified to include all services in conjunction with a reduced
rate across the board. The income tax should be the same:
eliminate credits, exemptions, deductions and
corporate/individual tax welfare in general and implement a
lower, simplified, flat tax. I am a CPA whose business would
likely suffer from reduced regulations and simplified tax laws,
but since my state would benefit, I would gladly accept that
tradeoff. Thanks, Dan.

Daniel F. Massucci, CPA/PFS, CFP
Massucci & Associates, LLC
www.massucci1.com
dan@massucci1.com
cell: (860) 919-8305
648 Main Street, Plantsville, CT 06479
phone: (860) 628-0434, (860) 668-6884, (203) 250-9298 -
extension 101
fax: (860) 628-3737, (860) 668-7546, (203) 250-7515
This message originates from the firm of Massucci & Associates,
LLC. The information contained in this e-mail and any files
transmitted with it may be confidential or otherwise privileged
communication. If the reader of this message, regardless of the
address or routing, is not an intended recipient, you are hereby
notified that you have received this transmittal in error and any
review, use, distribution, dissemination or copying is strictly
prohibited. If you have received this message in error, please
delete this e-mail and all files transmitted with it from your
system and immediately notify Massucci & Associates, LLC by
sending a reply e-mail to the sender of this message. Thank you.
New IRS rules, which govern the way we conduct our tax
practice, dictate that we give you the following notice: Any tax
advice included in this communication (including attachments) is
not intended or written to be used, and it cannot be used by any
taxpayer, for the purpose of avoiding penalties that may be
imposed on the taxpayer.
10/17/2013
1:36:00 PM
State Business
pratcies
It is time for the Governor and Legislature to pay attention to
the very fabric that keeps this State above water in budget and
employment areas. This State is extremely un-friendly and non-
supportive of the good businesses we have, instead the
Governor and Legislature is spending millions of dollars of
money we don't have to bring business here. In the past the
State of Connecticut has tried to entice companies to either stay
or come here only to take the money and run. STOP IT! Get a
real program going to help our economy and great workers. Stop
the senseless gun laws and other idiotic ideas which are just
driving out great businesses. It's time for a change, maybe it's
time to change those in office who cannot seem to get anything
right.

Ron Pariseau
39 Freedley Fork Road
Pomfret Center, CT 06259
10/17/2013
6:05:00 PM
FW: Setting up a
home-based bakery
business
Dear Sir or Madame:

In response to Governor Malloy's initiative to review state
regulations, I would like to say that the Department of Consumer
Protection's regulations as to bakeries and commercial kitchens
are very burdensome for entrepreneurs like myself, who would
like to start a home-based business. As you can see from
reading the messages below, I have been in communication with
Linda Kranmas about my desire to start a small bakery operation
out of my home. I have a house in Newington that has an
attached in-law apartment. Since we no longer have a tenant
living there, I was thinking of using the kitchen in the apartment
as a commercial bakery. Ms. Kranmas offered to come over and
walk through the site to tell me exactly what I would need to
change. I am grateful for her offer, and I plan to take her up on
it eventually. However, I have to say that I am a little worried
about what I would need to spend to renovate that space. I
certainly don't want to go so far out of the realm of a typical
home kitchen that I would have to renovate it back again if the
bakery business did not work out and I wanted to rent it out for
residential use again. Do you see my point? It's got to resemble
a home kitchen even though I would use it exclusively for my
business. For example, she said I would need a three-bay sink.
I've never seen a home kitchen with a three-bay sink. Presently,
I have a large single-bay sink in that area. I'm afraid I would
have to rip out the plumbing and rebuild that entire existing wall
of cabinets around the sink. Would that be overkill if I turned
that space back into an apartment? She also states "all
equipment to be NSF." Is it practical to require commercial
equipment in a start-up operation like mine? Assuming I can
find it used at a place where they sell used restaurant
equipment, would a future tenant feel comfortable using that
NSF stove or refrigerator?

I might also mention that many states have begun incubator
operations for specialty food businesses that allow
entrepreneurs to rent a commercial kitchen on a per diem basis.
Connecticut has nothing to offer in this regard that I am aware
of. The closest incubator operation is 70 miles away, at the
Franklin County (Massachusetts) CDC. I contacted them, and
10/18/2013
12:26:00 PM
they told me I am eligible to use their services even though I am
not a Massachusetts resident. If it turns out that the
renovations I would need to do in order to use my spare home
kitchen are too extensive, I will be forced to travel to
Massachusetts. I would rather not have to do this because it will
involve my having to spend money on hotel accommodations,
assuming I rent the kitchen for several days in a row and get a
lot of baking done.

Here is the link for the Franklin County CDC:
http://www.fccdc.org/

What I was hoping to do was to start with just a shoe-string
budget while keeping my day job. I think you need to find a way
to allow more flexibility in your regulations; otherwise, many
people like me will get discouraged and either not pursue their
ideas or move to another part of the country where the climate
is more user-friendly toward entrepreneurs.

Sincerely,

Dana M. Lucisano
41 Garvan St.
Newington, CT 06111-2021

day time telephone: 203-574-8225

________________________________________
From: Linda.Kranmas@ct.gov
To: dll-2@hotmail.com
Date: Wed, 30 May 2012 15:16:15 -0400
Subject: RE: Setting up a home-based bakery business
Yes I am willing to do the walk-through for you however, the
beginning of June- 1st. 2 weeks I will not be available. I work
7:30 AM to 6:00 PM Mon-Thurs so just let me know. If I am not
available my supervisor is Tim Spillane and he may be able to
cover for me if I am not available. Hope this information is
helpful. Good Luck

Linda I. Kranmas
Department of Consumer Protection
Food & Standards Division
165 Capitol Ave. Room 165
Hartford, CT. 06106
Office #860-713-6160
VM # 860-713-6189
Fax #860-706-1265

________________________________________
From: Dana Lucisano [mailto:dll-2@hotmail.com]
Sent: Tuesday, May 29, 2012 6:21 PM
To: Kranmas, Linda

Dear Ms. Kranmas:

I'm glad that, at least, it's possible to have a home-based bakery.
This was the kind of information I was seeking. Thank you for
your help. I'll call you when I'm ready to make a deposit.
Perhaps, you could do a quick walk-though.

--Dana Lucisano

________________________________________
From: Linda.Kranmas@ct.gov
To: dll-2@hotmail.com
CC: Tim.Spillane@ct.gov
Date: Tue, 29 May 2012 15:20:15 -0400
My name is Linda Kranmas and I am the inspector for the Town
of Newington and the surrounding areas. The town would have
to approve the use of your home for this purpose. Zoning, Fire
Marshall, Health Dept. (may not be involved if you are only
wholesaling but still touch base with them).The basement would
be fine to use as long as your are set up for commercial use and
the kitchen (bakery) Is not to be used for any personal use at all.
It must be closed off from access to any pets, children and
anyone not associated with the Bakery Business. You must have
smooth easy to clean, impervious to moisture ceiling tiles, floors
and walls are to be smooth and easy to clean. Perimeter of the
bakery must be provided with a cove molding at the base
juncture of the floor and wall to seal any openings. All
equipment to be NSF, or equivalent equipment. A three-bay
sink large enough to accommodate the largest utensil or pans or
bowls used. Wash, rinse, sanitize with drain boards on either
side to accommodate dirty and clean utensils. A Hand sink and a
mop sink. Home bathroom may be used, however after its use
hands must be washed there and then again when entering your
baking area prior to the start of work. Windows are to be
provided with screening. Depending on the Oven, may need to
be vented to the outside. Ask the Fire Marshall. This information
is not all inclusive as there may be items I did not mention.
When you find where you are going let me know and I will be
glad to look at it, please let me know.

Linda I. Kranmas
Department of Consumer Protection
Food & Standards Division
165 Capitol Ave. Room 165
Hartford, CT. 06106
Office #860-713-6160
VM # 860-713-6189
Fax #860-706-1265

________________________________________
From: Christie, Marcia On Behalf Of DCP.FoodandStandards
Sent: Friday, May 25, 2012 3:57 PM
To: Kranmas, Linda
Cc: Spillane, Tim
Subject: FW: Setting up a home-based bakery business

Please respond to Dana Lucisanos e-mail. Thanks.

________________________________________
From: Dana Lucisano [mailto:dll-2@hotmail.com]
Sent: Thursday, May 24, 2012 3:12 PM
To: DCP.FoodandStandards
Subject: Setting up a home-based bakery business

I am in the process of selling my house and, hopefully, buying
another somewhere in Newington. Once I get settled, I would
like to start a part-time bakery business out of my home to
supplement my income. When I was on the Dept. of Consumer
Protection website, I saw the application form I would need to
fill out in order to get a bakery license. What I was hoping to
find out is what you look for in terms of the physical layout or
work space. If I was to buy a house with a finished basement
that included a kitchen, separate from the family kitchen, could
that qualify for a bakery license? Is there anything I should look
for now, as I am searching for a new house?

Thank you for any guidance you can provide.

Dana M. Lucisano

Message from
KMBT_C452
GOVERNMENT
REGULATION
REFORM. REALLY?
Here is the scanned version. The original bounced back.

Michael J. Knight, CPA, CVA, CFE
Knight Rolleri Sheppard CPAS, LLP
Ph (203) 259-2727 x 20 - Cell (203) 685-2228
Fx (203) 256-2727
1499 Post Road - PO Box 139
Suite 1040, 2nd Floor Rear
Fairfield, Connecticut 06824
Website: www.krscpasllp.com
10/19/2013
6:39:00 AM
Paperwork for CT
Business taxes
Dear Gov. Malloy,

Thank you for your interest in reducing state government
paperwork.

I recently closed my small business due to retirement. I have the
following thoughts:

I had to file the following CT taxes each quarter, and some
required a separate annual summary filing as well.

Annual Corporation Tax- Secretary of State Quarterly Sales and
Services Tax -Dept of Revenue Services Quarterly payroll
withholding for part-time secretary - not sure which dept
Quarterly withholding for unemployment tax- Department of
Labor.

So many web sites, with different requirements, languages,
rules, sign-on protocols and password protocols, payment
regulations. etc.

Can't the state create a single, user-friendly, combined small-
business web portal for the taxpayer to enter all business tax
information; have consistent rules on how payments may be
made ; And have the flow of information sent internally by the
system to each department through the back end of the
website?

It's hard to make a living these days. I really didn't like burning
up a couple of hours each quarter for a part-time business on
state paperwork.

Best regards,

Peggie Cosgrove

Sent from my iPad

Peggie Ford Cosgrove
10/19/2013
1:45:00 PM
16 Niles Hill Road
New London CT 06320
USA

860-447-9217
reporting structure Chief financial officers in each agency report to the
commissioners. They tend to rubber stamp the budget and
spending decisions of the guy who does their performance
reviews. Consider a dual reporting structure with dotted line to
the commissioner and straight line reporting to OPM. Current
structure is contrary to smart spending decisions and
encourages the year end spending frenzy. spend it or lose it.

Bruce W Gardner box 369 Windham ct
10/19/2013
7:02:00 PM
Sunday Hunting on
private land.
I think that Sunday Hunting on private land needs to be allowed.
I hunt to provide food for my family and some friends. The
Sunday hunting ban in our day and age has been outgrown. I
understand that it was implemented for day of worship but I am
Jewish and my day of worship is Saturday and therefore it does
not benefit me. Also the Government has allowed alcohol to be
purchased on Sunday's and holiday's for monetary reason's.
Opening Sunday hunting will also give the state more money as
hunters come into our state to hunt on Sunday. and by opening
it to private land, it will not interfere with people who want to
use the state park's for recreation. So I feel that this law is
outdated as you look across the country and see that almost all
the state's in our union have done away with this restriction.
Studies have shown that this has had no detrimental affect on
wildlife population's. So Please consider changing this law.

Thank you Richard Sterzinger 28 alan rd. Danbury Connecticut
06810.
10/20/2013
3:12:00 PM
Your announcement
about red tape
reduction
Governor, this sounds nice, but part of the state government is
excluded; and those parts that do report to you have failed to
report on prior similar announcements.
So, this is more political theatre than reality.
You tout small victories, but do not addresses major battle
losses. You are on the Titanic playing the violin.
I hope you truly wake up to reality and address basic problems.
Young people are leaving the state; jobs are leaving the state
faster than new ones are being created. Please try not to view
the world through your liberal filters.
Pat Sullivan
860-210-9013
10/21/2013
5:05:00 PM
Unfair tax imposed Dear Governor Malloy,
You speak as if you are interested in helping small business
owners. Your words dont follow your actions.
We own a small retail outlet that happens to sell cigarettes, as
thousands of other families do . On July 1st 2013 you had signed
into law a sales tax on our cost of cigarettes. Its apparent that
you never owned or operated a retail outlet that was subject to
collecting sales tax for the State. The States reasoning for this
was to help prevent fraud. This couldnt be further from the
truth. The State really wanted to collect 90% of the tax money
earlier.
If the State wanted to prevent fraud, all they had to do was have
all the licensed cigarette wholesalers provide for the State, a
dollar amount that was sold to each licensed retailer as the
Beverage Alcohol Industry did a number of years ago. Instead
you impose a 6.35% sales tax on the cost of a product that could
sit on our shelves for a number of months before they are sold.
These early out of pocket dollars could have helped pay for
other purchases.
You have to agree that this is not a very friendly way of doing
business in the State of Ct. This should be repealed as quickly as
it was signed into law. To the best of my knowledge this is the
only product that has incurred such an injustice.
Hopefully you will address this issue.
Regards
Paul A Baudouin
120 Governor Trumbull Way F-4
Trumbull, Ct 06611
10/22/2013
11:26:00 AM
Re:
Comments/Request
on State Law
Changes
To Whom it May Concern,

I am writing in regards to the Governors request for opinions on
regulations that are "obsolete, duplicative, excessively
burdensome, or otherwise ineffective or unnecessary". In
particular, the excessively burdensome State Admissions Tax of
10% which is applied to my business.

I am a small business owner of a Family Entertainment Center
with a focus on Children's Birthday Parties. The name of my
business is Fun Factor and the facility is located in Brookfield, CT.
We provide indoor inflatable bounce houses for children to play
on, along with a few arcade games. We advertise ourselves
under the headings of "your Birthday Party Headquarters",
Birthday Parties, etc. and are listed in magazines such as Ct.
Parent Magazine under CT. Children's and Kids Birthday Parties,
as well as with YP Advertising under Party Rentals, Party
Planning. The birthday parties are structured so that the
children get one hour of free play, along with a 1/2 hour in a
party room for food, drink and cake. They are then permitted to
go back out & play on the bounces, etc. for as long as they would
like. Although walk-ins are allowed, the bulk of the business is
from the birthday parties themselves. I am attaching a couple of
documents to illustrate to you the make-up of the business
derived.

Attached are the September 2013 Product and Category Accrual
Sales Report, along with the September 2013 Event Stats by
Month. As you will see, I have indicated on the Product and
Category Accrual Sales Report, with a check mark, all items that I
can definitively tie back to birthday parties for that month.
Should individual invoices be required I would be happy to
provide them. Even the shipping & handling is tied to the parties
as it is the amount charged to mail out a party packet. The Event
Stats by Month provides a breakdown on the four party
packages we offer, as well as two camp sessions. The Camp
Sessions are typically field trips from schools, park & recreations,
etc. with breakouts being based on the number of attendees.
Both reports clearly show the bulk of the business coming from
the parties we host. The amount of the Admissions tax I was
10/23/2013
11:16:00 AM
required to pay for September 2013 was $1628.00; if you look at
the totals indicated on page 2 of the Product & Category Sales
Report I think you will see how excessively burdensome the
admissions tax is to a facility such as mine. We are not a large
amusement center but a small Mom & Pop shop offering
entertainment to kids.

Although we do allow walk-ins to come in to the facility, as I
mentioned, it is not the bulk of the business and I am requesting
a review be done as to why a facility with the prime focus of
Birthday Parties is required to apply the Admissions Charge to
patrons when facilities such as laser tag or miniature golf are
not. The Exemptions from the Admissions Tax, IP 2008 (11),
states daily or hourly fee's for organizations such as these are
exempt, along with batting cages, golf cages, golf ranges or daily
greens fees, ice or roller skating rings, tennis or racquetball
courts. Also that daily charges entitling partron(s) to participate
in an athletic or sporting activity are exempt. We have an
obstacle course, a sport bounce, slide, large inflatable basketball
hoop, all which can fall under this category.

I am respectfully requesting that this tax be looked at as it
applies to my business.

Thank you,

Amy Farley
Owner, Fun Factor Brookfield
www.FunFactorBF.com
Burdensome State
Regulations which
Harm Connecticut
businesses?
Burdensome State Regulations which """Harm""" Connecticut
businesses?

Here is my list:
1. Time off paid by business for a child (baby) only State in
country.
2. Sick leave paid by business, only State in the country.
3. Energy cost highest in the country 16% tax on wholesale fuel.
4. State dept highest in the country by population. Effects the
credit rate offered to businesses.
5. State income tax on social security and pension benefits.
Why? 36 States do not have this burden.
6. State inheritance tax is up by 7.2% this year. Sunset this law
now.
7. Local property tax is unreasonable when compared to other
States in USA, regionalize fire, police, road services by County.
End / reduce or change all of the above and give a Connecticut
business a chance to survive.

Best Regards,
Eric Erickson
10/17/2013
2:17:00 PM
public comments on
state regulations
To Whom It May Concern:

Please consider some Ct. State Sales Tax Revisions for the
following groups of private citizens:

Specifically:
1) For home schooling families who pay taxes but do not send
their children to school.
Please consider exemptions for curriculum purchases for them,
both in state and out of state. This can add up to a considerable
amount of money, and they are essentially paying a "double" tax
for schooling for their children, as their children do not attend
public school.

2) For people who are sick and need supplements.
Many people are disabled with undiagnosed and, therefore,
untreatable via the regular medical establishment, pain. The
only things that may help them are vitamins and supplements.
Prior to a few years ago, these were never taxed. Please
consider taking them off the sales tax list again. For people who
spend hundreds of dollars a month on necessary supplements,
the amount of money paid in 6.35% sales tax can be astounding
and is a big burden, especially if they cannot work.

Thank you for considering this.

Respectfully,

Irene Pahlsson
42 Newton Road
Branford, CT 06405
10/17/2013
3:46:00 PM
Sick of State
Government's Red
Tape?
Dear Michael:

I saw the e-mail you sent me about " Sick of State Government's
Red Tape? " and it actually made me laugh, but for very good
reason and this should make all of you laugh too. Apparently
Commerce Security Services our company has unpaid back state
sales and use tax for a month in 2010, I suspect it occurred when
Lynn had her bad car accident and six days later I ended up
having a heart attack. It's not a lot of money by any means This
is what I got from the DRS " If your contracts and services
normally averaged $X,500, remit the tax of $390 plus 25%
interest of $97.50. Although Amnesty runs to Nov 15, we will
not renew your sales tax permit which expires on Sep 30. Go to
www.makeitrightCT.com to research options via Amnesty ".

Now the state needs money right? well here is the problem and
issue I do not put personal or business things that are
confidential on this computer. The computer is not 128 bit
encrypted, and has been infected with viruses and trojans
before to the point I have had to wipe it and re-install windows.
Yet the state directs me to websites all the time, they tried this
nonsense with paying our monthly state sales and use taxes too,
I REFUSE to do it as I know my computer is not secure. So we pay
them by phone as it's more secure in relating to our financial
matters.

So I am sitting here this month with a postal money order in the
amount for $487.50, a willingness to send the money in and no
way to do it, go figure. Why cant I just submit a sales and tax use
form for that period and enclose the check and mail it to the
DRS? back taxes paid and the state gets money, everyone is
happy and one less matter to be bothered with... No of course
not as they have computers on the brain lol and it would be far
to easy and simple to do as I suggest...

Not everyone has an encrypted computer you know, and most
computers are infected with something, spyware, trojans,
viruses, key stroke loggers, and more. So why would anyone
depend so heavily on them other than less paperwork which I
am sure is eventually printed out anyways for record keeping.
10/18/2013
2:07:00 PM
Can I send you or DebraLee the form and money order and you
can figure it out for us lol, we have our hands full with running
our small business and a lawsuit over Lynn's car accident. I will
also be forwarding you some suggested legislative changes in
the near future and we would appreciate it if you look it over as
it could prevent someone form being hurt or killed needlessly.

David & Lynn Marchetti
Commerce Security Services, LLC.
P.O. Box 609
Newtown, Connecticut 06470
203-797-8626
Useless laws 1 - seat belt law - it's up to the adult whether they want to wear
there seat belt. There life is at risk no one else's
2 - gun law - why should law abiding citizens should be punished.
The main problem is the mental unstable people.

Sent from my iPhone
10/19/2013
8:54:00 AM
REGULATIONS I would appreciate a response to the following from someone
who is responsible and accountable for the outrageous cost of
State Government. Connecticut is among the highest tax states -
income, real estate, sales etc. Only those who own business or
have jobs in CT or work in NY have reason to reside in Fairfield
County. Those who can work from anywhere or who are retired
are leaving for areas where all housing, living expenses and taxes
are lower and there is no income state income tax. In large
measure the exorbitant costs in CT are related to collection and
spending of taxes on income, sales, estate and real estate as
swell as the enforcement of regulations. Where is the
representation of we the people to clean house and eliminate
taxes and the costs related to their collection and wasteful
spending? Apparently the majority of the legislature benefit by
higher taxes while we the people are poorer as a result. Our
daughter and he husband and two adult grand children have left
the State as well as several of our retired friends. Corporations
are also leaving. Isn't this a wake up call ??
--
Tom Watson
4 Sharp Hill Lane
Ridgefield, CT 06877
Office 203-894-4649
Cell 203-417-3600
10/19/2013
3:11:00 PM
UCC1 Filings To whom it may concern,

There is a statute on the books (According to Judy Pearl at
Secretary of States Office) that says they must keep a UCC1
filing against a company for 5 years after it has been satisfied
and the lender has paid the $50. To terminate it. This causes a
lot of problems when we go for financing or just general bank
review.( which they do on a yearly basis now) This is not right!
Its no different than after you pay off your mortgage and then
have to wait 5 years to get a clear deed. What can we do about
it?

Gary R. Bergeron, President
Connecticut Trailers, Inc
7 Bolton Center Rd
Bolton, CT 06043-7226

860-649-7223 x11 ~GSA Contract # GS-30F-0014V
800-597-9440 x11 ~DAS Contract# 10PSX0307
860-645-8755- Fax ~Dunns# 796365240
www.cttrailers.com ~CAGE Code 4QCH6

Bravo-BigTex-Bri.Mar-CM Trailers & Truck Bodies-Featherlite-
Haulmark-Mission, Aluminum-Sundowner-Wells Cargo-
Worthington, Blizzard Snow Plows & Sanders. We are behind
you all the way!!
10/20/2013
1:20:00 PM
FW: Message from
KMBT_C452
Regulation strangulation. See attached. Actions belie words. 10/21/2013
5:28:00 AM
Please remove this
law
Please remove the ban on wine sales in Supermarkets that sell
beer. I have been in several states where I can buy WINE AND
beer in the supermarket. This rule is discriminatory against the
wine drinkers of Connecticut.

Also, the State needs to get out of the business of price fixing
alcohol and limiting which brands can be sold in Connecticut.
This is hardly what I call free enterprise!

Thank You,
John A. Deer
203 Fieldstone Terrace
Naugatuck, CT 06770
10/22/2013
8:57:00 AM
Fw:
Bob Stryker
----- Forwarded Message -----
From: ROBERT STRYKER <rstryker71@sbcglobal.net>
To: "governor.regulations@ct.gov"
<governor.regulations@ct.gov>
Sent: Thursday, October 17, 2013 12:00 PM
Subject:

Gentlemen:

I refer to the conflicting powers - and regulations of the DEEP
regarding the watercourse of Candlewood Lake. Some of the
regulations and purported powers of the DEEP conflict with the
CT supreme court decisions and, therefore, should be changed
to reflect the court's decision.

CT statute: chapter 268, sec. 15-127 claims powers of the
commissioner include "state waters" ..."excepting federal
waters." Yet in the adjudicated supreme court case: Hackett v.
J.L.G. properties, 2008 (#17871), federal authority of the lake
(license P-2576 to First Light Power) supersedes local zoning.
Cases reviewed cited in this decision concluded that the state
has little, if any, authority in regulating Candlewood since this
appears to be exclusively the purview of the federal government
through the Federal Energy Regulatory Commission as
determined by Congress. Since local Zoning Commissions are
considered a legal entity within CT and not even subject to the
electors through the town meeting form of government (a
unique situation differing from all other New England states'
laws), it would follow that the state would also lack the legal
power it has assumed up to the time of this decision by our
court.

There are a number of ramifications that I would like to discuss
further concerning a number of regulations within this
department which also conflict with property rights, if you have
the inclination and time to respond. Otherwise, thank you for
this opportunity to bring this conflict to your attention.

10/22/2013
7:00:00 PM
Bob Stryker (203) 746-6363, or via email.
regulations There are numerous regulations and laws hindering or harming
the state of Connecticut and our citizens. These should be
eliminated or changed. Thank you for giving me the opportunity
to recommend several absolutely necessary changes to be
competitive as a state and protect citizens.

1) ALL unfunded mandates should be eliminated. If the state
cannot find the money to fund them don't raise my property
taxes to do so.

2) Stop all taxpayer funded "cleanup" of contaminated sites. If
land is not used for some new purpose the land would be "dirty"
forever, might better be using it in the meantime.

3) All laws should have sundown provision. Need review as
time passes. At least every 10 years.

4) Get rid of "retention" bonuses. Holdover from when state
employees had lots of benefits and low pay. Now they have
excessive benefits and excessive pay. Sure don't need additional
pay. Public pay/benefits should "mirror" similar, average, in
private industry instead of being "negotiated".

5) Privatize all services except police and courts. Particularly
schools, DMV, Social Services, DPW, DEEP, Accounting/payroll.
6) Require cell phone suppliers to "shut down" cell phone
services, except for 911, when GPS function indicates phone is
moving more than 5 MPH unless it is on a rail line.

7) Implement law to encourage gun production in this state,
keep the few manufacturers we still have and actively seek new
ones. Enforce and strengthen laws locking up illegal possession.
Encourage use by "honest" citizens.

8) Enforce all new laws vigorsly before adding new ones.

9) Continue with "free" unemployment money for the first
month. Gradually, over about two months, change
unemployment payments to a zero interest loan. Encourage
people to quickly get off unemployment. Allow them to pick a
10/26/2013
10:42:00 AM
smaller payment than the "standard" amount so they would be
able to receive needed funds but limit the loan amount they
would have to pay back.
This needs a great deal of work and comment. If it ever comes
up I would have much more to suggest needed before
implementation. There needs to be a way people could work
part time and not "loose".

10) Stop the costly and unnecessary labeling of genetically
modified foods. Have used hybrid crops for years, safe GMO's!

11) Stop using "other people's" tax money to help a few buy
things that many (including me)cannot afford. Stop paying for
part of someone's new hybrid car for instance, or their solar
panel heat and electric. Why should those that cannot afford
these pay for those that can already afford them. In my case I
have not been able to afford a new car in 20 years but have had
to help pay for those that can. Same applies to many people in
this state.

12) Have a citizens committee "watchdog" oversee the
awarding of all state and municipal contracts to keep politics out
of awarding them.

13) Have a cost/benefit analysis prepared and provided to the
citizens before enacting legislation. Review that in a year and
require a re-vote if the results are more than 10% different than
what was presented to the citizens and "voted on".

14) Revise (mostly lower)tax rates to be conducive for inviting
business (particularly manufacturing) to re-locate into
Connecticut. More new business would eventually result in
more taxes! In the meantime please limit spending to match
income. To accomplish this please create an "industrial
engineering" position with the absolute authority to make cost
saving changes in all state functions.

Thank you for your help.

William Fuller
67 Dino Rd.
Bristol, CT
06010
860-589-3206
fuller_william_d@sbcglobal.net
Joseph J
Camarra
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-1(c) and 26-66-
2
Regulations

10/31/2013
1:12:16 PM
paul anderson Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
Regulations
10/31/2013
4:40:21 PM
Ken Bavier Manchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 26-66-2 WE should be able to carry our personal protection in state
forests and parks.
10/31/2013
5:25:29 PM
Brian White Southbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

10/31/2013
5:55:05 PM
Christopher
Rubbicco
Sterling Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/31/2013
6:11:10 PM
Robert
Sherwill
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) 26-66-2

10/31/2013
6:36:50 PM
John Lee south
windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/31/2013
8:29:22 PM
Miguel Torres
Jr
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/31/2013
8:46:29 PM
Dan Whitney Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

10/31/2013
8:48:36 PM
Jeffrey Wild Naugatuck Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest a
23-4-1(c)and 26-
66-2

10/31/2013
9:45:56 PM
Richard
Pianko
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 6:54:32
AM
Richard
phelan
East haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forest a
23-4-1(c) and 26-
66-2
individuals with valid Permits to carry pistols and revolvers to
Forest specifically: -remove the prohibition on the 'carrying of
firearms' in section 23-4-1(c) of the Connecticut Agencies
Regulations. - Add an exemption to 26-66-2 to allow the carrying
of pistols and revolvers ( including handguns using center fire
ammunition) for the purposes of self defense
11/1/2013 7:44:18
AM
Steven
Patterson
New Fairfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013
10:44:31 AM
Jose F. Garcia
Jr.
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013
11:25:42 AM
Ronald
Iannucci Jr
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013
11:31:14 AM
robert wood milford Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c)&26-66-2 Please modify the State Agencies Regulations to allow

11/1/2013 1:03:44
PM
James Laviana Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
Please modify State Agencies Regulations to allow with valid
Permits to Carry Pistol and revolvers to carry for self defense
while in Connecticut State Parks and Forests. Specifically:
Remove the prohibition on " carrying of firearms" in Section 23-
4{c) of the Connecticut Agencies Regulation. Add an exemption
to 26-66-2 to allow the carrying of pistols and revolvers
purposes of self protection.
11/1/2013 1:03:58
PM
John Meany Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Regulations
11/1/2013 1:52:08
PM
scott houlihan easton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 3:44:20
PM
Jeffrey R. May East Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 4:04:15
PM
Shawn
Rigoulot Sr.
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 6:14:26
PM
Thomas
(Tony) Hayes
Environmental
Protection, Dept Of
Handguns in State
Parks
23-4-1(c) and 26-
66-2
Regulations
11/1/2013 6:15:45
PM
Bob Harley Haddam Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 6:57:42
PM
kenneth
silliman
new fairfield Energy and
Environmental
Protection, Dept Of
carrying handguns
state parks
23-4-1(c) 26--66-2 I walk my dog in state forest and parks I would feel safer with
my firearm I have a carry permit
11/1/2013 7:00:15
PM
Tom Cassin Newtown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 7:03:44
PM
William P.
Brinn
Washington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 7:12:29
PM
John Martello Michael Stamford Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/1/2013 8:06:11
PM
Rodney
Devoe
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/1/2013 9:49:32
PM
Peter Bova, Jr. Northford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits to Carry
CT State Parks and Forests.
Specifically:
23-4-1(c) of the Connecticut
and revolvers (including handguns
using center-fire ammunition) for the purposes of self defense.
11/1/2013
11:13:38 PM
Rita M. Bova Northford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits to Carry
CT State Parks and Forests.
Specifically:
23-4-1(c) of the Connecticut
and revolvers (including handguns
using center-fire ammunition) for the purposes of self defense.
11/1/2013
11:19:26 PM
Richard
Norbut
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/2/2013 8:40:45
AM
Jack Korduner Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

11/2/2013 8:44:34
AM
john milardo middletown Energy and
Environmental
Protection, Dept Of
Carry handguns in
State forest-park
23-4-1(c) and 26-
66-2
individuals with valid Permits to Carry Pistols and Revolvers so
we can carry a handgun for self defense while in CT State Parks
and Forests. Specifically:

11/2/2013 8:55:34
AM
John
McCormack
Moodus Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/2/2013 9:28:19
AM
Steven Vyce Madison Energy and
Environmental
Protection, Dept Of
Right to carry
handguns in state ps
23-4-1(c) and 26-
66-2

Forests. Of all places, remote state parks and forests would be a
prime area for necessity of self defense.

Specifically:

11/2/2013
11:36:01 AM
Donald A.
DiAnge
Windham Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2


11/2/2013
11:37:59 AM
George
Kochera III
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/2/2013 1:15:49
PM
Robert
Martineau
Ledyard Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/2/2013 5:07:18
PM
F. David Laun Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

11/2/2013 6:01:29
PM
F. David Laun Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/2/2013 6:09:33
PM
Brian Carr Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/2/2013 8:54:30
PM
Jeff
Pechmann
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/2/2013 9:34:01
PM
Francis P
Wells Jr
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/2/2013
10:53:14 PM
Raymond
Scoggins
Norwalk Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

-Remove the prohibition on the 'carry of firearms' in section 23-
11/3/2013 8:16:54
AM
Kimberly
Bailey
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/3/2013 9:02:56
AM
Peter Bova Wolcott Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/3/2013 9:59:56
AM
Kurt Asplund Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/3/2013
12:16:02 PM
Ann East Hartford Firearms Permit
Examiners, Board Of
Personal Freedoms I feel that Gov. Malloy has not fully investigated this this
matter of the issues of Firearms. Our rights have been in place
long before violence with weapons became a problem. This
needs to be dealt with by the Authorities and leave the citizens
who are responsible alone.
11/3/2013 1:30:20
PM
Dennis
Michaud
Environmental
Protection, Dept Of
To carry s pistol in a
State forest
You are stepping on my 2nd Amendment rights, no one has that
right.
11/3/2013 1:37:22
PM
James Baroni Cromwell Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/3/2013 2:29:25
PM
Scott Neurath Barkhamsted Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state forests

11/3/2013 2:29:48
PM
Scott Neurath Barkhamsted Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state forests
23-4-1(c) and 26-
66-2

11/3/2013 2:39:05
PM
Kurt L. Schutz Orange Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/3/2013 3:45:16
PM
Joseph
Swetcky, Jr.
Bloomfield Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests and Parks
23-4-1(c) and 26-
66-2
Please modify the State Agencies regulations to allow individuals
handgun for self defense while in certain CT State Parks and in
all CT State Forests.

Specifically:
-Remove the prohibition on the 'carrying of firearms' in
Section 23-4-1(C) of the Connecticut Agencies Regulations;
and revolvers for the purpose of self-defense.

Thank you.
11/3/2013 5:49:33
PM
Marten
Provenzano
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/3/2013 9:46:42
PM
Daniel
Troiano
Cheshire Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/4/2013 1:51:58
AM
Patrick Lloyd Stonington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013 8:29:32
AM
JERRY L.
WALTON
Pawcatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013 9:03:51
AM
Jason Roberts Torrington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

11/4/2013
10:31:35 AM
Jason Deguzis Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013
12:28:13 PM
Bryan
Lazerow
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013 3:58:05
PM
gordon
snyder MD
west hartford Emergency Services
and Public
Protection, Dept Of
carry handguns in
state parks
23.4.1(c), 26.66.2 please make it legal for pistol permit holders to carry handguns
in state parks etc
11/4/2013 4:36:32
PM
David S.
Reynolds
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013 5:26:41
PM
Richard
Schwab
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013 7:07:54
PM
Jason
Magnuson
Willimantic Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013 7:13:28
PM
norman
sholtis
barkhamsted Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1 c --26-66-2 Remove the prohibition on the 'carrying of firearms' in Section
11/4/2013 7:22:59
PM
Rebecca
Cronin
Windham Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/4/2013 9:29:15
PM
Channing L
Poirier
Environmental
Protection, Dept Of
Firearms in State
Parks
23-4-1(c) and 26-
66-2
Dear Governor Malloy:

At a sportsman outing I recently was made aware of the state's
consideration of allowing pistol permittee's to travel in and
through state parks while carrying a weapon.

Frankly, I never knew that carrying a concealed weapon by a
permit holder was illegal in a state park, and my guess is most
permit holders are also unaware of this prohibition.

I am asking you to support any legislation that would overturn
this ban, allowing permit holders to carry in and through parks,
as they would most any other location legally if they choose to
do so (obviously govt buildings and airports/schools excluded.)

Thank you for considering my concerns.

Kind Regards,
Channing L Poirier
East Lyme
11/4/2013
10:28:38 PM
Anthony L.
Cavallaro Jr.
Guilford
Sportsmen's
Association
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/4/2013
11:05:09 PM
LeRoy Kidd New Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 3:47:47
AM
Timothy
Sabrowski
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 7:21:39
AM
Peter
Schoppenhau
er Jr.
What difference
does it make?
Wolcott Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 8:02:17
AM
Daniel
Desjardin
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 9:45:05
AM
James Bicknell Stafford
Springs
Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1[c] and 26-
66-2
Please modify the Agencies Regulations to allow individuals with
valid Permits to carry pistols and revolvers to carry for self
defense while in CT. state parks and forests. Specifically;-
remove the prohibition on the 'carrying of firearms' in section
23-4-1[c] of the Connecticut Agencies Regulations.

Add an exemption to allow the carrying of pistols and revolvers
[including handguns using center-fire ammunition] for the
11/5/2013
10:00:13 AM
William M
Ducci
New
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
is State Forests
23-4-1(c) & 26-66-
2

11/5/2013
10:47:24 AM
bryan
vasconcelos
south
windham
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013
11:56:21 AM
Karl Dale Trumbull Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013
12:48:43 PM
Dan Sullivan Ellington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 1:22:51
PM
Gary Roman Suffield Healthcare Advocate,
Office Of The
Health Care
Insurance
Please advise as to why small businesses, other than the State,
cannot apply for health insurance as an association. My
company is seeing a 20% increase in costs, leading to difficult
buisness decisions about staffing and keeping satff employed as
only part-time employees.

The associations with other employers would tend to spread risk
and possibly lower premiums.
11/5/2013 1:54:30
PM
Ozlem Camli Rainbow Center
for Children &
Families
Wethersfield Education, Dept Of Kindergarten start
age
? Presently, children may enter Kindergarten before they have
turned 5 years of age. The cut off date is turning 5 by December
31 of the year they start school. This is much later than other
states around us. This is making it really difficult for children
with late birthdays, especially boys. This regulation has come up
in the legislation but there has not been a change yet. This
practice is a hardship on children who are not socially and
emotionally ready to start public school and meet the demands
of a structured classroom. These young children are not ready
to focus and stay on task and sustain their work as needed. They
struggle and fall behind, and may never quite catch up with their
peers. Research also supports that children who are pushed to
do academics too early struggle and have further difficulty in
their school years. It is in tehbest interest of the young children
of CT to reconsider this cut off date.
11/5/2013 6:20:44
PM
Don Schuler Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 7:40:36
PM
Jeffrey S.
Owens
waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in CT forest,park
23-4-1(c) and 26-
66-2

11/5/2013 7:43:17
PM
Sandy Bugai Rockfall Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 8:35:12
PM
GERARD
NAPOLI
MANCHESTE
R
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/5/2013 8:46:46
PM
william northford Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2

Regulations
11/5/2013
10:45:37 PM
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11/5/2013
11:38:03 PM
Francis
Bucettas
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 (c) and 26-
66-2

11/6/2013 1:09:47
AM
Scott
Rossignol
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/6/2013 7:02:32
AM
Kenneth
Baker
Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
In the state of Connecticut, It is extremely hard, costly and time
consuming to obtain a carry permit. I am seventy-five, and
having lived in Connecticut for over forty-five years without ANY
blemish on ANY database ANYWHERE, it took me four months to
obtain my permit.
Responsible gun owners are not the problem. It is the fault of
plea-bargaining and/or failure to rigidly enforce existing gun
laws already on the books. Even our existing regulations
regarding OPEN CARRY, and IN HOME self-protection are
confusing and sometimes contradictory.
Common sense tells me that even though I can carry a weapon
into a crowded mall where my chances of being assaulted are
next to zero, I cant carry a weapon in a state park or forest
where an ambush or assault is far more likely to occur.
I realize that there are places where weapons, especially
exposed ones, cannot be allowed. But when was the last time
that you heard of a crazed gunman in an sparsely Populated
state park?
Please change the regulations, and clarify others to permit
responsible gun owners to CARRY (even open-carry) in areas
where they might feel threatened. Believe me; most of us would
rather flee than kill a person or wildlife.
11/6/2013 9:24:41
AM
Randy
Daggett
K.B. Ambulance
Corps
Killingly Motor Vehicles
Department
ambulance
inspections
In regards to DMV ambulance inspection when purchasing a new
ambulance
step 1 stand in line to pay the $20 fee for the inspection, in my
case 45 minutes.
step 2 ambulance inspection only 10 minute wait by DMV
inspector
step 3 return to DMV line to transfer plates to the new
ambulance, one hour wait.
Conclusion: the inspection fee should be built into the transfer
fee so we only have to wait in line once, furthermore many
aspects of the DMV inspection and the OEMS INSPECTIONS ARE
THE SAME, Please help
11/6/2013 9:28:57
AM
Kenneth
Baker
Granby Firearms Permit
Examiners, Board Of
conceal /open carry
regulations
In the state of Connecticut, It is extremely hard, costly and time
consuming to obtain a carry permit. I am seventy-five, and
having lived in Connecticut for over fifty-five years without ANY
blemish on ANY database ANYWHERE, it took me four months to
obtain my permit.
Responsible gun owners are not the problem. It is the fault of
plea-bargaining and/or failure to rigidly enforce existing gun
laws already on the books. Even our existing regulations
regarding OPEN CARRY, and IN HOME self-protection are
confusing and sometimes contradictory.
Common sense tells me that even though I can carry a concealed
weapon into a crowded mall where my chances of being
assaulted are next to zero, I cant carry a weapon in a state park
or forest where an ambush or assault is far more likely to occur.
I realize that there are places where weapons, especially
exposed ones, cannot be allowed. But when was the last time
that you heard of a crazed gunman in an sparsely Populated
state park?
Revisit Sandy Hook for example. It was certainly a tragedy. But
despite the stringiest near lockdown conditions, a determined
madman still couldnt have prevented the killing of those
children with an assault weapon.
I have been to our (Granby) middle/high school complex when
school is starting or ending to pick up one of my grandchildren.
There are numerous LOADED school busses and PRIVATE
vehicles picking up students. There is no way to prevent that
madman from getting out of his car and spraying the entire
scene with gunfire.
Get assult weapons and high capacity magazines off the streets,
RIGIDLY enforce existing gun laws, and allow RESPONSIBLE gun
owners to be able to open or conceal carry hand guns at their
descretion where not specifically forbidden.
11/6/2013 9:40:32
AM
Robert
Makowski
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests

11/6/2013
11:19:47 AM
James
Branson
Brookfield Energy and
Environmental
Protection, Dept Of
Carry Handguns in
state forests
23-4-1(c) and 26-
66-2

11/6/2013
11:36:46 AM
Tristan Wilson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/6/2013
12:11:38 PM
Craig
Pernerewski
Southington I don't know Carrying handguns
in State Forests
23-4-1c and 26-
66-6
11/6/2013
12:18:54 PM
B Cannon Manchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/6/2013 2:24:14
PM
Gummoe Vernon, CT Energy and
Environmental
Protection, Dept Of
Carry handgut in
state parks and fo
23-4-1(c) and 26-
66-2
I would please ask you modify the State Agencies Regulations to

--I would propose to remove the prohibition on the 'carrying of
Regulations
-- Add an exemption to 26-66-2 to allow the carrying of pistols
11/6/2013 2:38:26
PM
Cory Cepelak Cromwell Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/6/2013 4:47:00
PM
Lorry
Champagne
Stafford
Springs
Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1[c] and 26-
66-2
individuals with valid Permits to carry Pistols and Revolvers to
forests. Specifically:-Remove the prohibition on the 'Carrying of
firearms' in Section 23-4-1[c] of the Connecticut Agencies
Regulations
and revolvers [including handguns using center-fire ammunition]
11/6/2013 5:05:15
PM
Michael
McCue
windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/6/2013 5:12:56
PM
David
Stroberg
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/6/2013 5:22:43
PM
Chris Zabka south
windsor
I don't know The Right To Carry
in State Forests
Regulations
11/6/2013 6:55:47
PM
Tim
Rockefeller
North
Branford
Energy and
Environmental
Protection, Dept Of
carrying handguns
in state parks
23-4-1(c) and 26-
66-2



I carried a rifle overseas and I am more than qualified to be safe
with it in the woods for personal protection.
11/6/2013 7:19:06
PM
David
Chapdelaine
North
Grosvenordal
e
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(C) & 26-66-
2


11/6/2013 8:32:22
PM
Michelle
Chapdelaine
North
Grosvenordal
e
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(C) & 26-66-
2


11/6/2013 8:34:59
PM
Frank V
Russello Jr
Guilford Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

11/6/2013 9:30:53
PM
Zachary
Mitchell
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/6/2013
10:44:43 PM
jack Guglielmi Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/6/2013
11:17:23 PM
John M. Joy Oxford Energy and
Environmental
Protection, Dept Of
Handguns in State
Parks & Forests
23-4-1(c) and 26-
66-2
I am a frequent user of the state's parks and forests - they are
wonderful resources. I also have a pistol permit. That I cannot
legally carry there makes absolutely no sense - especially since
the attractive feature of many of DEEP's resources are their
remoteness. I would never think of going there without a first
aid kit; why not the means to defend myself?
11/7/2013 7:04:00
AM
William G.
Pringle, Jr.
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/7/2013 7:32:18
AM
Silvio
Bandeira
Salem Energy and
Environmental
Protection, Dept Of
Handguns in state
forest / parks
Regulations
11/7/2013 8:19:17
AM
Elijah Mitchell New London Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/7/2013
11:15:08 AM
David Rouleau seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Hello. I am writing to recommend a change in regulations 23-4-
1(c) and 26-66-2.

CARRYING HANDGUNS IN STATE PARKS OR FORESTS

" According to DEP, a person may legally possess a handgun in a
state park or forest when carrying the handgun EXCLUSIVELY
FOR HUNTING SMALL GAME(e.g., rabbits, squirrels) or other
authorized activities, such as for use at a firearms range or
participation in a hunter education class. They may only do so at
predetermined times in areas set aside by the DEP commissioner
and posted for such purposes (Conn. Agencies Regs. 26-66-
2(d)). DEP says that what is permissible for hunters depends on
the site and season."

and

"Under DEP regulations, a person cannot use a handgun using
centerfire ammunition to hunt on state-owned land. Handguns
using ammunition larger than .22 caliber rimfire long rifle
cartridges also are prohibited on state-owned land (Conn.
Agencies Regs. 26-66-2 (a))."

I feel that if a person has been through the background checks
required to obtain a Conceiled Carry Permit which as most know
allows a person to carry a handgun in public they should also be
allowed to carry a handgun of any caliber when in state parks
and forests for self defense year round.
Many of the trails on these parks and forests can go several
miles away from civilization. These locations often have little to
no cell phone reception. Should a person encounter a dangerous
animal or person there may be no way for a person to call for
help. If there is cell phone coverage it can be quite difficult to
describe the specific location of the encounter to authorities
therefore dramatically increasing the amount of time it will take
authorities to respond to the scene. If a person was to
encounter an aggressive animal or person they currently have
little means of protecting themselves. Simply the loud noise of a
firearm may be enough to scare away a dangerous animal.
Actually shooting the threat may not even be necessary, after
11/7/2013
12:32:27 PM
which the proper athorities could be notified of the event.
If the encounter was caused by a dangerous animal it may be
rabid and a search for the animal as well as issuing an alert
would seem prudent. If the event was caused by a person the
sutiation would undoubtly warrant police intervention. This is
no diffrent than if one had to draw their handgun in any other
part of the state.
In closing it would not be unreasonable to change this
regulation making carrying conceiled handguns of any caliber for
self defense purposes in state parks and forests legal provided
the person has a valid ct state permit to carry pistols and
revolvers.

Thank you for your time and your consideration in changing
these regulations. I am confident that you can understand my
concerns in this matter.

David T Rouleau
Michael Tolpa Simsbury Energy and
Environmental
Protection, Dept Of
Handguns in State
Forests/parks
23-4-1(c) and 26-
66-2
Regulations
11/7/2013 1:07:46
PM
Mike
Guastaferri
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/7/2013 1:52:51
PM
Joe Bemonte Oakville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/7/2013 1:59:14
PM
Armando
Gonzalez
Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/7/2013 5:24:31
PM
David Dunn Stonington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

Thank you
David Dunn
Stonington, CT
11/7/2013 7:17:12
PM
Christopher
Dejlitko
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/7/2013 7:37:43
PM
Domenico
Cassano
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c) and 26-
66-2

11/7/2013 8:10:24
PM
Denise
Cassano
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/7/2013 8:14:01
PM
Jeffrey S.
Owens
Environmental
Protection, Dept Of
Carrying handguns
in CT forest,park
23-4-1(c) and 26-
66-2

11/7/2013
10:01:23 PM
Timothy
Burby
Bristol Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state parks a

11/8/2013 6:56:28
AM
Michael
Conway
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2

11/8/2013 7:01:14
AM
Dennis P.
Kisyk Sr.
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Regulation Section
Number: Enter 23-
4-1(c) and 26-66-2

11/8/2013 7:37:33
AM
kelly rogers meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
as a legal permit holder i feel that i should be able to carry
anywhere because whose to say that a bad guy isn't in the same
area and decides to commit a act of life threatening violence i
could prevent the situation and save my life and others after all
that's what i went thru training for and spent all this money for
to become a legal gun owner plus im a security officer so i know
something about hostile situations. thank you for listening kelly
11/8/2013 7:37:41
AM
Michael
Anderson
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the State Agencies Regulations to allow citizens
Specifically:

11/8/2013 7:47:43
AM
Elizabeth Mais Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/8/2013 7:48:07
AM
bruno
ceniccola
branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
stop attacking the law bidden citizen... 11/8/2013 8:16:01
AM
David Stocker Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
In the world we live in it would be foolish to be in an isolated
area with out personal protection from human, animal,or
unknown threats to personal safety. As I am handicapped my
protection options for myself and family are limited.Responsible
and permitted gun owners should not be forced to be
defenseless to enjoy the beauty nature has to offer.


11/8/2013 9:11:18
AM
Floyd
Baranello
So. Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/8/2013 9:26:43
AM
Jessica A.
Fletcher
Public Health
Inspector, RS and
REHS
Middletown
(hometown)
I don't know Food Safety and
Inspection
19-13-B-42
Attached is an article I wrote for the latest edition of "The
Environmentalist" (cteha.org) which explains my position:

WHY CT NEEDS TO ADOPT THE FDA MODEL FOOD CODE
Jessica Fletcher, CEHA Technical Advisory Committee on Food
Safety
OK, Im saying itacknowledging the elephant in the room: I
think CT should adopt the FDA Model Food Code. Ive chaired
the CEHA food committee for two years now and while doing so,
searched for a reasonable purpose and maybe a goal for this
committee while attempting to navigate the delicate balance
between CT DPH, local health, tribal sovereignty, and DCP.
While I dont mean to offend the food safety committee
members, to be quite honest, often when I reach out for ideas,
opinions or help, I get little or no response. This apathy
demonstrates the feelings of many health departments about
restaurant inspections here in CT. It might be understandable,
knowing how much there is to do in a local health department:
supervising septic installations, issuing well permits, monitoring
salons, pools, beaches When it comes to the food safety
program, its the same routine year after year, trying to keep up
inspection numbers, deal with complaints, train new inspectors
and worry about accumulating enough CEUs. Its frustrating!
Food inspections often must take a back seat to more pressing
business. Some health departments place the blame for this
frustration on the FPP, but I think its time to realize that some
of it might be due to CTs outdated food safety regulations.
Why should CT adopt the FDA Model Food Code? Well, to date,
New Hampshire, Vermont, and Rhode Island meet Standard 1 of
the Voluntary National Retail Food Regulatory Program
Standards. This means their food safety regulations are
equivalent to the Food Code. In fact, New Hampshire just
adopted the 2009 Food Code in its entirety. Maine and
Massachusetts are very close and currently striving to meet
standard 1 as well. What about Connecticut? While the CT DPH
has used the Food Code in the past as a reference and resource
for issues not included in 19-13-B-42, B-42 does not meet
standard 1 and is not equivalent to the Food Code. In fact, our
CT food safety regulations still lack information on Reduced
11/8/2013 9:28:16
AM
Oxygen Packaging (ROP), which is currently occurring in food
service establishments throughout CT. Calling ROP, which
includes cook chill, sous vide and vacuum packaging, a cooling
method seems to be a way of avoiding a potentially serious
food safety concern. It is also confusing to national restaurant
chains that operate in multiple states. Here are some additional
reasons to consider complete adoption of the Food Code:
Consistency- The best way to promote consistency in food
safety programs in the US is to get everyone using the same
code to regulate retail food operations. The Food Code is widely
used in many states, local and tribal jurisdictions. ANSI
accredited training programs, including ServSafe, use the Food
Code as the basis of their training.
More Partners- Adopting the Food Code connects CT with a
network of professionals and similar programs across the
country with which we can share concerns, exchange
information about what works, and receive support.
Input and Involvement- The Food Code is updated and
modified every two years based on recommendations made by a
nonprofit organization established in 1971 called The
Conference for Food Protection. This consortium of regulatory,
industry, academia and consumer professionals reviews,
discusses and debates food safety issues, both current and
emerging, resulting in a system where every constituent has the
opportunity to voice an opinion and make a contribution.
Collaborating in this process allows participants to share in the
shaping of food safety regulations through the process of issue
submission, council debate, committee work, and voting by state
delegates.
User-Friendly- Theres no doubt about it- the Food Code is easy
to use because the chapters are arranged in order of
importance: high risk -> low risk. Its easy to look things up if
you can identify the violation.
Annexes- In addition, the Food Code comes with an annex
which gives background information on enforcement,
references, administrative guidelines, management practices,
criteria for food processing (ROP), and model forms, including a
model inspection form for food establishments that is widely
used by health departments and companies that design digital
inspection systems.
Up-to-Date- Most importantly, the Food Code is updated every
two years with the latest scientific information available at the
biennial meeting of the Conference for Food Protection.
The CT DPH is currently soliciting volunteers to reconvene a food
safety advisory committee that will include representatives from
state and local regulators, academia, industry and consumers.
The last time this committee met regularly starting in 2005
through 2009, 19-13-B-42 was edited with new language and
updates. None of these changes were ever realized, so the time
and effort spent by this committee was wasted. Maybe this is
the time to consider a different course of action. Instead of
attempting to re-invent the wheel, why not convene this
committee and give them a new charge: adopt the new 2013
FDA Model Food Code. Why not join the other states and
jurisdictions that are working toward national uniformity of our
food safety programs? If you agree that we need to do
something different, speak up and get involved! Maybe
together we can relieve some of the frustration.

Richard
Langley Jr
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests

11/8/2013
10:02:08 AM
Jimmy
Couture
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/8/2013
10:53:09 AM
Mark Wiggins US Coast Guard
retired
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Even though you have ignored us before, I request the following:



There is NO LOGICAL reason for these laws.
11/8/2013
12:29:41 PM
Kevin
Anderson
Portland Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) 26-66-2 - Remove the prohibition on the 'carrying of firearms' in Section
11/8/2013
12:35:13 PM
Jesse Merly Fairfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
While in an isolated areas the need for personal protection is
greatest. Given the fact that law enforcement would not be able
to locate my position let alone arrive in a timely manner in an
instance where my life would be threatened.
11/8/2013 2:02:41
PM
Ken Taylor Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/8/2013 3:10:17
PM
Shaun Buck No Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/8/2013 3:26:09
PM
Kathleen S.
Weberg
Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with a valid CT Pistols and Revolvers Permit to carry a


- Add an exemption to Section 26-66-2 to allow the carrying of
11/8/2013 3:26:20
PM
Kenneth
Prince Jr.
E. Norwalk Energy and
Environmental
Protection, Dept Of
Handguns in state
parks & forests
23-4-1(c) and 26-
66-2

11/8/2013 5:50:18
PM
Claire Wong-
Ostapowicz
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/8/2013 6:25:21
PM
Patrick Lacy Moodus Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/8/2013 7:29:48
PM
Patricia Estok Environmental
Quality, Council On
carrying handguns
in State forests
23-4-1/ 26-22-2 Please modify the State Agencies Regulations to allow

11/8/2013 7:30:32
PM
Matthew
Cassina
CCDL Firearms Permit
Examiners, Board Of
2nd amendment
rights
By limiting state parks and forests to a "gun free zone" you now
put everyone at risk of a mad man and you give these crazy
people another place they know no "law abiding" citizen will be
legally carrying a firearm.
11/8/2013 7:50:10
PM
paul haefner new hartford Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2

11/8/2013 8:55:35
PM
William A
Clark
Trumbull Energy and
Environmental
Protection, Dept Of
handguns in state
foests/parks
23-4-1(c) and 26-
66-2
Regulations
11/8/2013
10:13:02 PM
John Leone New Britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Pistol Permit holders go through training and background checks
and I feel they should be allowed to carry their handguns while
enjoying the parks and forests just as any other citizens.
11/9/2013 3:14:44
PM
Vincent Ierace New Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/9/2013 3:53:05
PM
Anthony
Fusco
tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
8:25:44 AM
Justin Moser Southbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
9:29:06 AM
Joseph
Giordano
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
11:59:28 AM
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11/10/2013
5:11:26 PM
John Dinsdale Shelton Energy and
Environmental
Protection, Dept Of
Concealed carry Please modify the State Agencies Regulations to allow

11/10/2013
10:07:28 PM
Charles
Casciotta
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
10:14:32 PM
Dustin Flagge Northford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
10:15:19 PM
David R.
Buckley
Environmental
Protection, Dept Of
Carrying habdguns
in state forests
23-4-1(c) and26-
66-2

11/10/2013
10:15:44 PM
Matthew
Ferrante
Voting resident of
the state of CT
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
10:24:57 PM
David E Polett Darien
Connecticut
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2
individuals with valid Permits to Carry Pistols and Revolvers, to
11/10/2013
10:26:30 PM
Bill Gagnon Connecticut
Citizens Defense
League, Inc.
New London Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
10:39:19 PM
Nelson
Goewey
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
10:47:00 PM
Donald
Gordon
-- Montville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
10:58:20 PM
Douglass A
Coy
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
11:15:52 PM
Ronald J.
Chiasson Jr.
Portland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
11:16:57 PM
Peter E
Snyder
none Clinton Energy and
Environmental
Protection, Dept Of
handguns in State
forests, parks
23-4-1(c) and 26-
66-2

11/10/2013
11:22:36 PM
Matthew
Strasser
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/10/2013
11:29:33 PM
Jeffrey
Lockwood
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
12:04:32 AM
Eric Fournier Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
12:44:03 AM
AJ Wilkins West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2


Best Regards.
11/11/2013
3:18:22 AM
Scott Skurja Energy and
Environmental
Protection, Dept Of
Fire arms in state
parks & forests
23-4-1(c) and 26-
66-2


11/11/2013
4:45:43 AM
harold
douglas
new britain Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
5:14:48 AM
Richard Smith Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1c & 26-66-2 Please modify the State Agencies Regulations to allow

11/11/2013
5:40:49 AM
Richard
Brown
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
carry a handgun for self-defense while in CT State Parks and
Forests, specifically:

Remove the prohibitions on the 'carrying of firearms' in Section

11/11/2013
5:41:06 AM
Michael J
Malaro
Citizen of the
Great State of
Connecticut
Clinton I don't know Carry of Firearms in
State Parks
Dear Sir; As that I am trained in the use and carry of
firearms/pistols, and I hold a valid pistol permit, I should be
legally allowed to carry in State Parks in Connecticut.
11/11/2013
6:16:15 AM
Joseph Leo Weston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

11/11/2013
6:18:50 AM
Michael J
Malaro
Connecticut
Citizen
Clinton Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2 State Parks
23-4-1(c) and 26-
66-2
Please allow carry of Pistols and Revolvers in State Parks to
those allowed the right to carry. Thank You
11/11/2013
6:19:13 AM
Anthony
Piselli
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
6:20:05 AM
Kenneth T
Goins
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

11/11/2013
6:21:26 AM
gary
wesolowski
burlington Energy and
Environmental
Protection, Dept Of
carrying hndguns in
state forests a
23-4-1 (c) and 26-
66-2
Forests. Specifically
11/11/2013
6:31:58 AM
Ben Ludwig Winsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
6:40:47 AM
April Ludwig Winsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
6:46:01 AM
Matthew
ludwig
Norfolk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
6:58:07 AM
Raymond
Fasano Jr
Wolcott Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Regulation Section
Number: Enter 23-
4-1(c) and 26-66-2

11/11/2013
7:14:18 AM
Steven Fortini Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:15:17 AM
Shawn D.
Gravelin
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:15:30 AM
Gabriel Ardito Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:19:47 AM
William
Gorman
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:21:44 AM
Martial La
Roche
Environmental
Protection, Dept Of
Carrying handguns
in State Forest a
23-4-1(c) and 26-
66-2

11/11/2013
7:21:58 AM
David M Pope Ridgefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:27:09 AM
James Stanley Glastonbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:27:55 AM
Joseph Locke Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:37:49 AM
Sally Wright Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
11/11/2013
7:47:43 AM
David Ogan Unionville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:48:33 AM
Robert Ballas New Fairfield Energy and
Environmental
Protection, Dept Of
Carry handguns in
StateForests&Park
23-4-1(c) and 26-
66-2

11/11/2013
7:54:12 AM
Russell Lowry Coventry Energy and
Environmental
Protection, Dept Of
Carrying pistol in
state parks
Prohibition is a bad idea again. I would prefer to have armed
fellow citizens with permits and training by my side in the
woods, than to find myself facing an evil doer in the woods now
that you have told them where they can go for out of the way,
unseen access to potential victims. You are creating criminal
hunting grounds.
11/11/2013
7:59:23 AM
Pablo Torres new haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
8:00:15 AM
Kenia Torres new haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
8:00:49 AM
Janine Mulder Windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(c) and 26-
66-2

11/11/2013
8:07:37 AM
David Ardito Northford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/11/2013
8:12:12 AM
Gary DiPietro
Sr.
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please remove the prohibition on the 'carrying of firearms' in
11/11/2013
8:25:43 AM
RUDY ALTIERI WILTON Energy and
Environmental
Protection, Dept Of
CARRYING
HANDGUNS IN
STATE FORESTS
23-4-1(C) AND 26-
66-2

11/11/2013
8:27:12 AM
Charles Griffin Glastonbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2
Forests.

Specifically:


11/11/2013
8:31:22 AM
Gary DiPietro
Sr.
Seymour Fish &
Game Club
Oxford Firearms Permit
Examiners, Board Of
Ammunition sales in
private clubs
Our club has many youth members who shoot trap and skeet at
our club. Some of them are members without their parents
being members others are children of members. We need
clarification on giving/selling ammo to them to use at our private
club.The ammunition would only be used at our club and would
not leave the property.
11/11/2013
8:40:56 AM
Jared Kohut Meriden Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:04:08 AM
Robert
Weaver
Wolcott Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 and 26-66-
2
Remove the prohibition on the "carrying of firearme" in section
23-4(C) of the Connecticut Agencies Regulations.
revolvers (including handguns using center- fire ammunition) for
11/11/2013
9:06:28 AM
Stephen J.
Savino
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:06:45 AM
laddie
sacharko
Chaplin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:09:17 AM
Daniel
Jaramillo
Environmental
Protection, Dept Of
Carrying handguns
in State forests
23-4-1(c), 26-66-2 Sir,


for the purposes of self defense. Thank you.

Respectfully, Mr. Daniel Jaramillo
11/11/2013
9:13:06 AM
Gary Mahaffy Plainville Energy and
Environmental
Protection, Dept Of
cary of handguns in
state forests/p
23-4-1(c) and 26-
66-2

Fill out your Name, Email Address and Town.

field Regulations Agency drop-down, Select "Energy and
Environmental Protection, Dept of"

field Regulation Subject Matter: enter Carrying handguns in
State Forests and Parks

field Regulation Section Number: Enter 23-4-1(c) and 26-66-2


for the purposes of self defense. Thank you for your attention.
11/11/2013
9:21:55 AM
Shirley
Mahaffy
Environmental
Protection, Dept Of
carrying of
handguns in state
parks
23-4-1(c) and 26-
66-2
I would like you to modify the State Agencies Regulations to

11/11/2013
9:25:56 AM
Nancy Borzino Thomaston Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:33:14 AM
Donald
Willette
Seymour Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 (c) and 26-
66-2

11/11/2013
9:40:14 AM
Wayne
Rautenberg
Manchester Police
(RET)
Manchester Criminal Justice,
Division Of
carring a firearm in
state parks an
Governor,
Please reconsider amending the bill forbidding the
carrying of a firearm in state parks and forests.
Several years ago congress passed a bill allowing the carrying
of fire arms in federal parks.
One should be able to protect there family and self from
predators be they human or animal.
Thanks
11/11/2013
9:42:16 AM
Gary L.
LaPlante
Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:47:22 AM
Stephen
Granoth
CCDL Morris Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 & 26-66-2 Please modify the State Agencies Regulations to allow

11/11/2013
9:47:38 AM
Janice M.
LaPlante,
Ph.D.
Simsbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:48:30 AM
Becky M.
LaPlante
Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:49:51 AM
Laura L.
LaPlante
Collinsville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:51:22 AM
Richard Blake Northford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:53:23 AM
Lynn
Casassanta
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:54:58 AM
Kim Way Wethersfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
9:56:37 AM
Michael Burke Energy and
Environmental
Protection, Dept Of
carrying of
handguns in state
fores

11/11/2013
10:11:22 AM
Anthony F.
Caruso
NRA Watertown Firearms Permit
Examiners, Board Of
Permits allowed in
state parks


11/11/2013
10:19:43 AM
William
Creech
CCDL Norwich, CT Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
I feel citizens with a license to carry permit should be allowed to
carry their weapon for defensive purposes in State Forests.
Isolated trails away from civilization and public eyes are a great
place for criminals to pray on victims. It is one of the places I
feel least comfortable being unarmed. I take the right to carry
very seriously and feel every citizen has the right to protect
themselves from harm with lethal force as a last resort. I also
feel that criminals are less likely to harm others if they know that
there is potential to be harmed themselves. There is no better
way to advertise a place for a criminal to conduct business than
to declare a place where the innocent will be unable to defend
themselves.
11/11/2013
10:25:34 AM
Edgar R Tecun Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
10:33:49 AM
Ted Criscuolo
Jr.
Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
10:34:00 AM
Philip Kurze Colchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
-Remove the prohibition on the "carrying of firearms" in Section
11/11/2013
10:56:25 AM
Anne Peters Carmody &
Torrance LLP
Energy and
Environmental
Protection, Dept Of
Underground
Storage Tank
22a-449(d)-106 This section sets forth the requirements that apply to owners/
operators of regulated underground storage tank that have
leaked. The section was adopted in 1994 and is now outdated.
Since 1994, DEEP has adopted the Remedial Standard
Regulations, it created the Licensed Environmental Program and
it issued its Site Characterization Guidance Document, which
together describe how virtually all other environmental
investigation and remediation in the state must be conducted.
Moreover, because 22a-449(d)-106 applies only to owners and
operators of tanks, the same spill can be subject to two different
sets of response requirements, depending on whether the work
is being performed by the tank owner or the land owner.

This inconsistency between the requirements that apply to
cleaning up leaks from underground tanks and spills from any
other sources results in uncertainty for the regulated community
as to how the investigation and clean-up should occur, who
must conduct it and when it is deemed complete. The
inconsistency in requirements also causes a duplication of
efforts by both the regulated community and the DEEP without
any added benefit to the environment.

The current language in 22a-449(d)-106 is based on federal
model regulations and EPA must approve any changes. The
requirement for approval does not preclude changes to the
regulations, however. EPA has granted such approval for other
states, such as New Jersey, who revised the federal model of the
regulations to make them compatible with their state remedial
programs. Some states have adopted underground tank release
response regulations that omit the equivalent of 106 entirely
and simply refer to the remedial regulations that apply to all
releases. I respectfully ask that the State of Connecticut consider
a similar revision.

Thank you.
11/11/2013
11:54:14 AM
mike butler CCDL killingworth Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
12:11:02 PM
Kenneth
Fahey
Environmental
Protection, Dept Of
Carrying handguns
in state forests
Forests.

Please remove the prohibition on the "carrying of firearms" in
Please add an exemption to 26-66-2 to allow the carrying of
11/11/2013
12:13:10 PM
Michael
Volovski
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 and 26-66-
2

11/11/2013
12:25:08 PM
Douglas
Kneissl
Derby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1(c) and 26-
66-2

11/11/2013
12:27:56 PM
Jim Gurn CCDL Trumbull Energy and
Environmental
Protection, Dept Of
state forest
How dare you and the Democrats prohibit law abiding citizens
from our right to carry firearms in state forests
Your and the legislators should be ashamed of yourselves
I personally cant wait for the elections
Your HISTORY !!!
11/11/2013
12:38:35 PM
Peter Moses New
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/11/2013
12:50:21 PM
Larry Brown Horton
International
West
Hartford
I don't know RFPs We are an executive search firm and in the past have been
requested to respond to CT RFPs for our services. We have
generally declined as these RFPs are overly bureaucratic
requiring multiple forms, excess documentation and many
signatures. The RPFs convey to the responder that we at the
State believe you are inherently dishonest and we want you to
complete all of these legal forms so we can catch you doing
something wrong. To be successful on this business depends on
a strong working relationship between the consultant and the
hiring agency. Your RFP do not solicit that information.
11/11/2013
12:58:00 PM
Mark Folsom Somers Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
1:26:42 PM
Xavier L
Metichecchia
Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

11/11/2013
1:28:22 PM
Timothy M.
Clark
Environmental
Protection, Dept Of
Carrying handguns
in State Forrests
23-4-1 and 26-66-
2
with valid permits to carry pistols and revolvers, to carry a
handgun for self defense while in CT
State Parks and forests
Specifically
* Remove the prohibition on the carrying of firearms in section
* Add an exemption to 26-66-2 to allow the carrying of pistols
Ammunition) for the purpose of self defense.

This is especially critical in forests and state parks where there is
little or no cell service and the long response times
Of public safety personnel would be of no help
11/11/2013
1:59:27 PM
David Cox Trumbull Energy and
Environmental
Protection, Dept Of
Firearms in State
Forests / Parks
23-4-1(c) and 26-
66-2
Please modify regulations to allow CT residents with valid
Permits to Carry Pistols and Revolvers to carry a handgun for self
defense while in CT State Parks and Forests.

Specifically:- Remove the prohibition on the carrying of
Regulations
11/11/2013
2:00:15 PM
art powell east haven Energy and
Environmental
Protection, Dept Of
carrying hand guns
in state forests
23-4-1(c) and 26-
66-2
Please modify the regulations to allow individuals with a VALID
carry permit to carry hand guns in State Parks and Forests.
Please remove section 23-4-1 (c) and add 26-66-2 to allow
carrying hand guns for the purpose of self defense
11/11/2013
2:05:51 PM
Richard R.
Gott
Meriden, CT
06450
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2
Please modify the State Agencies regulations to allow citizens
with valid carry
permits to carry pistols and revolvers for purposes of self
defense in our State
forests and parks.
Remove the prohibition on the 'carrying of firearms' contained in
Section 23-4-1
(c) of the Connecticut Agency Regulations, and add an
exemption to 26-66-2
to allow for the carrying of pistols and revolvers (including
handguns using
centerfire ammunition) for the purposes of self defense.

Thank You
11/11/2013
2:28:08 PM
Robert Gabris CT voter Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/11/2013
2:35:59 PM
Peter A
Wilson
Sterling Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
2:48:01 PM
David Cox Trumbull Firearms Permit
Examiners, Board Of
Necessity for the
Board's existence
The Board of Firearm Permit Examiners are a necessary,
indispensable check upon local Police Departments that
arbitrarily deny handgun permits to law-abiding applicants.

Local police can and should deny a handgun permit application
where there is specific, tangible, and documented reason. The
'Board's existence deters local Police departments from either
denying or delaying ('tabling') applications out of either an
insubstantiated distrust of the applicant or unofficial-yet-
standard-policy.

My own handgun permit application in 1999 was 'tabled' by the
Trumbull Police for sixteen weeks, and they refused to advise me
of when I might receive a disposition, even though CT statute
requires a disposition within eight weeks. Had there been no
'Board, I would have had no recourse. But I wrote the 'Board to
detail the delay, faxing a copy of that correspondence to the
Trumbull Police. Two days later, my Town permit arrived in the
mail.

My point is that without checks, power can be misused and/or
abused. The Board of Firearm Permit Examiners -- again --
represents a necessary, indispensable check to assure that local
Police departments comply with Connecticut statutes in the area
of dispositioning handgun permit applications.

Please do not allow the 'Board or the 'Board members to be
subjected to political pressure, sanction, and/or otherwise
impair their ability to perform their work that assures fair and
equal treatment to law-abiding CT residents.

I for one am thankful for the 'Board's existence.

Thank you for the opportunity to voice my thoughts.

David Cox
Trumbull
roadguy56@gmail.com
11/11/2013
2:50:33 PM
Chris Bollin Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

11/11/2013
3:34:56 PM
Carl Milano seymour Energy and
Environmental
Protection, Dept Of
carry handgun in
state forests park
23-4-1 (c) and 26-
66-2
Thank you 11/11/2013
3:47:16 PM
Michael J.
Weatherbee
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
3:47:45 PM
Michael
Lazzaro
Colebrook Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c)& 26-66-
2

11/11/2013
5:03:18 PM
Arthur
DeSalvo
Environmental
Protection, Dept Of
Carrying Guns in
State Forest
23-4-1(c) and 26-
66-2

11/11/2013
5:23:30 PM
David Cox Trumbull Emergency Services
and Public
Protection, Dept Of
Legally-armed
protection in
schools
Sec. 53a-217b Dear Governor Malloy,

I'm sure that in the aftermath of the Sandy Hook tragedy, you
can appreciate the public debate on how to best protect
children in school. I for one cannot fathom how we can
positively see the need for an access chokepoint and mandatory
metal detection screening -- operated by armed Law
Enforcement -- at courthouses and key public facilities, and yet
NOT see the foolishness of our current laws positively requiring
of teachers / administrators that they be unable to protect
defenseless children -- exposing those children to what we now
realize is great danger. Not to be too glib, but as was well-stated
in a famed movie, is there any other kind of danger?

The common thread between Adam Lanza, Omar Thornton
(Manchester beer distributorship), James Holmes (Aurora),
Seung-Hui Cho (Virginia Tech), and Eric Harris & Dylan Klebold
(Columbine) is that all of them were attracted to committing
their crimes in what are known as unenforced 'gun-free zones,'
considering that all the perpetrators were keen to avoid a
situation in which they would be confronted by anyone who
even MIGHT be capably-armed. Those perpetrators chose
unenforced 'gun-free zones' on the basis that everyone within
was required -- by law -- to be disarmed, able to only run, or
hide, or helplessly plead for mercy. In each case, when finally
confronted by local police wielding deadly force, the
perpetrator(s) either committed suicide or surrendered
peaceably.

It is my contention and the contention of many, that had the
perpetrator(s) of each shooting known beforehand that there
would be at least one capably armed individual to confront
them, they would have been deterred from committing their
crimes.

I am aware that placing an armed police officer or armed
security guard within each school is impractical, budget-wise ...
and yet something truly effective must be done to better secure
safety of children in school.

11/11/2013
5:56:41 PM
I do not advocate that any teacher or school administrator
holding a handgun permit be automatically allowed to carry a
handgun in school. I believe that not even nearly all responsible
handgun permit holders can handle the far-greater responsibility
of carrying a handgun within a school environment. Still fewer
could be counted upon to act both safely and courageously in
the event of an armed incursion.

I DO advocate that a State-funded psychological screening
program and training program applicable to implementing legal
in-school carry of a handgun for the protection of its children be
made available to any handgun permitted teacher /
administrator VOLUNTEER. Such a volunteer who passes
prerequisite psychological screening could be subsequently
trained to safely carry a handgun in a school environment, to
recognize and avoid situations in which use of deadly force is
inadvisable or inapplicable, even though it might initially seem
necessary, and to think clearly in the presence of a deadly
threat.

It should be the State's expectation that each school could field
at least one teacher / administrator who has passed both the
psychological screening & training, and is willing to use that
training to better-safeguard children within the school in which
he/she works. Larger schools would undoubtedly field more
teachers / administrators; perhaps several.

It would be essential to such a program that the public be
conspicuously made aware of it, not only through mass-media,
but especially through a notice conspicuously posted on the
doors of the schools, stating, "Armed personnel present to
protect our children," a very powerful deterrence to a gun-
wielding coward looking to impose himself upon the
defenseless.

The program's psychological screening and the training would be
of far less expense to CT taxpayers compared to staffing every
school with a police officer or contracted armed security guard.
I expect that the State Police Training Academy could field plenty
of volunteers willing to donate their time in seeing to
implementation of such a program.

In the end, the measure of such a program's value is in how
many lives might such a program save? The problem with that
value assessment is that the number of lives saved by deterring
another armed school incursion are intangible and elusive, in
that an averted tragedy cannot be documented.

Look at this in absolute terms; might ONE life be saved by a
program that has real deterrent effect upon criminals and puts
up a last line of defense against an incursion? If you can answer
'yes,' then I think you can agree then the program I propose is
well-worth the expense and effort to implement it. I do hope
you will consider it.

Thank you for the opportunity to express my thoughts.

David Cox
Trumbull
roadguy56@gmail.com
Paul Mathieu Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

Forests.

Specifically:


11/11/2013
6:57:09 PM
David E.
LaPorte
Rockville Fish &
Game Club, CCDL,
NRA
Ashford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
6:59:57 PM
Michael
Robidoux
Environmental
Protection, Dept Of
Carrying Firearms in
State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:01:10 PM
Bill Unger Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
7:02:36 PM
Mark Vose Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state Forests

11/11/2013
7:36:09 PM
mike Lavoie Shelton Energy and
Environmental
Protection, Dept Of
right to self defense
in state fore
23-4-1(c) and 26-
66-2


11/11/2013
8:15:27 PM
John
Mezzanotte
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
10:59:41 PM
James
Gauthier
Retired Sergeant-
Town of Groton
Police Department
Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/11/2013
11:45:07 PM
k. raymond east haven I don't know law

11/12/2013
12:27:19 AM
Richard
Mitchell
Chester Emergency Services
and Public
Protection, Dept Of
carrying gun in state
forests and p
23-4-1 26-6-2 To allow to carry guns in state forests and parks,Thank you 11/12/2013
6:46:06 AM
Rob Miller Canterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
7:10:05 AM
Stephen
Pickford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
7:41:09 AM
Janice Mandel Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
7:42:16 AM
dennis drown southbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and
26-66-2

11/12/2013
8:25:05 AM
Anthony
Joseph
Ferrara
Derby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
8:32:29 AM
David Irwin Griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
10:10:10 AM
Clare
Waterman
Irwin
Griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
10:10:36 AM
Robert V.
Raby
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
10:19:06 AM
Patrick D.
Malloy
Occupational &
Professional
Licensing Division
Stamford Consumer
Protection, Dept Of
Architectural
Licensing Board
The Department of Consumer Protection Occupational &
Professional Licensing Division has an opportunity to streamline
procedures to get an Architectural License. The current
procedures are outdated and the forms that are required by
applicants to be filled out are outdated as well. The process is
redundant and is already covered by the National Council of
Architectural Registration Boards (NCARB). In addition, the CT
Architectural Licensing Board asks for an applicant to submit an
Application for Architecture License to verify score report on the
Architecture Licensing Exam (ARE administered by NCARB),
these scores are already reported directly to the CT Architectural
Licensing Board which is a redundancy again. Most States that
have direct reporting by NCARB (like Connecticut) have more
streamlined procedures and CT has an opportunity to get up to
date.
11/12/2013
11:13:36 AM
Marcus
Wilczak
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
11:20:14 AM
James
Mierisch
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
11:35:52 AM
Martin
Hamilton
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
1:07:42 PM
Joe Cantillon Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/12/2013
1:36:37 PM
Rick Moody Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
1:41:57 PM
Paul Green East Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
2:07:21 PM
Brenda Steed Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
2:58:47 PM
BRIAN M.
OWENS
CITIZEN KENSINGTON Energy and
Environmental
Protection, Dept Of
CARRYING
HANDGUNS IN
STATE PARK/FOR
23-4-1(C) 26-66-2 Please modify the State Agencies Regulations to allow

for the purposes of self defense. Thank you in advance for your
attention, and public opinion in this matter.
11/12/2013
3:02:44 PM
Raymond
Bennett
Litchfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
3:16:51 PM
John Pepper Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Allow carrying defensive handguns in Forest and Parks


11/12/2013
3:54:46 PM
State Regulations
Thank you for the offer of feedback, and I think it is a great
idea.... if someone is reading and reflecting with purpose. I
apologize but have no ti me to find (impossible task) the specific
regulations relating to the follo wing issues. If the quid pro quo
is that I have to find somewhere in the l iterature the exact
citation before anyone will pay attention, I have not a nd simply
do not have the time in my 70+ hour work week.

Overall, I do not feel that the State of Connecticut in general is a
great State to do business. We are pushing business out
because of taxes, gas pr icing, medical reimbursements, and
medical practices inability to create en terprise. Two items
specifically are:

1) This year, in January and February, we had the highest "call
out" rati o in history. Our Practice does give PTO, or paid time
out to all staff, t hat they can take as they earn it. the State law
that now says they can ca ll out "sick" and be paid regardless of
whether they have earned the time a s yet is not helpful. If an
employee plans in our Practice they can take 3 days over the
following year. That is fair and reasonable.

a. If you do not like the job's benefits, get another job. Forcing
busin esses to offer paid time is handing employees a perk they
haven't earned, a nd is simply more of the philosophy that
rewards bad behavior and punishes the staff who come in. We,
who already offer it, are experiencing people " calling out"
because they can. The State appears to support a program whic
h is very easy for any employee to abuse. It penalizes good
employers, and rewards employees who would manipulate the
system.

2) We would like very much to build our own Operating Room.
Connecticut is a "zero CON State" and we cannot do this. It
inhibits our ability to:

11/6/2013 1:32:14
PM
a. Compete with our contemporaries for better health care
pricing

b. Forces insurance carriers to pay higher prices for Hospital
settings, almost double.

c. Constricts our ability to get better contracted reimbursement
rates wi th insurance carriers.

d. Inhibits our ability to grow our business, provide better
patient acce ss to care, and simplify the surgical process for
patients

e. Inhibits our ability to recruit orthopaedic doctors into the
State. I n addition to the sub par reimbursement levels,
physicians like to be able to work in a free standing OR, it is
much more efficient, and costs patient , insurance carrier and
doctor less money and time.

If you got past the first paragraph, I appreciate your reviewing
these comm ents.

[cid:image003.png@01CEDACA.B1AAE8E0]

Joe-Annis Iodice
Executive Director
Compliance Officer
Comprehensive Orthopaedics
863 North Main St. Extension Ste 200
Wallingford, CT 06492
Office: 203 741-6547
Cell: 203 313-9029
Fax: 203 741-6575
www.comcllc.com
jai@comcllc.com<mailto:jai@comcllc.com>

"Individuals play the game, but teams beat the odds." - SEAL
Team Saying

IMPORTANT: This message is intended for the individual or
entity to which i t is addressed. It may contain information that
is privileged, confidential and exempt from disclosure under
applicable law. If the reader of this mes sage is not the intended
recipient or the employee or agent responsible for delivering
the message to the intended recipient, you are hereby informed
that any use, disclosure, distribution or copying of this message
and any a ttachments is strictly prohibited. If you have received
this message in err or, you are directed to delete it immediately

--
_000_5E78DA0F6C951746840A6D8CF496FCC044CE2512Maveric
kcorpcom_<
signing duplicate
medical orders
I take care of several developmentally disabled adults who live
at group
homes and attend sheltered workshops. I have to sign several
pages of
medical orders for each person every 90 days or so and this is an
activity
that I essentially do for free as it occurs outside of patient visits
and I
can not bill for it.
The current regulations (I think from DMH or DDD) require I sign
an
original copy of each page for the group home and then a
second copy of
each page for the sheltered workshop. The orders arrive as NCR
(newer
version of carbon paper) triplicate forms and once I sign the top
page, my
signature appears on all 3 copies. Then I have to again sign one
of the
copies again so the pages that go to the sheltered workshop
have an
original signature and not a carbon copy.
This amounts to a lot of wasted time for me. Eventually with
electronic
records, both places will just have to look at a computer and see
that I
have electronically approved a single set of orders.
I suggest modifying the law or regulations so the physician can
sign one
set of orders and if they want a copy at the sheltered workshop,
they can
accept the carbon copied signature that appears on the page
they receive.

--
Jeffrey M. Kagan, MD

--089e01175f6d461d7d04ea77f668<
11/5/2013 8:21:00
PM
Unnecessary State
Rules
To whom it may concern, the following was taken from the DEEP
web site; "Can I continue to hunt deer or small game with my
Bushmaster AR-15 rifl e?It depends on where you hunt, since
possession is restricted. There ar e new requirements for the
possession of certain types of center-fire assau lt style
semiautomatic rifles and some shotguns which will require the
owne r to register those firearms with the Department of
Emergency Services and Public Protection prior to January 1,
2014 (Download Registration Form). On ce registered, those
specific firearms still cannot be used on any public l ands but
they may be used for hunting on the owner's own property or
on pri vate lands with express permission of the landowner.
Download a complete li sting of the restricted firearms which
require DESPP registration and can o nly be possessed under
certain conditions." Firs t off, to hunt deer in Connecticut you
have to use a 6mm round or larger, a n AR-15 is made in two
calibers, the .223 or know as 5.56mm and the .308 ca liber, so
how is it that whom ever wrote this did NOT put in there that
the .223 or 5.56mm can NOT be used for deer hunting, only
6mm or larger. It se ems that alot of misinformation is being
given out on state weapons and hun ting laws or are people at
the DEEP just making up laws as they feel ? Robert Staurovsky34
Rockland AvenueStratford, CT. 06614Cell 1-203-449-4321
---1412092350-788968489-1383055153=:60281<
10/29/2013
6:59:13 AM
Dept of Public
Health regulations
To Whom It May Concern;

I am a long time early childhood education center serving
children of six weeks through twelve years of age. My concern is
not so much the existing regulations, but for some entities in
our state, lack of regulations. In many areas of the state, town
recreation departments and certain non profit groups are
running school age prgrams in our school systems, and do not
have to report whatsoever to the Department of public health.
This saves them much time and money, and the safety and
health issues we need to adhere to as private business owners is
exempt for town sponsored non profits. This is hurting our
businesses greatly, as we cannot afford to lower our costs given
our overhead, and I'm pretty sure that most families do not
know that their schoolage program is unregulated. This means
no safety measures required, no background checks required,
and no staff to child ratios are required. State Regulations need
to apply to EVERYONE running a program for children, not just
some. When questioning Department of Health, I have been
told, "we have no jurisdiction over that". It simply does not
make sense, and liability concerns must be considered, for the
programs and the families.Please consider looking into this.
Sincerely, Cathy W. DelGreco, Owner/Director, New England
Preschool Academy, Inc. 860-627-6575
------=_NextPart_000_0052_01CEDAF9.D89AF970<
11/6/2013 2:09:45
PM
ATV usage on State
Property
I am an avid ATV rider, but because ATV's are not allowed to be
used
ANYWHERE legally in Connecticut, I am forced to drive all of the
way to Western
Massachusetts to ride legally.

I am forced to register all 3 of my ATV's in Massachusetts, pay
the sales
tax to Mass and also a yearly registration fee.

I would much rather have a closer place to ride and to be able to
keep my
tax dollars here in Connecticut. I agree not every state park
should be open
to ATV or motorcycle(Dirt bike) but some of them should be.
Respect the
rights of everyone who wants to use our state parks and not just
those who
enjoy hiking, horseback riding or mountain bike riding.

On a regular basis I read about people getting arrested in the
local towns
for illegally riding and maybe the arrests could be reduced if
people
actually had a safe and legal place to ride.

The ability for residents to legally ride would also have a very
positive
impact on the state Powersports dealers and I'm sure they
would see an
increase in sales.

Thank you,
Tom Wilkinson
69 Woods Hill Rd
Northford, CT 06472

--part1_1d759.507c3683.3faa91e9_boundary<
11/5/2013 1:24:41
PM
Devin T
Maloney
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

11/12/2013
5:23:42 PM
Anthony Rocky Hill Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in StaTe Forests
individuals with valid permits to Carry Pistols and Revolvers to

revolvers (including handguns using center-fire ammunition)for
the purposes of self defense
11/12/2013
5:38:19 PM
Mariusz
Zalewski
East
Hampton
Energy and
Environmental
Protection, Dept Of


Justification: There are still dangerous animals roaming CT parks
and forests. Having a firearm will give individuals with valid
permits a chance to defend themselves, people around them
against vicious, rabbit animals.
It will also give them a chance to defend themselves and people
around them in case of a violent crime where loss of life, limb or
eyesight is imminent.
11/12/2013
6:51:24 PM
Mike sullivan Southbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
Specifically:
- remove the prohibition on carrying of firearms in section 23-4-
1(c) of the connecticut agencies regulations
revolvers (including handguns using centerfire ammunition) for
11/12/2013
7:04:47 PM
David Combs Columbia Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
7:19:55 PM
Barry Smith Ridgefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c} and 26-
66-2

11/12/2013
8:09:23 PM
Tina
Binheimer
tolland Energy and
Environmental
Protection, Dept Of
Carry Handguns in
State Forests and
23-4-1(c) and 26-
66-2

11/12/2013
8:10:52 PM
Kevin P. Dunn Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/12/2013
9:04:09 PM
William
Donahue
Portland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
I am asking you to please modify the State Agencies Regulations
to allow individuals with valid Permits to Carry Pistols and
Parks and Forests.

Specifically:

11/12/2013
9:22:18 PM
Kenneth
lowell
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and26-
66-2


11/12/2013
9:22:33 PM
Richard Lee Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forrests
23-4-1 (c) & 26-
66-2
Regulations
11/12/2013
9:54:14 PM
Grant H. Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
Dear Governor,



Thank you.
11/12/2013
10:29:23 PM
Bruce
Pendleton
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/13/2013
6:49:07 AM
Edward
Aldrich
Goshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/13/2013
7:34:27 AM
Joy Burlington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/13/2013
7:48:14 AM
Oriane Alves FAIRFIELD Energy and
Environmental
Protection, Dept Of
Carrying Hanguns in
States Forests
23-4-1(c) and 26-
66-2

11/13/2013
8:02:09 AM
Steve Price Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2


11/13/2013
8:25:36 AM
Joseph Justus Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State forests
23-4-1(c) & 26-66-
2
carry a handgun for self defense while in Ct.state parks and
forests. Specifically: Remove prohibition on the "carrying of
firearms" in section 23-4-1(c) of the Connecticut Agencies
Regulations.
and revolvers(including handguns using center-fire

Thankyou for your time,
Sincerely,Mr.Joseph Justus

11/13/2013
9:50:07 AM
Michael
Chiloyan
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/13/2013
9:53:24 AM
Giulio
Cancellieri
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

1) Remove the prohibition on the 'carrying of firearms' in Section

2) Add an exemption to 26-66-2 to allow the carrying of pistols
11/13/2013
10:01:12 AM
jose roman waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/13/2013
11:57:21 AM
Brandon C
Martinelli
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/13/2013
11:58:56 AM
Michael
Cervellino
State of CT Tax
payer
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2

11/13/2013
12:58:39 PM
Elizabeth
Drysdale
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/13/2013
3:06:25 PM
Kay Drysdale Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/13/2013
3:07:04 PM
Kit Drysdale Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/13/2013
3:07:59 PM
Timothy
Nagle
shelton Energy and
Environmental
Protection, Dept Of
carrying hand guns
in state forests
23-4-1(c) and 26-
66-2

11/13/2013
3:28:12 PM
Joseph
LaChioma
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1 & 26-
66-2

11/13/2013
6:24:27 PM
ronald t.
cimini
north haven,
ct.
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/13/2013
7:09:14 PM
christine gray tolland Energy and
Environmental
Protection, Dept Of
enter Carrying
handguns in State
Fo
23-4-1(c) and 26-
66-2

11/13/2013
8:12:49 PM
Paul T Orsino
Jr
Energy and
Environmental
Protection, Dept Of
Carry of pistols and
revolvers

the purposes of self defense.Carry of pistols and revolvers
11/14/2013
6:42:15 AM
Paul Dummitt
Jr
Farmington Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2

11/14/2013
8:21:46 AM
Andrew
Lukban
Hartland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
My 2nd Amendment right to self defense as guaranteed by the
Constitution of these United States should not be invalid when I
am on public property. It should be honored.


11/14/2013
10:11:50 AM
Brian
Broadrick
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/14/2013
1:15:11 PM
Shane Nelson Burlington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/14/2013
7:09:44 PM
Peter Bronson Norwalk Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2


11/14/2013
8:36:42 PM
Andrew
Embury
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forest
23-4-1(c) and 26-
66-2


11/14/2013
9:02:44 PM
edwin cay east windsor Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest a
23-4-1(c) and 26-
66-2

11/15/2013
12:48:16 AM
Brian King Norwich Energy and
Environmental
Protection, Dept Of
State parks and
forests


Thank you Brian King
11/15/2013
8:04:19 AM
Kevin burlington Public Health, Dept
Of
day care 19a-79-4a(a)(1) change requirement for adult physicals from 24 months to 36
months.
11/15/2013
9:26:13 AM
Of
day care 19a-79-6a(c)(11) Increase years first aid manual is good for from 5 years to 10
years.
11/15/2013
9:30:36 AM
Todd
Hillebrecht
Bristol Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
self defense while in Ct State Parks and Forests. Specifically:


11/15/2013
9:57:08 AM
Kevin P.
Parent
PLANTSVILLE Energy and
Environmental
Protection, Dept Of
carrying handguns
in State Forest a
23-4-1(c) and 26-
66-2
Specifically:

-Remove the prohibition on the "carrying of firearms" in
section 23-4-1(c) of the Connecticut Agencies Regulations
- Add an exemption to 26-66--2 to allow the carrying of
ammunition)for the purpose of self defense
11/15/2013
9:58:23 AM
Of
day care 19a-79-10(f)(3) plastic bags shall be inaccessible is already covered in 19a-79-
10(h)(2)
11/15/2013
10:07:25 AM
James Garlock Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/15/2013
1:16:10 PM
Dennis Rae jr. Colebrook Energy and
Environmental
Protection, Dept Of
23-4-1 23-4-1 I think u should let people to carry a hand gun in state forest. As
long as they have a permit
11/15/2013
7:11:11 PM
Robert Reid US Citizen Stafford
Springs
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/15/2013
8:01:04 PM
mike thibault Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/16/2013
7:19:12 AM
Christopher
M. Gazsi
NAUGATUCK Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/16/2013
9:59:37 AM
Peter Brown Middlefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please change the regs to allow pistol permit holders access to
these areas. Pistol permit holders go through an FBI background
check as one of the criteria for getting the permit. The bad-guys
who don't (and can't) get a pistol permit ignore your laws
anyway, so I don't see why the laws should stop only the people
who have passed the background checks.
Thank you,
Peter Brown, 93 Baileyville Rd. Middlefield CT. 06455
11/16/2013
10:00:08 AM
mike baio old saybrook Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/16/2013
12:08:23 PM
Peter T.
Obuchowski
Griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/16/2013
12:34:27 PM
Richard M
Giannini
New britain Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

11/16/2013
3:14:09 PM
Joseph F.
Keane III
Derby Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in St. Forests &
23-4-1(c) and 26-
66-2

11/16/2013
3:48:05 PM
Shane Nadeau plainfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/16/2013
7:50:30 PM
Matthew
Glidden
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/16/2013
9:40:18 PM
Justin doss Middlefield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 26-66-2

11/17/2013
12:11:04 AM
Jonathan
Zeman
Stamford Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2


11/17/2013
7:50:09 AM
Jack Kelley Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/17/2013
8:41:21 AM
jennifer Energy and
Environmental
Protection, Dept Of
carrying hand guns
in state forests

11/17/2013
8:55:25 AM
Michael
Giangregorio
Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

Governor or Whomever reads this,


11/17/2013
1:26:48 PM
AnnMarie
Gazsi
Oxford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
11/17/2013
3:32:15 PM
louis vuitton
outlet
http://www.cckkk.
com/louisvuitton-
outlet.html
louis vuitton
outlet
outlet
Keep in mind that a perefume may smell differently once it
leaves the store, and aftter wearing it for an entire day.
11/17/2013
5:59:05 PM
Michael
Pisano
Bethel Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state parks
23-4-1(c) and 26-
66-2

11/18/2013
12:09:25 AM
Shane Carlson Litchfield Energy and
Environmental
Protection, Dept Of
handgun carry: state
parks/forests
23-4-1(c) and 26-
66-2

11/18/2013
12:12:57 AM
sean mcintyre bristol I don't know carry in public parks Its our land. We have a right to protect our selves on our own
land.
11/18/2013
1:34:31 AM
Christine
McEvoy
Oxford Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

11/18/2013
7:26:20 AM
Tim Sotolongo Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/18/2013
8:45:16 AM
Patrick Smith Montville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/18/2013
9:22:10 AM
Jonna Ambur North Haven Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

11/18/2013
9:31:04 AM
Daniel W
Rhoads
Barkhamsted Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/18/2013
10:41:05 AM
Richard
Borecki
Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
While the following was pre-written, I FULLY support the
proposal and strongly encourage the changes.


11/18/2013
12:30:31 PM
Anthony
Colucci
Trumbull Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) & 26-66-
2
- Remove the prohibition on the "carrying of firearms" in Section

11/18/2013
12:38:22 PM
David
Robertson
Branford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2



Thank you
11/18/2013
12:43:52 PM
Roger
Cormier
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

11/18/2013
2:54:27 PM
Robert
Arseneault
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/18/2013
3:51:47 PM
Gary
Svenningsen
JR
none Oxford Energy and
Environmental
Protection, Dept Of
carrying a handgun
in state forest
23-4-1(c) / 26-66-
2


11/18/2013
5:05:22 PM
GORDON
JONES
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/18/2013
5:54:18 PM
Fred Pasler Burlington Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

11/18/2013
7:29:43 PM
Alicia Glifort Northford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


11/19/2013
8:07:13 AM
Donald Aitken
Sr.
NRA member Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/19/2013
12:09:33 PM
Edward
Sanchez
shelton Energy and
Environmental
Protection, Dept Of
handguns in state
forest and park
23-4-1(c) and 26-
66-2

11/19/2013
1:57:15 PM
Brian Bolter Plantsville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/19/2013
3:21:50 PM
dano iamaw cromwell Governor's Office guns in parks whats the problem?. 11/19/2013
5:25:28 PM
John
Mastrianni Jr.
Derby I don't know Carry on State Park Concealed Carry in State Forest should be allowed. I find it
funny that in the same forest I carry a shotgun year round for
hunting, but not a 9mm Pistol for self defense if someone tries
to harm my family or myself when we are hiking...
11/19/2013
6:48:39 PM
mark
moorman
NVCC-DOL- TRA-
UI-AAG-Superior
Court
Woodbury Attorney General,
Office Of The
DOL- AGENT for
Federal TRA
The issue I raise is an ongoing problem with TRA administration,
lack of the state to comply with the TRA, The problem is
multifaceted, one area is tyhe participants are not treated
properly at many stages of the TRA.
This infringes upon the participants * UI benifits.

My case is still an issue, one of many , and many other are
unaware of the problem due to the failure of the TRA
management at the DOL. SO many are hur with out a recourse
such as a appeal. As in my case, and extraoridanary effort to
force a appeal via help from state representative my case made
it to the superior court.

But from the dol office and all the way up to the court the state
failed to comply with honoring the TRA in totality.
AT the court the state atty, AAG and the Judge were anaware of
the nature and the working of the TRA. And stragely enough the
state admited it never handled one yet.

This is due to the state failing to allow participant to file a appeal
to start with. That along with many other aspects of the TRA that
were not followed by the State
the program in effect hurts the participants, this is totaly oposite
of the purpose of the TRA.
This case is documented UWY-cv-12-5016389-s .

There are problems at the * DOL, AAG, Court and all other
supporting staff at the State for the program.
This undermined the case before the superior court as the judge
was impacted by the states statement and presentations that
the TRA was not the ruling law over the TRA training program
that was the central , focus of the appeal. * lack of TRA payment
for 104 week and improper payments of UI.

11/19/2013
7:09:00 PM
This all transpired under the direction of dol staff, specificaly
Maria Lagasse. Who to date has failed to present the truth of the
TRA program and provide the signed contact which the state
engaged my participation as a qualified approved TRA
participant.

I would like to follow - up this letter with a in person meeting to
fully address the issues.

Thank you
Mark Moorman
* AT each step of this case the state failed to provide or support
it's status as the **(agent) for the Federal program.
Stephen
Strawinski
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/19/2013
8:41:44 PM
Thomas Scelfo Woodard & Curran North
Branford
Energy and
Environmental
Protection, Dept Of
Particulate
Emissions
22a-174-18(f) Regulation 22a-174-18(f). Process Industries General (Process
Weight Regulations)

RCSA 22a-174- 18(f) is an old air pollution regulation that dates
back to regulations initially established in Los Angeles, California
in 1949. The regulation contains a table that lists allowable
emissions rates for particulate matter in pounds per hour based
on the total weight in pounds of all materials introduced into a
process that may cause the emissions of particulate matter. The
emission limits in this regulation are based on the weight of
material processed in an attempt to supplement standards
based on air flow from stack exhausts for certain process
industries (e.g., iron foundries, steel blast furnaces) because
facilitys in these industries could have injected air to dilute the
stack exhaust stream to comply with early air pollution
regulations. At the time of passage, facilities subject to this
regulation were all equipped with exhaust stacks where
emissions could easily be controlled, and exhaust gasses could
be sampled and emissions quantified. This process weight
regulation was refined in 1959 by the Bay Area Air Pollution
Control District in San Francisco, and this type of regulation was
adopted by states across the nation before the Clean Air Act
came into existence.

Today, the regulation rarely imposes conditions more stringent
than newer air emissions standards on the types of processes
originally intended to be regulated by this regulation. However,
CTDEEP has begun to apply this old regulation to emissions from
various fugitive sources that do not exhaust through a stack, and
in that context, the regulation would prohibit many industrial
operations in the state, including welding. The CTDEEP has
sought to apply this regulation to outdoor abrasive blasting
operations, which also cannot comply with the requirement,
which was never intended to apply to fugitive emission sources.
Furthermore, even if a fugitive emission source could use a
calculation to demonstrate compliance with these regulations,
such sources cannot demonstrate compliance through testing
since fugitive emissions cannot be accurately measured. In
addition, the regulation is not designed to address small
particulates (PM 2.5 or PM10) but rather Total Suspended
11/20/2013
11:27:40 AM
Particulates, which is no longer a pollutant regulated as a
National Ambient Air Quality Standard.

The original purpose of this specific regulation was to control
particulate emissions from certain industries that processed
large volumes of material with exhausts that vented through
point source discharges, all of which could be controlled with air
pollution control equipment. It was not intended to address
small emission sources, like welding operations, paint booths or
abrasive blasting operations, which cannot be described by the
title of section 22a-174-18(f), Process industries general.
Applying this regulation to all operations that are not process
industries, as some CTDEEP personnel have suggested, would
make certain activities, such as welding, illegal in Connecticut.

Section 22a-174-18(f) should be deleted as obsolete. If the
Department concludes that it would be too difficult or time-
consuming to delete the regulation, it should be revised to be
similar to New Yorks process weight regulation which restricts
its application to ten specific emission sources that are listed in 6
NYCRR Part 212: General Process Emission Sources, section
212.9(e), most of which do not exist in Connecticut (e.g., lime
kilns, glass production furnaces, gypsum dryers).
Roger A.
Diebel
Preston Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

11/20/2013
1:34:04 PM
Jason Chasse Burlington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/20/2013
4:03:45 PM
Robert
Dingman
Windsor
Locks
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/20/2013
8:16:41 PM
Robert
O'Connell
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/20/2013
8:21:43 PM
Mark R.
Sussman
Murtha Cullina LLP Hartford Energy and
Environmental
Protection, Dept Of
Air Pollution 22a-174-6 This regulation sets forth requirements for air pollution
emergency episodes. It has not been updated since 1993, and to
my knowledge, the emergency episode steps called for by the
regulation fortunately have not been triggered in decades, if
ever. The Department should review the standards in the
regulations to see if they are still appropriate. In addition, some
of the steps called for under various emergency episodes need
to be revisited. For example, if an emergency is triggered, no
"incinerators" can be operated. Since Connecticut relies so
heavily on resource recovery, shutting down all of these units
could result in other health hazards. Moreover, the resource
recovery facilities have modern air pollution controls that were
not required when this regulation was initially adopted in the
late 1970's or early 1980's.
11/21/2013
9:05:43 AM
James L.
Machie sr.
Willimantic Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(c) and 26-
66-2

11/21/2013
10:16:59 AM
Ann Morse Middletown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1 (c) and 26-
66-2

11/21/2013
10:36:49 AM
Troy Wood Killingly Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/21/2013
4:26:06 PM
C.Messologitis Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/21/2013
6:12:50 PM
Ken Locke Sandy Hook Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/21/2013
8:17:49 PM
Christopher
Byrne
Goshen Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/21/2013
9:15:42 PM
Michael
DeLany
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-c(1) and 26-
66-2


11/21/2013
9:45:02 PM
Sheila foster Norwich Environmental
Quality, Council On
Carrying handguns
in State Forest a
23-4-1(c) & 26-
66-2
Please modify the State Agencies Regulation to allow individuals
with valid Permits to carry pistols and revolvers to carry a
handgun for self defense while in CT State Parks and Forest.
Specifically:
-Remove the prohibition on the carrying of firearms in Section
11/21/2013
9:49:25 PM
Angela N
Pellegrini
N North
Branford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/22/2013
10:37:41 AM
louis vuitton
outlet
http://www.katieh
aines.com/louisvui
tton-outlet.html
louis vuitton
outlet
outlet
For the green crowd, they are more acceptable over alternatives
such as plastic bags.
11/22/2013
1:34:18 PM
larry deluca stamford ct Firearms Permit
Examiners, Board Of
fire arm regulations
and magazine
how about the illegall people that have more deadly weapons
than most legitimate gun owners have? i think this is very
unconstitutional to institute these regulation for honest firearm
users. check how many tTexas teachers and others have been
able to stop offensive shooters in schools and malls and other
buildings.
i still appreciate you as a mayor but this law interfears with Ipic
and Lipssic compatisions, these are legitimate competitions and
no one has ever shot anyone else in these competitions, thiis is a
sad situation. be a fighter for the 2nd amendment rights.
thank you,
larry deluca
stamford resident
11/22/2013
3:20:57 PM
Riccardo
Abate
Branford Energy and
Environmental
Protection, Dept Of
Carrying hang guns
in state forests
23-4-1(c) and 26-
66-2


11/24/2013
1:54:13 AM
mike haeseler ledyard Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

11/24/2013
5:34:15 AM
Michael A.
Palazzi
Andover Policy And
Management, Office
Of
Ct gun law I think this gun bill was rushed through the legislature at the
insistence of the Governor due the the Sandy Hook murders.
This is only makes it difficult for law abiding citizens to obtain
guns and ammunition. It does nothing to stop the daily killings in
all major cities in ct. It does nothing to suppress the flow of
illegal guns in ct. It has nothing to penalize the person
committing a crime with an illegal gun.
I don't understand why it was rushed through before the report
from the Governor appointed commission was available
investigating the Sandy Hook murders. I'm sure there will be
some good information that would be useful to include in any
gun bill.I don't believe it is public to this date!!
I sincerely feel this was a spur of the moment idea to control
guns in ct. Some of the ideas in the bill are good and are needed
for safety, but falls short on controlling crime in the cities.
11/24/2013
12:58:02 PM
John Energy and
Environmental
Protection, Dept Of
Carrying handgund
in state parks an


11/24/2013
1:08:43 PM
Jeff
McLaughlin
willimantic Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1 (c) And 26-
66-2
Regulations
11/24/2013
1:44:54 PM
Rob Collin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/24/2013
7:37:15 PM
n plymouth Energy and
Environmental
Protection, Dept Of
handguns in state
forests/parks
23-4-1(c) and 26-
66-2
specifically: remove the prohibition on the 'carrying of firearms'
in section 23-4-1(c) of the Connecticut agencies regulations.
11/24/2013
8:58:41 PM
Hyde Harman Voluntown Energy and
Environmental
Protection, Dept Of
right to carry It just seems to me that if I jump through all the requirement to
carry a hand gun in Conn. it simply doesn't seem that I should be
restricted as to where I carry one. This especially should be the
case in the state forest system. Thank you, Hyde Harman
11/25/2013
11:33:17 AM
Vin Gaetano CT Resident,
Taxpayer, Hunter
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Additionally, I am a trained firearm user (rifle, shotgun,
handgun) and trained archer. (I completed TWO Handgun Cert
classes, TWO Hunting Safety Courses, and One Bowhunter Safety
class, all here in CT), and have a CT Firearm Permit

In addition to my infrequent hunting, I am an avid hiker, and
bicyclist (CT Rail Trails and some forests). I am deeply concerned
about the increased presence / reported sightings of the Black
Bear - I understand Connecticut has limited resources in
managing this bear population, and I would enjoy the appreciate
the added protection of my firearm.

Kind Regards -
Vin Gaetano
Wallingford CT
11/25/2013
12:10:42 PM
State regulations
that harm
[Comment Emailed with an attachment]

Thanking you in advance for your consideration
--

*Maureen Griffin*

--089e0149411abf42f404ebf326af<
11/24/2013
4:44:26 PM
Regulations on small
business

As a small CT manufacturer,with a payroll $ 1,994,000.00 / yr.
our total
insurance costs for employee Health Insurance was $ 342,000.00
/ yr and
Worker Compensation Insurance was $ 282,000.00 / yr ... Those
2 costs are
31% on top of that payroll figure. Within that $ 282.000.00
Comp
figure was $ 3,457.00 for the Ct Accessment Fund and $
7,196.00 for the Ct
2nd injury Funds.

We contribute over 90% of the cost of our employees health
plan, because we
feel it's an asset to keep our employees healthy.

Since we deal with large OEM's like Sikorsky, Rolls, PW, Triumpf
in the
state and out... ...it's impossible to raise our pricing at the same
rates
that insurance has goes up. We need the state to help hold
down those
costs. As a manufacturer our Comp. mod rate in our type
industry is
always higher because of the nature of our hard work! And
the Class
we're in covers a small group, because not many of us are left.
I
would like to see how the state could promote some relief there.

All those high costs take away our abilty to grow and support
more jobs.

11/22/2013
3:02:08 PM

Now with the Affordable Health Care Act, emplorers like us with
there own
private health plans will have to contribute accessments to
support the fund
that protects insurers that run the Federal Affordable Health
Care plans.
So that law costs us even more again! It never seems to end!

At any given time, one of my employees may be covered under
3 different
insurance plans.. Workers Comp, Health, or Motor Vehicle
Insurance.

When the State and Federal govt got into affordable health care,
why
couldn't we have covered everyone with one plan 24 hours a day
at work or at
home..combining Health and Comp. It seems we have
redundancy there,
that hurts all us in the competition of the market place.

Mark Vecchiarelli

President

Yankee Casting Co., Inc.

243 Shaker Rd.

Enfield, CT 06082

Phone: (860) 749-6171

Fax: (860) 763-3342

website: <http://www.yankeecasting.com>
www.yankeecasting.com

cid:image001.jpg@01CE929A.27D36F70
cid:image002.jpg@01CE929A.27D36F70

cid:image003.jpg@01CE929A.27D36F70cid:image004.jpg@01CE
929A.27D36F70cid:imag
e005.jpg@01CE929A.27D36F70

This email message and any attachments are for the sole use of
the intended
recipient(s) including the e-mail addresses of other parties. It
may contain
proprietary and/or confidential information which may be
privileged or
otherwise protected from disclosure and may be subject to the
International
Traffic in Arms Regulations (ITAR) or the Export Administration
Regulations
(EAR). Any unauthorized review, use, disclosure or distribution is
prohibited. The recipient of this information may not disclose,
export,
re-export, or transfer the information to any Foreign Person,
within or
outside the United States, without following all applicable
requirements of
the U.S. export control regulations. If you are not the intended
recipient(s), or an authorized representative of the intended
recipient(s),
and received this transmission in error, please contact the
sender by reply
email immediately and permanently destroy the original
message and any
copies of the message as well as any attachments to the original
message.

------=_NextPart_001_0027_01CEE793.D16F63B0<
Duplicative
Regulations
[Comment Emailed with an attachment]
format=flowed

Thank you for the opportunity to comment on regulations that
are
duplicative. I have focused on the food service regulations in the
CT
Public Health Code.

Eloise Hazelwood

--
Eloise Hazelwood, RS, MPH
Director of Health
Town of Wallingford
203-294-2065
wlfdhealth@sbcglobal.net

--------------000006070403000907050304<
11/25/2013
11:45:42 AM
Very Small Business
Owner Complaint

I don't understand the need for a $250.00 per year Enterprise
Tax on small
businesses.

I'm a retired guy d/b/a Tribury Media, LLC to pick up some extra
money for
myself. My business makes only a few thousand dollars per year,
between
$2,500 and $5,000 gross.

By the time I pay my expenses and my state and federal income
taxes, and
fill out all the myriad forms - there is precious little profit. Out of
that "profit" the State of Connecticut wants me to send them
$250.00.

This is a real disincentive to me keeping the business alive. I'd be
much
better off doing my services cash and barter to avoid taxes.

I'm sure there are hundreds if not thousands of small
entrepreneurs just
like me. Isn't the State Income Tax enough?

--
*Terrence S. McAuliffe*
Owner, Tribury Media, LLC
30 Independence Circle
Middlebury, CT 06762
203-758-1492 Office
203-770-9744 Cell

--047d7b10c8733b217904ebf0a279<
11/24/2013
1:44:13 PM
Shane
Thibodeau
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/25/2013
4:03:00 PM
John Hayes Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/25/2013
6:04:33 PM
James
Bonnanzio
Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/25/2013
6:23:37 PM
Eugene
Flannigan
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/25/2013
9:25:43 PM
Lisa M
Martins
BROOKLYN Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/25/2013
9:48:07 PM
Jonathan
smart
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2

11/25/2013
11:40:51 PM
Steve
McGough
Windsor
Locks
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/26/2013
9:28:57 AM
James
Bernetich
Environmental
Protection, Dept Of
Sunday Hunting
restriction
I feel that Hunting should be allowed on Sunday. Please review
this regulation and explore the possibility of lifting this
restriction.
11/26/2013
10:33:21 AM
Jeffrey J
Scarpace
Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you for your considerations.
11/26/2013
5:13:00 PM
James Regan Berlin Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
11/26/2013
10:22:46 PM
Jose Paul
Magalhaes
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/26/2013
11:24:16 PM
Jesus Arce Manchester Energy and
Environmental
Protection, Dept Of
Carrying a hand gun
in a state park
23-4-1(c) and 26-
66-2

11/27/2013
10:15:31 AM
Allen F. petri Lyme Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2
with valid Permits to carry Pistols and Revolvers to carry a
handgun for self defense while in State Parks and Forests.
Specifically: Remove the prohibition from the 'carrying of
firearms' in Section23-4-1(c) of the Connecticut Agencies
Regulations - Add an exemption to 26-66-2 to allow the carrying
11/27/2013
11:23:58 AM
Epifanio Colon Ellington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/27/2013
4:11:34 PM
Eric G. Koch Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in St. For. & Pks
23-4-1(c) & 26-66-
2
individuals with valid Permits to Crry Pistols and Revolvers to
Forrests.
Specifically:
-Remove the prohibition on carrying of firearms in section 23-4-
1(C) of the CT Agencies regulations.
11/27/2013
5:34:23 PM
Sheila M.
Koch
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in St. For. & Pks
23-4-1(c) & 26-66-
2
Forrests.
Specifically:
11/27/2013
5:35:09 PM
Quinten M.
Koch
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in St. For. & Pks
23-4-1(c) & 26-66-
2
Forrests.
Specifically:
11/27/2013
5:35:41 PM
Daniel J.
Stritch
Trumbull, CT Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/27/2013
6:41:05 PM
LOU
CARPENTER
SHELTON Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

11/28/2013
8:14:38 AM
Jon Northway Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/28/2013
9:43:14 AM
Judy Connell-
Northway
Cheshire Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/28/2013
9:44:42 AM
Jamie Haddad Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thanks you.
11/29/2013
7:00:06 AM
Gregory prospect Energy and
Environmental
Protection, Dept Of
Carrying Possession
of a Hand Gun
23-4-1(c) 26-66-2 Please Modify the state agencies
regulation to allow individuals with valid
permits to carry pistols and revolvers to
carry a handgun while in CT state parks and
forests.
Remove the prohibition on the carrying of firearms
in section 23-1 (c)

Add an Exemption to 26-66-2 to allow the carry
of pistols and revolvers that is permitted
on state highways and other state owned
property.
11/29/2013
8:37:51 AM
William Baker West
Hartford
Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests

11/29/2013
11:06:47 AM
Matt Dziurgot Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/29/2013
7:04:07 PM
ken hicks wwoodstock I don't know Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
all of these new gun laws will not prevent another incident like
in newtown from happening. law abiding citizens should be
encouraged to carry instead of being made to feel like criminals.
if anything makes sense it is expanding background checks and
harsher penalties for gun based crimes. guns are not the
problem people are the problem and stricter mental health
regulations should be put into effect for those with existing
conditions. to myself and many others this makes more sense
than any other restrictions. the fact that these awful acts were
carried out with fire arms is disturbing. at the same time if this
individual was not able to get a hold of the guns his mother had
he would have found a different means of attacking the school. I
have also noticed that the term serial killer is not in the news as
much any more. it seems that they have evolved from doing
several incidents to just one major one. that is why mental
health should get a bigger focus than any other aspect in this
state let alone country.
11/30/2013
9:08:16 AM
Robert Tuttle Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/30/2013
10:24:32 AM
Peter
Ceulemans
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests


---------------------------------------------------------
11/30/2013
12:01:11 PM
Daniel Wrobel Colchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/30/2013
3:28:15 PM
louis vuitton
outlet
http://www.chevi
deco.be/louisvuitt
on-outlet.html
louis vuitton
outlet
outlet
No matter you is a welcome woman, a perfect woman, a strong
female character or a female character for peace.
11/30/2013
4:08:59 PM
alex
poulicakos
Energy and
Environmental
Protection, Dept Of
carry in state forests 23-4-1

11/30/2013
6:15:46 PM
alex
poulicakos
Energy and
Environmental
Protection, Dept Of

11/30/2013
6:15:58 PM
alex
poulicakos
Energy and
Environmental
Protection, Dept Of

11/30/2013
6:16:10 PM
samantha
robert
Energy and
Environmental
Protection, Dept Of

11/30/2013
6:19:41 PM
Robert G Paris Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

11/30/2013
8:10:42 PM
James
Connelly
West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/1/2013 1:53:41
PM
Salvatore
Rubano
cheshire, ct Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/1/2013 2:26:18
PM
Stephen Lotto Prospect Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forest a

- Remove the Prohibition on the `carrying of firearms' in section
23-4-1(c) of the Connect Agencies Regulations.

- Add an exemption to 26-66-2 to allow the carrying of pistol and
revolvers( including handgun using center-fire ammunition) for
12/1/2013 9:01:25
PM
undesireable
regulations

Please remove the "prevailing wage laws" and ALL requirements
that unfairly increase the cost of doing business in this
state.Help us to become mor e competitive in with other states
and countries for added business and com panies. Drop all laws
that try to regulate the interaction of compa nies and unions.
eliminate requirements about mandatory arbitration. Try to take
the government out of regulations hindering job growth.Re duce
business taxes. When we have JOBS people will be able and
willing t o pay their fair share of taxes. Quit subsidizing things
that are n ot economically viable such as electric cars and
charging stations, solar c ells on buildings.Severely restrict the
DEEP ability to wreak havoc on c ompanies for minor "problems"
with insignificant spills. Limit response to spills of 100 gallons
(not 1 drop in present law). Same with private citizens, no legal
response to minor amounts (under 10 gallons per year).
Eliminate wetlands commissions that unfairly limit ability of
owners to utilize their property. Help us compete for MORE
JOBS in this state. Bill Fuller, Bristol, CT.

11/27/2013
3:32:03 PM
Jason Cole Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/2/2013 4:29:32
PM
Olga Gotta STAMFORD Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/2/2013 4:31:03
PM
Richard M
Allen
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) & 26-66-
2


12/2/2013 4:31:26
PM
David Nault Bethel Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1c and 26-
66-2

12/2/2013 4:40:46
PM
Mark A.
Melley
independant Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/2/2013 6:23:45
PM
Mike Manzi Harwinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/2/2013 7:32:17
PM
George R
Curry
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2
Please alter the Regulations to permit men and women with
Permits to Carry Pistols and Revolvers to carry a handgun for
self-defense while in Connecticut Forests and Parks.

Kindly, remove the prohibition on the 'Carrying of Firearms' in
section 23-4-1(c) and include an exemption to 26-66-2 to allow
the carrying of pistols and revolvers(including handguns utilizing
center-fire ammunition)for the purposes of the GOD given right
of self-defense.
12/2/2013 7:58:49
PM
Ralph
Chappano
Avon Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in CT Forests/Pks
* Remove the prohibition on the 'carrying of firearms' in Section
23-4-1(c) of the CT Agencies Regulations
* Add an exemption to 26-66-2 to allow the carrying of pistols
12/3/2013 8:42:37
AM
Stephen J.
Savino
Burlington Governor's Office Firearms carry in
state forests
So this means someone hiking in the woods is not allowed to
protect themselves from an animal attack. What is wrong with
you people?? There has been an increase in wild animal
encounters of late in residential areas. A Coyote walked through
my yard just last week end. I would not go hiking in the woods
without a means of protection.
12/3/2013 9:47:04
AM
Thomas
Franek
Wolcott Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks

12/3/2013 9:58:24
AM
jonathan van
ryzin
norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

12/3/2013
10:27:42 AM
Ray Cote Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013
11:17:12 AM
Daniel
Battistini Jr
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013
11:52:32 AM
Fernando
Solis
East
Hampton
Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013 1:56:32
PM
Adam
Kalinowski
Norwalk Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Kind regards,
Adam Kalinowski
12/3/2013 4:00:47
PM
Sean Lassen Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013 6:01:34
PM
William Wolfe Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/3/2013 6:35:25
PM
T.M.
Fitzgerald
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013 7:39:15
PM
JOHN
BELLEAU
HAMDEN Energy and
Environmental
Protection, Dept Of
CARRYING
HANDGUNS IN
STATE FORESTS
23-4-1(c) AND 26-
66-2

12/3/2013 7:40:43
PM
christopher
labonne
griswold Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013 7:41:44
PM
Robert A Cote NRA winsted Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest a
23-4-1 (c) 26-66-2 Please modify the State Agencies Regulations to allow

12/3/2013 7:51:24
PM
John P Kelly Marlborough Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013 8:49:48
PM
Dave Johnson Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013 9:31:43
PM
Mike Young Danbury Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

12/3/2013 9:54:10
PM
Michael
Dalena
PLainville Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/3/2013
10:47:31 PM
Dennis Rae jr. Colebrook Emergency Services
and Public
Protection, Dept Of
Carry in state forest Permit holders should be able to carry anywhere. 12/4/2013 7:54:12
AM
Corine
Hellerman
Energy and
Environmental
Protection, Dept Of
Permit/exemption
for soil strippers
22a-174-3a A stripping facility used to remove VOC from contaminated
groundwater or soil with 95% control efficiency does not require
an air permit. However, the definition of VOC, and hence this
permit exemption, does not include perchloroethylene, a
commonly stripped compound.

The definitions in 22a-174-1 include organic compounds, which
would include perc, but the stripping facility exemption specifies
VOC, not organic compounds.

Perchloroethylene (perc) is an organic compound that is
commonly stripped from soil and water and is not a VOC. Other
organic compounds that are not defined as VOCs, including
methylene chloride, 1,1,1 trichloroethane, methylene-chloride,
trichlorotrifluoroethane and many freons that were used in
degreasers for metal cleaning, are also stripped from soil and
water. Historical degreasing is a major reason that soil vapor
extractors are used. Further, CT's definition of stripping
facility uses the term organic compounds, but the permit
exemption in 22a-174-3a(a)(2)(B)(ii) for stripping facilities uses
the more restrictive term VOC.

Thus, it follows that a permit should not be required for an
exempt VOC soil stripping facility, when a permit exemption
with requirements or permit by rule would suffice.
A permit for such an operation would most likely have the same
requirements as the permit exemption requirement of 95%.

It is also suggested that this exemption could be modified to
include stripping of any organic compounds.
12/4/2013
11:48:36 AM
William Rahl Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in St. Forests
23-4-1(c) and 26-
66-2
As A law abiding citizen for 58 years in my birth state of CT and
a Pistol Permit holder for 40 years

I am allowed to carry just about anywhere in the State but
would be unable to defend myself,family or friends should we be
encountered by a gang or other person or animal that meant us
harm. Please consider this as common sense law
Sincerely,
William Rahl
12/4/2013
12:45:24 PM
Chris Asetta Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/4/2013 5:30:32
PM
Paul McVay Watertown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

12/4/2013 9:29:43
PM
Richard
Parmalee
Danbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/4/2013 9:32:10
PM
Tomothy
Hawks
Baltic Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/4/2013 9:41:22
PM
William
Moran
Bethlehem Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/5/2013 6:02:06
AM
David Pang Westport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/5/2013 8:32:30
AM
Victor Ribera North
Branford
Energy and
Environmental
Protection, Dept Of
hand gun carrying in
state forestan
23-4-1(c) and 26-
66-2


12/5/2013 2:45:40
PM
justin williams naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

-I purposely do not use the state parks and forest because I
cannot protect my self or my family. 4 legged creatures can be
just as dangerous as 2 legged.

Please change this!!!!
12/5/2013 2:55:51
PM
Michael
Eastland
CCDL Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2



this change would be especially helpful to women who could
find themselves vulnerable to a larger male attacker.
12/5/2013 4:03:02
PM
LaVan
Norwood
Military Veteran Salem Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
I am deeply offended by your efforts to deny me the rights I
served my country to protect! I full stand by the following
statements.


12/5/2013 9:25:24
PM
Brooke
Cheney
Environmental
Protection, Dept Of
Carry in State
Forests and Parks
23-4-1(c) and 26-
66-2
I was with my two children 5&6 years old, we were picking up
trash in a CT state park. We were far from anyone we knew, but
close to the access road. As a van drove by slowly I realized that
as a lone woman with 2 small kids in the woods I had little or no
options to defend myself or my kids. As a victim of violent crime
I know it can happen in an instant.


12/5/2013
10:58:07 PM
Jason Walllingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/5/2013
11:15:58 PM
Robert Voytas southport Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/6/2013 7:17:22
AM
John Eno Meriden Motor Vehicles
Department
Suspended Liscense The time period to process suspended liscneses take way to long
and it affects a lot of people if they take their time and when it
comes to the suspension day being up and no word or anything
from them about it
12/6/2013
10:37:27 AM
Josh
Cleveland
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) 26-66-2

12/6/2013
12:22:10 PM
Laurence
Styga
Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/6/2013 2:10:00
PM
Excessively
burdensome
regulation


I would draw your attention to the twelve pages of regulations
(Sections 7- 170 to 7-185) currently regulating raffles, the five or
more pages in the a pplication packet, and the time it takes both
at town hall and in the Depar tment of Consumer Protection to
process these applications. Could we not ha ve a threshold prize
value-perhaps just for nonprofit organizations-below w hich all
this is unnecessary? Or a blanket permit for five years? The
burde n on our small churches, daycare centers, civic
organizations is not insign ificant, and there has to be better use
of our state government employees' time than reviewing these
applications.

The raffle regulations are a small issue, but they reinforce the
very negat ive impression local citizens have of the state
government bureaucracy.


Cathy

__________________________

Catherine Iino
First Selectwoman
Town of Killingworth

323 Route 81
Killingworth, Connecticut 06419

860-663-1765, ext. 501
860-301-1398 (cell)

________________________________

12/5/2013
10:28:15 PM
This correspondence contains proprietary information some or
all of which m ay be legally privileged; it is for the intended
recipient only. If you are not the intended recipient you must
not use, disclose, distribute, copy, p rint or rely on this
correspondence and completely dispose of the correspon dence
immediately. Please notify the sender if you have received this
email in error. NOTE: Messages to or from the Town of
Killingworth domain are su bject to the Freedom of Information
statutes and regulations.

The Town of Killingworth,
Connecticut<http://www.townofkillingworth.com/>

--
_000_85D9171F3F2ADF459BB6C11A5429C52D8BC538ECmail01
kwlocal_<
Possible obsolete
DMV regulations for
review

To whom it may concern,

I would like to submit a Department of Motor Vehicles
Regulation for review. The regulation deals with a "class 1A"
driver's license. It appears that this is related to driving a
tractor-trailer combination with 2 trailers.

I believe that currently a driver would need a Class "A"
Commercial Drivers License with a "T" Endorsement for double
and triple trailers. I believe the Class 1A license is obsolete and
no longer issued.

Requirements for the Issuance of a Class 1A Operator's License
and Administrative Penalty for Operating a Commercial Vehicle
Combination without Such License

Regulation 14-261a-1



Sincerely,

Corporal Brian Norko

Stratford Police Department

bnorko@townofstratford.com

203-385-4186

--Boundary_(ID_sBqWD4p423Aa2wYnjcCBJg)<
12/5/2013 3:37:52
PM
brownfields

MUST change law that the only way DEEP staff gets paid is when
they signoff on projects. They have no clue how onerous the
regs are and how much Brown field's stuff is nonsense. Its
"normal" for simple clean-up jobs to take YE ARS.
Thanks
Jon Brayshaw
First Selectman
Middlefield

--
_000_EDEF7ECE6F4D1845B797ED86941D1B140B6D1AMIDDLEFI
ELD02midd_<
12/6/2013 5:26:23
PM
eileen costello danbury Early Childhood,
Office of
teacher
qualifications
Please consider grandfathering language in the early childhood
teacher qualifications. The number of people in the workforce is
not sufficient enough to meet the new staff qualification
mandate. There are also no additional funds to pay for the staff
with higher degrees. School Readiness programs are at a tipping
point. The mandates on higher quality, while necessary and
supported by those in the field, are impossible to meet while
being flat funded for 5+ years. These mandates are causing
deficits in many of the programs. If we continue to mandate
quality initiatives, we must also support an annual COLA to these
programs and to the administration of the program.
12/6/2013 3:05:14
PM
Brendan
Malone
Suffield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2
Specifically:
-Remove the prohibition on 'carrying of firearms' in section 23-4-
1(c) of the Connecticut Agencies Regulations
and revolvers(including handguns using centerfire ammunition)
12/6/2013 4:22:58
PM
Juleen
Flanigan
Education
Connection
Litchfield Developmental
Services, Dept Of
parent fees Birth to Three The CT Birth to Three program serves infants and toddlers with
developmental delays. This program originates in the federal
IDEA law. Within the last 10 years, the state of CT through DDS
established a parent fee system for parents of infants and
toddlers with developmental delays in order to generate more
revenue for the program. Children who are eligible to receive
services have significant delays in development. We continue to
lose families in this system because the fee is too high. This
defeats the intent of this program which is early identification of
a developmental need in order to provide services that may
improve their developmental level so they are not in need of the
expensive preschool education services. Parents are required to
allow their insurance plans to be billed for services and in
addition need to pay a parent fee. This is counterproductive to
the goal of the program. When children enter the public school
system at the age of 3, parents are not required to pay a parent
fee. So the policy is also not consistent with school policy. The
parent fee is not a requirement of the federal law that governs
this program and is counterproductive to helping children.
12/6/2013 4:31:13
PM
Nicholas
Marsan
Norwalk Energy and
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
12/6/2013 4:37:10
PM
Tim Jones Newington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/6/2013 9:45:46
PM
Sean B Cocola South
Glastonbury
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/6/2013
11:11:00 PM
Jean Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1 (c) and 26-
66-2

12/7/2013
10:33:34 AM
Allen Riquier CCDL, NRA Chaplin Governor's Office Pistol carry in state
parks
I believe that legal concealed carry of hand guns should be
allowed in state parks. I live on 11 acres of land surrounded by
2700 acres of state and federal land. I see no reason for not
being allowed to carry. We have had dozens of people of
questionable intent, including escaped convicts hiding out at
Mansfield Hollow State Park. The good guys should be armed as
well.
12/7/2013
10:44:26 AM
Mike Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

12/8/2013 2:54:05
AM
Alex Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

12/8/2013 2:54:56
AM
Gilda Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

12/8/2013 2:55:15
AM
Michael Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

12/8/2013 2:55:47
AM
Lawrence
Dotter
East
Hampton
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:23:08
AM
Vincent
Ackerman
Killingworth Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:45:24
AM
Raymond
Heely
Preston Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

12/8/2013 9:44:41
AM
Mark Jalbert Waterford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 9:51:29
AM
Ryan
Brielmann
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

12/8/2013 2:24:19
PM
Frank
Dombroski
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(c) & 26-66-
2
Forests. Specifically: Remove the prohibition on the 'carrying of
firearms' in section 23-4-(c)of the Connecticut Agencies
of pistol and revolvers(including handguns using center-fire
12/8/2013 2:29:54
PM
Valerie
Dombroski
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(c) & 26-66-
2
firearms' in section 23-4-(c)of the Connecticut Agencies
of pistol and revolvers(including handguns using center-fire
12/8/2013 2:33:20
PM
Omar Rawlins Naugatuck Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:18:14
PM
Joshua Benoit Enfield Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks
23-4-1(c) and 26-
66-2

12/8/2013 8:21:15
PM
Michael Heine Tolland Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2

12/8/2013 8:22:44
PM
Shachar J
Baitch
West
Hartford
Energy and
Environmental
Protection, Dept Of
Carry handguns
State forests/parks
23-4-1(c) and 26-
66-2

12/8/2013 8:25:19
PM
Jason Lopez Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:26:29
PM
Jason houle Milford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1c and 26-
66-2

12/8/2013 8:30:22
PM
Mark Hazzard Terryville Energy and
Environmental
Protection, Dept Of
firearms in state
parks and forests
I would like to say I have spent much money on permits and
training federal law says I have a right to carry in these places
The second amendment clearly states I have a right to keep and
bear arms why does the state of CT. feel they have the right to
counter the Constitution of the United States?
12/8/2013 8:31:00
PM
Eric Parent CCDL Ashford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:43:14
PM
John Hobden Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
3-4-1(c) and 26-
66-2


12/8/2013 8:44:59
PM
Lazarus
Alperovich
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:48:41
PM
Kris
Lingenfelter
Windsor
locks
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:53:17
PM
Charles
Graffeo
Bethel Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 8:55:50
PM
Glenn Higney North
Windham
I don't know Carrying a handgun
in State Forests
Explain to me why it is lawful for us as permit holder in Ct to be
trusted by the State of. CT to carry a hand gun anywhere in the
state except state land. Does the Gov think that we don't need
protect on state land or that bad people don't hang around in
state forests. I hike a lot of trails throuout the state and I've
been confronted by some pretty bad looking people. If I can't
carry in state forests and land I and my family will just stop using
these areas for my family. Just one more reason to think about
moving my family and business from this state. This used to be a
great state to live in and it seems like we just keep getting
pushed out.
12/8/2013 9:00:09
PM
George
Robinson
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

Sincerely,
George C Robinson
12/8/2013 9:08:53
PM
Anthony
Perrelli
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 9:10:40
PM
Scott R.
Despres
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 9:13:27
PM
Jack
Kavanaugh
Groton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 9:20:10
PM
Victor J.
Strama
Woodstock Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013 9:28:21
PM
James S.
Borbas
Prospect Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in State Forest
23-4-1(c) and 26-
66-2
carry a hand gun for self defense while in State Parks and
Forests. Specifically: Remove the prohibition on the "carrying of
firearms" in Section 23-4-1(c) of the Connecticut Agencies
Regulations. Add an exception to 26-66-2 to allow the carrying of
12/8/2013 9:39:28
PM
Donald
Gordon
Oakdale Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and26-
66-2

12/8/2013
10:03:35 PM
David Bartlett Montville Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013
10:03:59 PM
william
connole
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/8/2013
10:07:08 PM
Allen Gerard Retired CT Police
Officer
Prospect Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please represent me as a law abiding citizen, tax payer and
voter in the state of Connecticut and modify state regulations to
Revolvers, to carry a handgun for self defense while in
Connecticut State Parks and Forests.

Rural areas such as Connecticut forests and parks are prime
locations for violent criminals to pry on defenseless citizens.
There hasn't been any abundance of problems with law abiding
pistol permit holder citizens carrying handguns for self defence
in Connecticut forests and Parks to warrant this new restriction.
Banning the good guy men and women will just serve as a green
light for the criminal element to commit crimes of violence in
these areas, now unchallenged.

Specifically:
12/8/2013
10:24:23 PM
Michael
Lathrop
Eastford Energy and
Environmental
Protection, Dept Of
State parks
23-4-1(c) and 26-
66-2


12/8/2013
10:44:53 PM
Ronald N.
Saunders
Environmental
Protection, Dept Of
Carring handguns in
state Forests a
23-4-1(c) and 26-
66-2

12/8/2013
10:55:50 PM
Stephen Ricci North Haven Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013
10:59:07 PM
James Pecca Bethany Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013
11:01:44 PM
Andrew
DeJoseph
Milford Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest &
23-4-1(c) and 26-
66-2
Please modify the State Agencies Regulation to allow individuals
with valid permits to Carry Pistols and Revolvers to carry a
handgun for self defense while in CT Parks and Forest.
Specifically remove the prohibition on the "carrying of firearms"
in section23-4-(c) of the Connecticut Agencies Regulations. And
an exception to 26-66-2 to allow the carrying of pistols and
12/8/2013
11:19:55 PM
Charles D.
Newell
Pomfret
Center
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013
11:32:40 PM
Oscar Manero Stamford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/8/2013
11:50:04 PM
Bill Gagnon New London Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013
12:36:58 AM
James Scullyt Eat Hartford Energy and
Environmental
Protection, Dept Of
Carrying guns in
State Forests and
23-4-1(c) and 26-
66-2


12/9/2013 6:39:52
AM
Bryan Arndt Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
12/9/2013 6:40:21
AM
Norann Dillon Revenue Services,
Dept Of
The Bottle Bill Section 22a-243 Repeal the bottle bill, please. It's a hassle on consumers and
retailers, and I guess distributors, too - I didn't know they had to
pay and refund the deposit until reading the FAQs about it. The
machines are broken half the time and they reject bottles and
cans if they aren't programmed to accept them even though you
paid the deposit. Curbside recycling is pretty standard these
days so why keep subjecting us to this hassle?
12/9/2013 6:56:19
AM
Michael Habif Norwalk Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 7:07:54
AM
Joseph
Sproviero
easton Energy and
Environmental
Protection, Dept Of
carry handguns in
state parks
23-4-1(c), 26-66-2 Handgun permut holders have been fully vetted
and should be able to carry in state parks and forests just like
anywhere else
12/9/2013 7:12:17
AM
Shane
Delaney
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 7:25:12
AM
Christopher
Tolla
STAMFORD Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 7:29:15
AM
Joe Donahue thomaston Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest
23-4-1[c] , 26-66-2 Please remove the prohibition on the carrying of firearms in
section 23-4-1[c]. Please add an exemption to 26-66-2 to allow
the carry of pistols and revolvers [including handguns using
center-fire ammunition] for the purposes or self defense. thank
you
12/9/2013 7:52:19
AM
Johnny Carrier Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 7:59:46
AM
James Bills East Hartford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 8:35:07
AM
John Swanson East Granby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Parks
23-4-1(c) ; 26-66-2 Please modify the State Agencies Regulations to allow

12/9/2013 8:44:25
AM
David
LaPointe
Canterbury
CT
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 8:46:57
AM
Alton Blodgett Lebanon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state forests
23-4-1(c) and 26-
66-2


12/9/2013 9:04:15
AM
Michael J
Malaro
Resident of the the
Great State of
Connecticut
Clinton Emergency Services
and Public
Protection, Dept Of
State Parks an
23-4-1(c) and 26-
66-2



12/9/2013 9:09:03
AM
Spencer Energy and
Environmental
Protection, Dept Of
23-4-1(c) and 26-66-
2

12/9/2013 9:46:04
AM
David Lenihan Energy and
Environmental
Protection, Dept Of
Carryin handguns in
stae forests
23-4-1(c) and 26-
66-2


12/9/2013
10:16:02 AM
jeff a myshka oakdale Governor's Office the right to carry
handguns
handgun for self defends while in Ct. state parks and forest
specifically : Remove the prohibition
on the the carry of firearms in section 23-4-1(c) of Ct. agencies
regulations.
Add an exemption to 26-66-2 allow the carrying of pistols and
revolvers (including handguns using Center -fire ammunition) for
the purposes of self defends.
12/9/2013
10:26:36 AM
Jeremy
Hanson
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013
10:28:07 AM
Michael
Mayer
Bethlehem Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank You,
Mike Mayer
12/9/2013
10:43:25 AM
Thomas J
Gallagher
North
Branford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/9/2013
10:58:58 AM
Tom Smith Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
As a Ct Pistol Permit holder, hiker, hunter, fisherman and senior
citizen, I feel it should be my right if I choose, to legally carry a
hand gun in the CT state forests and some state parks for
personal protection.

While open carry is legal in CT in certain areas and under certain
conditions, I agree and concede the proper method of carry in
State parks and State Forests should be concealed, so as not to
alarm others in the area.

While I see no need for a hand gun at state parks such as
Hamonassett,or other beaches, parks and picnic areas
frequented by families, I feel it is viable in CT's State Forests and
rural undeveloped parks such Salmon River and Horse Pond and
the like .

I like to hike hunt and fish, and do so mostly alone.

I have encountered and been approached by individuals and
groups of individuals in the Mashomesec State Forest whose
activities were/are somewhat questionable.

Luckily, my body language demonstrated I wanted nothing to do
with them, but as a lone senior citizen I did feel very
uncomfortable at the time.

If Ct citizens are properly licensed and permited, I can see no
reason to restrict the carrying of a hand gun for personal
protection in these areas.

I do not, and will not condone any recreational shooting in these
State Forest areas, but I see personal protection as being
needed.

Thank you for the opportunity to express my views. I await your
response and decision on this matter.

Thomas Smith
182 Evergreen Road
Cromwell, CT 06416
12/9/2013
11:15:58 AM

trsbws@sbcglobal.net
Emma P.
Canas-Strama
Woodstock Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1(c) and 26-
66-2

12/9/2013
11:39:15 AM
Bruce Wagner Shelton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests


12/9/2013
11:43:10 AM
Paul J Dejohn Wethersfield Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in Stae Forest
23-4-1(c) and 26-
66-2

12/9/2013
11:46:24 AM
Matthew
LaFayette
Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/9/2013
11:59:20 AM
Edward J
Menard
Windsor Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013
12:14:33 PM
Zane Dargaty Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013
12:43:57 PM
Angelo
Fiducia
Berlin Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forest
23-4-1 (c) & 26-
66-2
firearms' in section 23-4-1 (c)of the Connecticut Agencies
12/9/2013 1:22:33
PM
John Lubinski beacon falls Governor's Office right to carry in
state forests
Dear Governor Malloy, we the people that are pistol permit
holders should while hiking in our state forests be able to carry a
side arm for protection, for ourself and others that are with the
permit holder while using the forests. there are so many
preditors out there such as bears, coyotes, mountain lions yes I
said mountain lions they are out there, if you walk up on any one
of these animals and they are with there young there could be
an accident waiting to happen thank you for your time John
12/9/2013 1:24:06
PM
William
Morey
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) & 26-66-
2

12/9/2013 1:24:51
PM
Brian Van
Damme
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

12/9/2013 1:31:59
PM
Michael
McJunkins
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

12/9/2013 1:36:46
PM
Joseph
DeLuca
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 2:07:15
PM
craig ingalls Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 2:19:46
PM
Corine
Hellerman
Energy and
Environmental
Protection, Dept Of
Operation of
emergency engines
22a-174-3b, 22 As evidenced by DEEP's presentation material on p. 11 here:
http://www.ct.gov/deep/lib/deep/air/siprac/2011/rice_neshap.
pdf ,

emergency engines are subject to CT's requirements, which are
very different, and sometimes in conflict, with EPA's
requirements under 40 CFR 63, Subpart 4Z NESHAP.
Specifically, the two agencies define emergency differently and
allow operation under differing circumstances.

Regulatory burden would be greatly reduced if CT adopted the
EPA requirements, as well as EPA's white paper, which
acknowledges that emergency generators typically do not
operate much, and uses 500 hours per year to calculate
potential emissions. Many states use this guidance. This would
be prudent, especially in light of the recent amnesty letters
issued by CT DEEP for operating emergency generators during
storm events.
http://www.epa.gov/ttn/oarpg/t5/memoranda/emgen.pdf
12/9/2013 2:49:41
PM
Pedro Ferrer southbury Governor's Office Right to carry in
State Parks
As law abiding citizens it is a shame that for our own protection
after having gone through training, paying all license fees and
registrations we as rightful pistol permitt license holders cannot
enjoy the same freedom and safety and ability to potect
ourselves and loved ones in a state park.

This is a suggestion to change and or ammend the law as asked
by GOV.D.Malloy
12/9/2013 2:54:31
PM
AL
SEPTEMBER
TORRINGTON Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 3:07:19
PM
glynis
simmons
meriden Energy and
Environmental
Protection, Dept Of
carrying hand guns
in state forests
23-4-1c and 26-
66-2

to whom it may concern:


12/9/2013 3:19:55
PM
James Laviana Waterbury Governor's Office Carrying hand guns
in state forests
I think that law abiding citizens, with the proper permits, should
be allowed to carry hand guns in our state parks and forests.
12/9/2013 3:26:31
PM
Robert
Mattson
Environmental
Protection, Dept Of
Carry handguns in
State Forests
23-4-1(c) & 26-
662


12/9/2013 3:50:00
PM
chad mason Stafford Spg. Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 4:37:52
PM
Joseph
Phillips
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Forests.

CT Pistol Permit holders go through training, background checks
and pay a lot of money to obtain these permits. The CT
constitution recognizes the citizen's right to self defense. It
states, Every citizen has a right to bear arms in defense of
himself *or herself+ and the state (Art. I, 15).

Specifically:

12/9/2013 5:09:55
PM
Ralph T.
DeAngelo
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests

12/9/2013 5:11:11
PM
Rick Wiese Colchester Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
12/9/2013 5:21:49
PM
jeffrey beebe East Lyme Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 5:30:37
PM
Bill Hodge Jr Vernon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/9/2013 5:40:33
PM
Chris DeCarlo Wallingford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Thank you.
12/9/2013 6:03:11
PM
Jack Kuenzle Roxbury Energy and
Environmental
Protection, Dept Of
State Forests
23-4-1(c) and 26-
66-2


Citizens in the state of Connecticut have the right to carry
concealed firearms, and state parks and forests should be part of
the permitted regions to do so. It is in parks and forests that that
many citizens face threats of secluded areas and wild animals,
where the danger is high and the need to be able to carry a
firearm in equally so. Please reform the law to allow civilians to
properly and fully exercise their rights.
12/9/2013 7:13:45
PM
yolanda
verneris
hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 7:22:34
PM
Charles J.
Roberts
Oakdale Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/9/2013 8:00:30
PM
Nancy Devine Southbury Energy and
Environmental
Protection, Dept Of
Carrying Handguns
In State Forrests
23-4-1(c) and 26-
66-2

12/9/2013 8:06:21
PM
Christopher
Torino
Bristol Fish and
Game Association
West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in ST Frsts &Prks

12/9/2013 9:03:59
PM
Jonathan
Nadeau
plantsville Energy and
Environmental
Protection, Dept Of
carrying hanguns in
state forests
23-4-1 (c) & 26-
66-2

12/9/2013 9:26:18
PM
peter lewin salisbury Energy and
Environmental
Protection, Dept Of
carring handguns in
state forests a
handgun for self defense while in ct state forests and parks.
specifically;
-remove the prohibition on "the carry of firearms" in section 23-
4-1(c) of the connecticut agencies regulations.
-add an exemption to 26-66-2 to allow the carry of pistols and
revolvers (including handguns using center fire ammunition)for
12/9/2013 9:58:59
PM
West
Hubbard
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


Governor Malloy, if you really do support the 2nd Amendment
and our own state constitution, I ask you to push for these
changes and stand with law abiding gun owners.
12/10/2013
4:43:51 AM
Keith Tubman Westbrook Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/10/2013
8:22:31 AM
George
Chaber
Environmental
Protection, Dept Of
carry of pistols&
revolvers in park
23-4-1(c),22-66-2 Please modifythe state regulations to allow individuals with valid
permits to carry pistols and revolvers to carry handguns for self
defense while in Connecticut state parks and forests.
12/10/2013
9:38:52 AM
David A
Dojnia
Ansonia Energy and
Environmental
Protection, Dept Of
Carrying hand guns
in state forests
23-4-1(c) and 26-
66-2

12/10/2013
10:26:44 AM
Matthew G
Szydlo
Environmental
Protection, Dept Of
Carrying Handguns
in State Parks
23-4-1(c) and 26-
66-2



Thank you,
Matthew Szydlo,
Citizen, Eagle Scout, Small Business Owner
12/10/2013
10:49:50 AM
Stephen
Sutton
Environmental
Protection, Dept Of
handguns in State
Forests/Parks
23-4-1(c) and 26-
66-2
Regulations
12/10/2013
10:51:20 AM
Gregory Allen
Beck
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/10/2013
11:20:12 AM
MBR Mandate- A
need for change

December 10, 2013


The Minimum Budget Requirement (MBR) - a statutory mandate
that each town
appropriate at least the same amount for education as it did the
previous
year. The MBR, and its predecessor the Minimum Expenditure
Requirement
(MER), were originally intended to be companions to ECS that
would require
towns to spend at least the foundation amount for each student.
However,
with the foundation remaining virtually flat over the years,
minimum
spending evolved into a requirement for towns to commit all or
most new ECS
aid they receive to local education budgets. Eventually any
connection to
per pupil spending or the foundation ceased to exist.

After attending the first budget meeting in the town of Redding
last week, I
felt absolutely compelled to send you an email on the MBR as
noted above.
According to the Superintendent, the taxpayers of Redding may
have to
continue spending money on school personnel both certified
and non certified
because of this mandate unnecessarily. I am quite certain that
12/10/2013
10:39:14 AM
you are
aware of the decline in enrollment in a majority of the small
towns as is
the population moving into Connecticut. For example, five years
ago the
total number of students per grade at Redding Elementary
School were 168,
156, 147 and 134. The projected enrollment for 2014-15 is 68,
84, 93 and
80. Do these numbers suggest a decrease in staff from 5 years
ago. Of
course it does, but because of the MBR mandate the taxpayers
will NOT be
allowed to correlate the size of enrollment to the size of
teaching staff.
This is inexcusable. The taxpayers of Redding are already
suffering
financially from overly high taxes. As is many of the towns
around us who
are engaged in the same battle with declining enrollment.

I understand this mandate was put in place to make sure that
the quality of
education did not decline year after year, but now that we have
different
factors weighing heavily on the core of this mandate it is time
for a
change. At the very least, the smaller towns in CT should be
given a waiver
to allow them to pursue a budget that accurately reflects the
change in
enrollment while still maintaining the highest quality of
education. If
this leads to a negative budget at one or more schools than it
should be
allowed to proceed. If The Federal Government can allowed
waivers out of
NCLB by the states, than the municipalities of CT should be
allowed a waiver
out of MBR.

Declining enrollment is a serious issue in the coming years. The
new
projected enrollment figures from the professional consultants is
grim.
Small towns such as Redding simply cannot continue to sustain
the fiscal
responsibility in maintaining a budget with excess staff simply
because of a
piece of legislation put in place years ago that never took into
account the
variable of declining enrollment.

Staffing levels at each and every school in CT must be allowed to
match the
student population.

Please forward this email to the appropriate department in
charge of making
changes and or amendments to state legislation. This mandate
needs
immediate attention at all levels. We cannot continue to burden
the
taxpayers of CT with outdated legislation.

Thank you for your support in this matter.

Sincerely,

Dana A. Grey

<mailto:Greyda@optonline.net> Greyda@optonline.net

Cc: T. Boucher

J. Himes

--Boundary_(ID_VapKbOx7Uweop19zBBZxUQ)<
MBR (MINIMUM
BUDGET
REDUCTIONS)

format=flowed

Content-Disposition: inline

The Minimum Budget Requirement (MBR) =E2=80=93 a
statutory mandate that eac h=20
town appropriate at least the same amount for education as it
did the=20
previous year. The MBR, and its predecessor the Minimum
Expenditure=20
Requirement (MER), were originally intended to be companions
to ECS that=20
would require towns to spend at least the foundation amount
for each=20
student. However, with the foundation remaining virtually flat
over the=20
years, minimum spending evolved into a requirement for towns
to commit=20
all or most new ECS aid they receive to local education
budgets.=20
Eventually any connection to per pupil spending or the
foundation ceased=20
to exist.
I was prompted to write to you by an article I saw on a local blog
for=20
Redding, CT.=C2 I worry sometimes that Redding gets dismissed
because it =20
is perceived as a well-running, wealthy town.=C2 Nothing could
be furthe r=20
from the truth.
Many residents of Redding, CT feel undermined by its Board
of=20
Education.=C2 The combination of continuing job loss and poor
real estat e=20
sales has obviously also affected our school population. =C2
Where grade =20
sizes were once strong at 130 - 150 students, we have been told
that=20
12/8/2013 9:52:41
AM
current projections puts us around the 80 range for 2014 and
possibly=20
the 60 range in 2015.=C2 At a recent Board of Ed meeting,
our=20
superintendent conveniently forgot to bring the projections that
were=20
provided to him by the State of CT.=C2 When pressed as to how
he would =20
modify the budget to address the decrease in students, it
sounded as MBR=20
is being used as a veil to protect all of his employees.=C2
Redding Publ ic=20
Schools is the biggest business operation in our town.=C2 We
are=20
overstaffed, plain and simple.=C2 There just doesn't seem to be
any rega rd=20
as to how it affects the taxpayer.=C2 Furthermore, even with
this layer of=20
pork I'm not so sure there is evidence of Redding students
being=20
superior readers and experts in mathematics.
Long story short - PLEASE amend the MBR so that it makes sense
to make=20
substantial cuts when the student population is dramatically
decreased.=C2 =20
There just can't be a blanket rule when such severe changes
are=20
occurring at the town level.
I have cc'd Mr. Genovesi, State Senator Boucher's legislative
aide.=C2 I =20
will also forward this letter to Senator Boucher and
Congressman Jim=20
Himes via their website.
Thank you for the opportunity to express my concern.
Very truly yours,
RoseMarie Savino Gerschwer

--Boundary_(ID_v8fKIsr2R1o5LteD0Y/8Yg)<
Cutting Regulations

Governor Malloy,

How about we cut to the chase and cut the public service work
force and the
programs the work on by 25%. That would put it all back where
we were
several years ago.and we'll certainly all be able to survive
that......

Bob MacGuffie

203-727-7798

---
This email is free from viruses and malware because avast!
Antivirus protection is active.
http://www.avast.com

------=_NextPart_000_0162_01CEF464.CB801980<
12/8/2013
10:28:17 PM
John J
Canning
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Carrying handguns in State Forests and Parks. 12/10/2013
3:37:11 PM
John J
Canning
J Wallingford Energy and
Environmental
Protection, Dept Of
carrying handguns
in State Parks
23-4-1(c) and 26-
66-2


12/10/2013
3:44:11 PM
jeffery j forte thomaston Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2
please modify the states agencies regulations to allow
carry a handgun for self defense while in state parks and forests
specifically :remove the prohibition of carrying of firearms in
section 23-4-1(c) of the state agencies regulations
- add an exemption to 26-66-2 to allow the carrying of pistols
and revolvers (including pistols with center fire ammunition)for
12/10/2013
5:57:35 PM
Daniel Bassett Meriden Energy and
Environmental
Protection, Dept Of
carrying handguns
in state parks
23-4-1(c) and 26-
66-2


12/10/2013
6:29:19 PM
Mark
Trotochaud
Oakdale Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
8:47:24 AM
Robert
Kwasnicki
Enfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
10:18:36 AM
Jason
Jakubowski
Hospital for
Special Care
New Britain Public Health, Dept
Of
Medical Record
Retention
19-13-D5(d)(4) I believe that when the state medical record retention was
changed from 25 years to 10 years, section 19-13-D5 (Chronic
Disease Hospitals) was not included in this change. I believe this
was just a general oversight and should be brought into
alignment.

Hospital for Special Care is requesting a wording change so that
that Sec. 19-13-D5 coincides with the record retention
requirements in Sec. 19-13-D3 (acute care hospitals).

The change would shift record retention at chronic disease
hospitals from 25 years to 10 years, which is consistent with all
other hospitals in CT.

We believe this was merely a technical oversight, though a
rather burdensome and expensive one from our perspective.
12/11/2013
10:28:38 AM
Joseph Salemi Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Please modify the state regulations to allow licensed concealed
carriers to carry for self protection in State Parks and Forests.

Specifically:

12/11/2013
11:50:19 AM
Brian
Gauthier
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
12:02:48 PM
David Combs Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests

12/11/2013
12:14:38 PM
Jeff Yale Meriden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
for personal protection in state parks and state forests. Pistol
Permit holders go through training, background checks and pay
a lot of money to obtain these permits.


12/11/2013
12:29:26 PM
Brian Alter Chicopee,
MA
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
I am a MA resident who holds a CT pistol permit.


12/11/2013
12:30:02 PM
Jeremy
Hubbard
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
12:56:07 PM
Lee
Letourneau
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
1:28:03 PM
Zachery
Neville
Avon Energy and
Environmental
Protection, Dept Of
Carrying handguns
in state parks
23-4-1(c) and 26-
66-2


12/11/2013
1:40:05 PM
James Duffy Stratford Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/11/2013
2:07:50 PM
Jonathan
Varnet
Enfield Energy and
Environmental
Protection, Dept Of
Firearms in state
forests
Forests.
Specifically:
23-4-1(c) of the Connecticut Agencies Regulations-
12/11/2013
2:24:44 PM
Christina
Taylor
Meriden I don't know Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Considering the amount of homeless people that are adding up,
Id like the right to carry a firearm in state (and town) forests
whenever I can. I understand not all homeless people are
criminals but people can get desparate in times of great need.
Thank you for your time and consideration.
12/11/2013
2:54:46 PM
Christina
Taylor
Meriden I don't know Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
Considering the amount of homeless people that are adding up,
Id like the right to carry a firearm in state (and town) forests
whenever I can. I understand not all homeless people are
criminals but people can get desparate in times of great need.
Thank you for your time and consideration.
12/11/2013
2:54:47 PM
Rob LeMay Fairfield Emergency Services
and Public
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
3:09:09 PM
Richard D.
Kelley
CCDL Energy and
Environmental
Protection, Dept Of
Carring handguns in
state forest an
21-4-1 (c) and 26-
66-2
individuls with valid Permits to Carry Pistols and Revolvers, to
Forests.
SPECIFICALLY:- Remove the prohibition on the carring of
firearms in Section 23-4-1 (c) of the Connecticut Agencies
Regulations.
And an exemptionto 26-66-2 to aiiow the carring of pistols and
revolvers, (including handguns using center-fire ammunition for
the purposes of self defence.
12/11/2013
3:41:00 PM
Nicholas
Vissicchio
CCDL Derby Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
6:00:44 PM
Jeffrey Burns Charlestown,
Rhode Island
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/11/2013
8:23:48 PM
Sean Cassano columbia Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2
ammunition) for the purposes of self defense
12/11/2013
9:32:22 PM
Christine Ladd Education, Dept Of TeacherEvals Stop using student test scores to evaluate teachers. It is
unethical, invalid, and unreliable.
12/11/2013
9:40:14 PM
Bill williams Cheshire I don't know Carrying firearms in
state forests
23-4-1(c)

12/11/2013
10:16:18 PM
Nicholas
Astorino
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/12/2013
7:39:44 AM
Daniel
McGinn
Abington Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/12/2013
10:42:18 AM
Maurice
Remillard Jr
Danielson Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
11:03:32 AM
Cathy
Suchenski
Social Services, Dept
Of
Public Relations Dorothy L. moved to CT from RI during July. We immediately
applied for Title XIX, SNAP and the Medicare Savings Plans all of
which she had in RI. She says it took a matter of weeks to get
approved there. She has not heard anything on any of the 3
programs. Shes told medical providers that Title XIX is pending
but now she has a collection agency notice from Hunters
Ambulance. My call to the Call Center this morning confirmed
they have it in the system (including 5 years of back bank
records) but no action has been taken. I was told it would be
referred to the New Britain Regional Manager. I asked for a
name and a phone # there but was denied. My name and phone
# were taken hours ago but no call has been received. Isnt
there a 45 day limit to make a Title XIX decision? She hasnt
received any acknowledgement, not even a request for more
info.
12/12/2013
12:42:42 PM
Elizabeth
Drysdale
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
1:12:35 PM
Brian Snider Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
1:13:06 PM
Kit Drysdale Waterbury Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
1:14:51 PM
Patrick Crean Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
1:15:29 PM
Dave
Mastrianna
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
1:16:12 PM
Kevin
Deangelis
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
1:17:02 PM
Jim Burns Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
1:17:43 PM
Jon-Paul
Mucha
Coventry Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2


12/12/2013
2:00:30 PM
Floyd
Baranello
South
Windsor
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/12/2013
4:10:10 PM
Scott Rainey Plainfield Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/12/2013
4:16:29 PM
Michael
H.Kissel
windsor Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/12/2013
10:19:58 PM
Gina Arena I don't know Alcohol - legal
drinking age
I know the reason for the drinking age to be 21 is because of
federal funding, but I think it's ridiculous that young adults are
not allowed to legally drink until age 21. I am a high school
teacher and a parent of teens. Instead of preventing underage
drinking, the law causes teens and young adults to binge drink
before going out or getting drunk in basements, unsupervised.
When you, Governor Malloy, and I, were young adults, the
drinking age was 18, (in my case, changed to 19) and I think I
was a lot safer in a bar, pub or other public place where there
were adults around serving or bouncers. In public, we were
more likely not to get drunk and out of hand for fear of
embarassment and humiliation. Plus, the cost of drinking in a bar
also restricted the number of drinks we consumed. The other
result of the higher drinking age that I see is that teens and
young adults are turning to marijuana and synthetic drugs which
are easier to get than alcohol. I'm sure the number of deaths on
the road has decreased since the drinking age was raised, but I
also think it's because the state has improved on educating
young adults on the dangers of drinking and driving. Kids are still
drinking. Let's put it out in the open where we can monitor it.
12/13/2013
12:11:35 AM
David
Romajas
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/13/2013
4:18:58 AM
CT Assn. of
Health Care
Facilities
On behalf of
member facilities
East Hartford Public Health, Dept
Of
Public Health Code 19-13-D8t et seq. COMMENT ONE

Regulation:

19-13-D8t(c)

Relevant Agency:

Department of Public Health

Action Sought:

Grant the commissioner the power to deem any regulatory
requirement as no longer consistent with the current standards
of care and exempt facilities from further compliance without
the need for each individual facility to seek a waiver.

Reason:

Because standards of care change more frequently than
regulations, if the Department determines that a particular
requirement is no longer necessary, the process for exempting
compliance could be streamlined by granting the commissioner
the authority to automatically waive further compliance. As an
example of how the current system is highly inefficient, the
Department recently sent a blast fax to providers explaining that
an annual urinalysis required by 19-13-D8t(n)(8)(B)(ii) is no
longer consistent with current standards of care. Because the
regulation requires the urinalysis, however, providers must file
for a waiver of the requirement and include detailed information
as to why such a waiver is warranted. Moreover, the
Department must spend the time and effort to review the
requested waiver, ensure that all appropriate information and
respond to the provider.

COMMENT TWO

Regulation:

19-13-D8t(b)(2)(A)
12/13/2013
3:19:16 PM

Relevant Agency:


Action Sought:

Update statutory references by amending reference to
Connecticut General Statutes Sections 19-576 through 19-586 to
Sections 19a-491 et seq.

Reason:

Statutes currently referenced in regulations have been
transferred and/or repealed.

COMMENT THREE

Regulation:

19-13-D8t(d)(3)(A)

Relevant Agency:


Action Sought:

Amend the language regarding identification bracelets to be
consistent with federal regulations and requirements for rest
homes with nursing supervision and requiring instead A
method for identification of all patients at all times shall be
established by each chronic and convalescent home.

Reason:

In many facilities, identification bracelets are not safe or
appropriate for certain residents, e.g., dementia residents who
may find them agitating or who repeatedly remove them.
Requiring identification bracelets for all residents creates an
institutional feel contrary to the shift towards culture change.
Federal regulations do not impose a requirement for
identification bracelets and alternatives should be permitted to
be implemented so long as the facility develops a method of
identifying all patients.

COMMENT FOUR

Regulation:

19-13-D8t(f)(3)(I)

Relevant Agency:


Action Sought:

Amend language requiring submission within 72 hours of
reports on all accidents, or incidents, and any unusual or
suspicious deaths in connection with subsection (g) of these
regulations to state submission of reports on all reportable
events in accordance with subsection (g) of these regulations...

Reason:

The current language in the regulation is contrary to actual
reporting requirements set forth in subsection (g) and may result
in confusion. Not all incidents require a report within 72 hours.
Class E incidents are maintained by the facility and are not
submitted to the Department. Class A,B, and C incidents must
be immediately reported by telephone to the Department with a
written report within 72 hours. Amending the language to refer
to the specific requirements in subsection (g) eliminates any
potential for confusion.

COMMENT FIVE

Regulation:

19-13-D8t(g)(5)

Relevant Agency:


Action Sought:

Delete the requirement for review of all reportable events by
the administrator and director of nurses on a monthly basis.

Reason:

Review of reportable events is routinely performed by the QA
committee. The administrator and DNS already review and sign
all reportable events prior to submission. Requiring monthly
review by the Administrator and DNS is unnecessarily
burdensome.

COMMENT SIX

Regulation:

19-13-D8t(i)(1)

Relevant Agency:


Action Sought:

Reduce the number of physicians on the medical staff from
three to one in addition to the medical director.

Reason:

In many facilities, the medical director also serves as the
attending physician for many of the residents. As a result, it is
often difficult to have three physicians on the medical staff and
any such requirement is unnecessarily burdensome.

COMMENT SEVEN

Regulation:

19-13-D8t(i)(4)(A)

Relevant Agency:


Action Sought:

Revision Reduce the frequency with which the medical staff
must meet from at least once every 90 days to at least once
every 120 days.

Reason:

It is unnecessarily burdensome to require the medical staff to
meet with such frequency. Issues of patient care, medical
quality of care and interdisciplinary care issues can be effectively
addressed with meetings every 120 days.

COMMENT EIGHT

Regulation:

19-13-D8t(j)(4)

Relevant Agency:


Action Sought:

Revision An assistant director of nurses shall be appointed in
any facility of one hundred and fifty (150) beds or more.

Reason:

The current requirement that an assistant director of nurses
(ADNS) shall be appointed in facilities with 120 beds or more is
unnecessarily burdensome on nursing facilities. The primary
duties performed by ADNSs in facilities with a licensed capacity
of 120 to 149 beds are administrative in nature (e.g. staff
scheduling), which could be performed by other staff. The ADNS
is not counted as direct care staff (19-13-D8t(m)(8)), therefore,
the proposed revision will not impact the required number of
direct care staff and would save facilities from the expense of
having a full-time registered nurse on staff where clinical
involvement is limited. Patient care would not be impacted.
The current requirement imposes unnecessary expense on
facilities and should be revised.

COMMENT NINE

Regulation:

19-13-D8t(l)(1)(H)

Relevant Agency:


Action Sought:

Revision Require that a placement agency or nursing pool that
supplies a nurse aide to a facility verify nurse aide credentials
instead of the facility.

Reason:

Facilities pay a premium to use placement agencies or nursing
pools for staffing needs. The cost of using those organizations
necessarily includes the administrative burden of verifying
qualifications. As a result, it is unnecessarily burdensome to
require the facility to perform the verification.

COMMENT TEN

Regulation:

19-13-D8t(n)(1)

Relevant Agency:


Action Sought:

Revision allow for comprehensive medical history and medical
examination to be completed within 48 hours of admission,
excluding weekends and holidays.

Reason:

Requiring physicians to make visits to complete the medical
history and examination within 48 hours is unnecessarily
burdensome where those 48 hours fall over a weekend or
holiday. Excluding weekends and holidays provides flexibility
without jeopardizing quality care.

COMMENT ELEVEN

Regulation:

19-13-D8t(n)(4)

Relevant Agency:


Action Sought:

Revision Remove the specific list of tests and procedures that
must be performed within 30 days of the residents admission
and replace with: Test and procedures determined to be
necessary by the Department in conjunction with a work group
that includes long-term care providers shall be performed and
the results recorded in the patients medical record by the
facility within thirty (30) days after the patients admission. The
Department shall ensure that a listing of such tests and
procedures are revised no less frequently than every three
years.

Reason:

These regulations were created nearly twenty years ago and
have been amended or updated infrequently. Currently, this
specific section requires the performance of specific tests
without regard for whether requiring such tests is within the
standard of care. Changes in standards of care occur with far
more frequency than updates to regulations. As a result, it is
rarely advisable to have specific tests or other services dictated
by regulation because the regulation will quickly become
outdated.

In this instance, adherence to a specific list of tests either
subjects patients to unnecessary tests or omits others that may
be necessary. Instead of having a regulation that specifically
prescribes tests to be performed, the regulation should require
any tests within 30 days of admission that are deemed necessary
by the Department in consultation with long-term care
physicians. The regulation should require that such listing of test
be updated on a regular basis.

Regulations like this one, which quickly become outdated,
necessarily are ineffective and unduly burdensome. For
example, the Department recently sent a blast fax to providers
explaining that an annual urinalysis required by 19-13-
D8t(n)(8)(B)(ii) is no longer consistent with current standards of
care. Because the regulation requires the urinalysis, however,
providers must file for a waiver of the requirement and include
detailed information as to why such a waiver is warranted.
Moreover, the Department must spend the time and effort to
review the requested waiver, ensure that all appropriate
information and respond to the provider.

COMMENT TWELVE

Regulation:

19-13-D8t(n)(5)(A)

Relevant Agency:


Action Sought:

Revision Each patient in a chronic and convalescent nursing
home shall be examined by his/her personal physician at least
once every thirty (30) days for the first ninety (90) days following
admission and at least once every 60 days thereafter.

Reason:

According to the current regulation, if the physician believes that
the patients condition does not necessitate visits at 30 day
intervals after the first 90 days, visits can be every 60 days
provided that the physician provided justification for his/her
determination in the medical record. Such a requirement is
unnecessarily burdensome and inconsistent with the federal
standard. The proposed language reflects the federal standard.
The additional documentation requirement creates additional
and unnecessary requirements for physicians. If a physician
believes that more frequent visits are necessitated, he or she
will order such visits. Requiring the physician to document that
more frequent visits are not required is unnecessary.
COMMENT THIRTEEN

Regulation:

19-13-D8t(n)(8)

Relevant Agency:


Action Sought:

Revision Remove the specific list of services that must be
provided to patients and replace: The facility shall provide
professional services to each patient as determined to be
necessary by the Department in conjunction with a work group
that includes long-term care providers. A listing of those
services and the frequency with which they are to be performed
shall be revised no less frequently than every three years.

Reason:

These regulations were created nearly twenty years ago and
have been amended or updated infrequently. Currently, this
specific section requires the performance of specific professional
services without regard for whether providing such services is
within the standard of care. Changes in standards of care occur
with far more frequency than updates to regulations. As a
result, it is rarely advisable to have specific tests or other
services dictated by regulation because the regulation will
quickly become outdated.

In this instance, adherence to a specific list of professional
services that must be provided at specified frequencies has the
potential to subject patients to unnecessary tests or services.
Instead of having a regulation that specifically prescribes
professional services to be provided, the regulation should
require that necessary professional services be required as
determined by the Department in consultation with long-term
care physicians. The regulation should require that the list of
necessary professional services be updated on a regular basis.

Regulations like this one, which quickly become outdated,
necessarily are ineffective and unduly burdensome. For
example, the Department recently sent a blast fax to providers
explaining that an annual urinalysis required by 19-13-
D8t(n)(8)(B)(ii) is no longer consistent with current standards of
care. Because the regulation requires the urinalysis, however,
providers MUST file for a waiver of the requirement and include
detailed information as to why such a waiver is warranted.
Moreover, the Department must spend the time and effort to
review the requested waiver, ensure that all appropriate
information and respond to the provider. Even once the
Department has broader waiver authority, the fact that
providers must seek waivers for requirements that no longer
comport with standards of care is unduly burdensome on both
the provider and the Department.

COMMENT FOURTEEN

Regulation:

19-13-D8t(q)(3)(D) and (F)

Relevant Agency:


Action Sought:

Revision Change (D) from Serves at least three meals, or their
equivalent, daily at regular hours, with not more than a 14 hour
span between evening meal and breakfast to Serves at least
three meals, or their equivalent, daily at regular hours, with not
more than a 14 hour span between evening meal and breakfast
unless a nourishing snack is provided at bedtime, then up to 16
hours may elapse between a substantial evening meal and
breakfast the following day if a resident group agrees to this
meal span.

Revision Change (F) from Provides bedtime nourishments for
each patient, unless medically contraindicated and documented
in the patient's care plan to Offers bedtime nourishments to
each patient, unless medically contraindicated and documented
in the patient's care plan.

Reason:

Nursing homes have been instituting culture change initiatives
focusing on resident choice for meal times. Instituting such
culture change is contrary to strict dining time requirements.
Further, the change sought here, to permit 16 hours between
meals where a nourishing bedtime snack is offered, is consistent
with the federal requirements. The change clearly would not
adversely impact residents, as the federal government has
approved of the requirement, and would facilitate the culture
change by providing more flexibility.

Finally, changing the requirement that snacks are provided to
each resident as opposed to offered results in the unnecessary
waste of food. Again, federal rules require only that bedtime
snacks be offered. This change would not impact residents and
would serve to curb unnecessary expenses.

COMMENT FIFTEEN

Regulation:

19-13-D8t(r)(3) and (s)(5)

Relevant Agency:


Action Sought:

Revise the language to require that staffing hours or ratios for
the therapeutic recreation director and social work service staff
be determined by census at the facility as opposed to the
number of licensed beds.

Reason:

Few facilities have a census that parallels licensed capacity.
Therefore, requiring staff based on the licensed capacity as
opposed to actual census is ineffective and unnecessarily
burdensome. Nurse staffing is determined by the facilitys
actual census, not the number of licensed beds. See 19-13-
D8t(m)(5) and (6). As with nurse staffing requirements,
therapeutic recreation director and social work service staff
requirements that are based on census will not endanger the
life, safety or health of any patient and should be the regulatory
standard.

COMMENT SIXTEEN

Regulation:

19-13-D8t(s)(8) and (9)

Relevant Agency:


Action Sought:

Revision Remove from social workers the responsibility to
conduct annual inservice training on personal and property
rights and on an area specific to the needs of the resident
population. The facility would remain responsible for
performing the training.

Reason:

The inservice training need not be provided by a social worker to
be effective and requiring the social work to perform the
training unnecessary interferes with the more relevant social
work duties. Other facility staff members could perform the
inservice training.

COMMENT SEVENTEEN

Regulation:

19-13-D8t(v)(7)(E)

Relevant Agency:


Action Sought:

Revision Require that the equipment be offered but do not
require that it be provided if a patient does not want the
equipment in his or her room.

Reason:

The current regulation requires that the facility provide a list of
items in all patient rooms including a mirror, bedside table,
armchair etc. As currently written, the facility must provide the
equipment listed and cannot remove the equipment if the
patient rejects it. Such a requirement is not only ineffective but
also impinges on the patients ability to choose the equipment
he or she wants in the room.

COMMENT EIGHTEEN

Regulation:

19-13-D8t(v)(8)(C)

Relevant Agency:


Action Sought:

Remove the requirement that there be a bathtub on each
nursing unit or in the alternative, reduce the requirement from 1
tub per unit to 1 tub per facility.

Reason:

Most nursing home residents do not take baths; they prefer
showers. Therefore, requiring a tub on each unit is ineffective
and unnecessarily burdensome.

COMMENT NINETEEN

Regulation:

19-13-D8t(v)(9)(iv)

Relevant Agency:


Action Sought:

Remove the requirement that each facility have a bedpan
washing and flushing device.

Reason:

Facilities no longer use metal bedpans that require a bedpan
flushing and washing device. As a result of this regulation,
maintenance staff must flush the required device monthly
because it is unused. Requiring these devices is inefficient and
unnecessarily burdensome.

COMMENT TWENTY

Regulation:

19-13-D8t(v)(10)(A)(1)

Relevant Agency:


Action Sought:

Remove the requirement that each facility have an examination
room.

Reason:

Most physicians examine residents at the residents bedside.
Therefore, the requirement that there be a dedicated exam
room space is excessive and unnecessarily burdensome.
COMMENT TWENTY-ONE

Regulation:

19-13-D8t(v)(20)(A)

Relevant Agency:


Action Sought:

Change the requirement for stretchers to one per floor.

Reason:

Currently, the regulation requires that the facility have one
stretcher per nursing unit. This requirement is excessive and as
a result is unnecessarily burdensome.

COMMENT TWENTY-TWO

Regulation:

19-13-D8t(v)(20)(I)

Relevant Agency:


Action Sought:

Remove the requirement that each facility have one autoclave.

Reason:

Facilities have no need for an autoclave. Such a need may have
existed in the past but it no longer exists. Requiring such costly
equipment is unnecessary.
CT Assn. of
Health Care
Facilities
On behalf of
member facilities
East Hartford Social Services, Dept
Of
Waiting List
Regulations
17-311-200 et
seq.
General Comment: The provisions in the Waiting List
regulations, enacted in 1988 (except for 17-311-209 which was
enacted in 1990) and never updated, are antiquated and impose
unreasonable administrative burdens on facilities without any
added benefits. The most overbearing and unnecessary
requirement are addressed below.

Regulation:

17-311-200(b) and (c)

Relevant Agency:

Department of Social Services

Action Sought:

(1) Remove or general assistance benefits from a town from
(b).

(2) Revise the definition of applicant for admission in (c) as
follows: applicant for admission means any person who either
himself or through a representative, including but not limited to
his guardian, conservator, family member or physician, indicates
a desire to the nursing home to be admitted into such nursing
home. A general inquiry from a hospital does not create an
applicant for admission under this section.

Such indication of desire for admission to the nursing home may
be communicated to the facility by a person or his
representative in person, by mail, by telephone or by electronic
mail to the individual or address specified by the facility for
indicating a desire for admission. Nursing homes may not restrict
applicant for admission status to those persons who have
personally visited the facility, completed and signed application
forms, submitted medical, social or financial information, or in
any other way not expressly permitted by this section.

Reason:

12/13/2013
3:23:58 PM
(1) P.A. 04-76 removed this language from the statute in 2004.
See Conn. Gen. Stat. 19a-533.

(2) In the 25 years since this regulation took effect, technology
has changed dramatically. Hospital discharge planners now use
systems such as eDischarge, an automated fax notification
system. This system allows discharge planners to seek
admission for patients to a large number of nursing homes at
one time and has greatly increased the number of inquiries
which a nursing home receives. Most of these patients never
specifically expressed an interest in the facility. Because the
regulation is unclear as to whether these general inquiries fall
within this regulations, many facilities have been including them
and are overcome with the administrative burden complying
with the related requirements. In fact, one administrator
reported that his facility sent out 1,154 receipts in the first six
months of 2013 as a direct result of these general inquiries. This
is time consuming and expensive. These names of these persons
are then also added to the dated list of applications. Not only is
management of these requirements unnecessarily burdensome
on facilities, they also no longer serve the intended purpose and
are totally ineffective with respect to general inquiries made by
hospitals.

Furthermore, the current definition does not acknowledge the
use of electronic mail. The revision provides for the use of
electronic mail to indicate a desire provided that it is sent to the
individual or address designated by the facility for handling
indications of desire for admission.

Regulation:

17-311-204

Relevant Agency:


Action Sought:

Revise the language to remove the requirement that the dated
list of applications be maintained in a bound volume and replace
with Such dated list of applications shall be maintained either in
a bound volume or an electronically generated list that ensures
the integrity of the data entered. The list must be in the
chronological order in which the persons contacted the facility
and indicated a desire to be admitted with the date and time of
initial contact indicated by the persons name.

Reason:

In 1988, when this regulation took effect, adequate electronic
means were not readily available to facilities for maintaining a
list. Twenty-five years later, requiring a bound volume is
outdated, unnecessarily burdensome, and ineffective. As with
the advent of electronic medical records, it is possible and, in
fact, preferable to maintain such records electronically not only
to reduce document storage needs but also to add a level of
security. The ability to track changes made to electronic files far
surpasses the ability to track hand-written changes to a bound
volume.

Regulation:

17-311-205

Relevant Agency:


Action Sought:

(1) Revise the language in (a) as follows: Add electronic mail and
facsimile as acceptable methods of sending a written application
form.

(2) Add the following language to the end of (b): An application
that does not include requested financial information shall not
be considered substantially complete.

Reason:

(1) The additions of electronic mail and facsimile are required to
update this regulation to acknowledge advances in technology.

(2) The addition of this language provides the necessary
clarification for facilities that applications without requested
financial information do not entitle one to occupy a space on the
waiting list. Establishment of a payor source and the ability to
meet Medicaid requirements now or in the future are critical
components of the application. This is consistent with 17-311-
209(b)(1).

Regulation:

17-311-206

Relevant Agency:


Action Sought:

Revise the language in (a) to remove the requirement that the
waiting list be maintained in a bound volume and replace with
which shall be maintained either in a bound volume or an
electronically generated list that ensures the integrity of the
data entered. The waiting list must contain the names of
persons who have substantially completed and returned to the
facility the written application form.

Reason:

In 1988, when this regulation took effect, adequate electronic
means were not readily available to facilities for maintaining a
list. Twenty-five years later, requiring a bound volume is the
epitome of outdated, unnecessarily burdensome, and
ineffective. As with the advent of electronic medical records, it
is possible and, in fact, preferable to maintain such records
electronically not only to reduce document storage needs but
also to add a level of security. The ability to track changes made
to electronic files far surpasses the ability to track hand-written
changes to a bound volume.

Regulation:

17-311-207

Relevant Agency:


Action Sought:

(1) Repeal this section.

(2) In the alternative, revise the language to remove the
requirement that the daily log be maintained in a bound volume
and replace with which shall be maintained either in a bound
volume or in an electronic record that automatically records the
date, time and author and does not permit any data to be
overwritten or changed without maintaining a record of the
originally entered data. The daily log must be completed.

Reason:

(1) P.A. 93-381 removed the daily log requirement from the
statute in 1993 and therefore, there is no longer a need for it in
the regulation. See 19a-533.

(2) Electronic records are becoming the norm. Requiring the
maintenance of bound volumes is consistent with the standard
25 years ago. Medical records are now successfully maintained
electronically as well as many other types of records and
facilities should be permitted to maintain all of its required
documentation electronically. Current technology allows for the
integrity of the data to be maintained through automatic date,
time and author stamps and by not allowing permanent
deletions.

Regulation:

17-311-209

Relevant Agency:


Action Sought:

Add: (21) Regardless of the ratio of payer mix, if at the time of
vacancy a nursing home has residents who have been Medicaid
pending for longer than 90 days or are in a Medicaid penalty
period and the facility is receiving no payment for care for those
residents, then the nursing home may admit the next self-pay
person on the waiting list.

Reason:

Nursing homes are must continue to provide care for patients
with Medicaid applications pending and for those with imposed
penalty periods without being paid for that care. While the cost
of that care may be reimbursed if a pending application is
granted without a penalty period, many times a penalty period is
imposed or the delay in granting the application is so extensive
as to create a financial hardship for the facility. The difference in
payment rates between self-pay and those individuals receiving
assistance will help to carry the overwhelming burden it has as a
result of penalty periods and delayed Medicaid applications.
CT Assn. of
Health Care
Facilities
On behalf of
member facilities
Of
Patient Personal
Allowance
17-2-140 et seq. COMMENT ONE

Regulation:

17-2-140 through 17-2-145

Relevant Agency:


Action Sought:

Update all dollar amounts referenced herein to reflect
appropriate increases since time regulations were implemented.

Reason:

These regulations have not been updated with respect to dollar
amounts for PPA, allowable gifts, burial accounts etc. since 1978
and are no longer accurate or reasonable given the passage of
time.

COMMENT TWO

Regulation:

17-2-143(C)(10)(i)

Relevant Agency:


Action Sought:

Increase the value of a gift that a resident may use his or her
personal needs allowance to give or purchase from $25 to an
amount not to exceed the value of the monthly personal needs
allowance.

Reason:
12/13/2013
3:28:47 PM

This regulation took effect in 1978 and has not been amended.
According to the regulation, the amount of the personal needs
allowance at that time was $25 per month. Clearly, the
intention of the regulation was to limit gifts to the amount paid
to the resident monthly as a personal needs allowance. The
proposed change eliminates the need for future changes due to
increases in the personal needs allowance.
CT Assn. of
Health Care
Facilities
On behalf of
member facilities
Of
Reimbursement
Regulations -
Updates
17-311-1 et seq. General Comment: the following regulations refer to
transferred, repealed or obsolete statutes or use language which
has changed.

Regulations:

17-311-12 (refers to C.G.S. section 17-311)
17-311-38 (refers to C.G.S. section 17-2)
17-311-47 and 50 (refer to 17-311 (c)).
17-311-52 and 54 (refer to homes for the aged, now
residential care homes)
17-311-60a refers to (C.G.S. 17-314(b), etc.17-2-143(C)(10)(i))
17-311-209 (refers to The Commission on Hospitals and Health
Care)

Relevant Agency:


Action Sought:

Update.

Reason:

Update to comport with statutory changes.
12/13/2013
3:32:52 PM
James
Ferravante
Newtown Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/13/2013
5:45:42 PM
Michael
Kluczinsky
Oakville Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forest
23-4-1(c) & 26-66-
2
handgun for self defense while in CT state forest and parks
specifically:-remove the prohibition on the 'carrying of firearms'
insection 23-4-1(c) of the Connecticut agencies regulations -Add
exemtion to 26-66-2 to allow the carrying of pistols and
the purpose of selfdefenens.
12/14/2013
12:02:13 AM
Gloria
Sadlowski
Rockfall-
Middlefield
Public Health, Dept
Of
hospital medical
records
Section 19-13-D
3(d) (6)
This regulation could perhaps be modified so essential medical
records are kept. For my situation this regulation has been
unnecessarily burdensome. This is briefly described. My
insurance hospital records for physical injuries from years ago do
not exist because of this regulation. I wanted to have a full-time
job starting in 2003 and work for about ten years for retirement
savings. Instead I was not hired for the jobs I applied for. An
employer since 2003 required the records (they are also
required for Department of Labor employment assistance and
unemployment benefits). I did contact the Department of Social
Services in 2003. I could not afford to replace the records myself.
I did not know all my medical problems. I spent several years
trying to learn a skill I eventually realized I could not do. I could
not pay the town taxes, then a foreclosure started late 2008 and
my house was sold. I continued the cases pro se with little
money available and am still in the courts trying to get my house
back. I had to apply for Social Security which did not seem right
for my missing old insurance medical records problem.
Supplemental Security Income was approved after more than 3
1/2 years. I thought I would start to recover and be able to
finally start to pay the taxes and do home repairs, but soon an
eviction happened instead. I wish there was a better way to
rebuild missing records and described with my court papers the
possibility of a program for this. With the Disability Act better
methods should perhaps also be used.
This regulation took the medical records I need and then
employment assistance, jobs, savings, earnings, access to my
house and possessions, and maybe my house; and also
contributed to many horrible problems.
12/14/2013
10:01:55 AM
John Streiber Ellington Energy and
Environmental
Protection, Dept Of
carrying handguns
in state forests
23-4-1(c) and 26-
66-2
Forests.

Specifically:

12/14/2013
12:44:53 PM
John Harding Cornwall
bridge
Treasurer, Office Of
The State
Taxes and budget Do not increase taxes. Stop entitlement programs and spending
. The state of ct and it's tax structure is the highest in all the
states.
You are ruining our state by overspending and bankrupting us.
Stop spending money we do not have and do not raise taxes.
John and Catharine Harding
Cornwall bridge, CT
12/15/2013
8:57:51 AM
David Zita Old Lyme Energy and
Environmental
Protection, Dept Of
fishing tournaments 26-159a-26 Please repeal this regulation in its entirety. It serves no useful
purpose in the real world. Here's what it does. If I get together
with several friends and decide have a friendly competition with
prizes to the victors, we become outlaws for not following these
rules. There is no conservation purpose served whatsoever. I
follow all regulations concerning seasons, sizes, and bag limits
without complaint because doing so serves the goal of
conservation and wise use of resources. This regulation,
however well intended, does not and is just plain nuts. Please
understand that I worked for DMHAS for 25 years and I have a
sophisticated appreciation for the importance of regulations.
This regulation is nothing but a nuisance. I guess I just want
DEEP off my boat. Please repeal 26-159a-26. Thanks for hearing
my gripe.
12/15/2013
10:02:04 AM
Evangelo
Sfakios
North
Windham
Energy and
Environmental
Protection, Dept Of
carry handguns in
State Forests/par
23-4-1(c) and 26-
66-2

12/15/2013
11:28:01 AM
Robert
Rainville
Griswold, CT Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/15/2013
12:21:26 PM
Thomas R
Burkholder
Bristol Administrative
Services, Dept Of
Multi-year contract
prohibition
In the past several years, we have been told by the "auditors"
that we could not enter into a multi-year contract for
maintenance or services for instrumentation, equipment, etc.
even though most vendors offer significant discounts for multi-
year contracts. These contracts have been renewed annually for
years and non-renewal would lead to failure of these
instruments and equipment. If this is a regulation, it's not clear
how you would even begin to find it in the database.
12/15/2013
12:49:19 PM
Mary Uriano Manchester I don't know family caregiver
compensation
The fact that CT does not compensate family caregivers is very
burdensome to the person that requires care & their family. The
referrals to outside care is more frustrating than helpful, to all
involved. The person requiring care should have a choice. Thank
You
12/15/2013
12:56:56 PM
mark
moorman
Judicial Review
Council
DOL- AGENT for
Federal TRA
Please forward my request to have issues with the DOL-TRA
unemployment/ TRA/TRA reviewed and a forum to discuss the
broad impact of the duties of the State as the * Agent of the
Federal Government for the state of ct TRA program.

Please respond via e- mail when and where these topic can bee
discussed!

Mark Moorman
203-263-3198
12/15/2013
5:05:49 PM
Martha F.
Neal
Board of Finance,
Colebrook, CT
Colebrook Labor Dept Prevailing Wage I am writing to urge you to review the regulations pertaining to
Prevailing Wage.

The ceiling of $100,000.00 for maintenance contracts has been
in effect since 1991. The cost of materials has risen significantly
since 1991 and municipalities and taxpayers are paying one-third
more than necessary because of the Prevailing Wage ceiling. I
would urge you to raise this ceiling to $500,000.00. At a time
when taxpayers and municipalities are struggling to resurface
roads, paint town buildings and take care of significant assets, it
seems unfair that they should have to pay so much more
because of outdated regulations.

Additionally the ceiling for new building should be raised to
$5,000,000.00. Once again the current ceiling has not been
raised since 1991. It is unrealistic to expect municipalities to
work with a regulation which does not allow new construction
without the burden of additional and unnecessary costs.

Small towns without huge commercial income suffer hugely
from the current prevailing wage regulation. These towns could
receive much more in the way of services if the ceilings were
raised to realistic levels. In addition, the current regulations put
additional financial burdens on small businesses that deal with
municipal contracts.

The current Prevailing Wage Regulation is outdated and
unrealistic, it needs to be addressed.

Martha F. Neal
12/15/2013
5:36:30 PM
JOHN GOULD NORWICH Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/15/2013
8:00:58 PM
government
regulations

Dear Sirs:

Attached are my comments regarding burdensome government
regulations/statutes. I thank you for the opportunity to express
my views and concerns. I have also included a prominent
attorney's remarks regarding a recent US Supreme Court case
that concerns the issues that I raise.

Sincerely,

Charles Rinaldi
Enfield
------=_Part_4868571_349786538.1386868497729<
12/12/2013
12:14:57 PM
Executive Order No.
37 - regulatory
review

December 12, 2013

Via email -
governor.regulations@ct.gov<mailto:governor.regulations@ct.g
ov >; Commissioner Rubenstein, Department of Consumer
Protection

Dear Sir/Madame,

In response to Governor Daniel Malloy's October 16, 2013,
Executive Order No. 37 that invites public comment on
ineffective regulations over four ye ars old, we submit
(ATTACHED) our suggestions with respect to such regulat ions
pertaining to alcohol beverages under the jurisdiction of the
Departm ent of Consumer Protection ("Department").

Respectfully,

Dwayne A. Kratt

Dwayne A. Kratt
Sr. Director, Government Relations, NE
Diageo
801 Main Avenue
Norwalk, CT 06851
O - 203-229-4504
M - 203-286-9044

_____________________________________________________
_
12/12/2013
9:54:56 AM

This email is sent on behalf of a member of the Diageo group of
companies, whose holding company is Diageo plc, registered in
England and Wales with number 23307 and with registered
address at Lakeside Drive, Park Royal, L ondon NW10 7HQ,
England.

This email and any files transmitted with it are confidential and
intended solely for the use of the individual or entity to which
they are addresse d.=20

This footnote also confirms that this email has been scanned for
all virus es by the Messagelabs SkyScan service.

If you have received this email in error please notify the Diageo
Serviced esk on +44 (0) 131 319 6000

http://www.diageo.com
=20
___________________________________
--
_000_1BED6AAE811AF343BA756586A28497DA02489C63A5DCA
VMSG005Agu_<
Executive Order No.
37 - Request to
Amend the
Regulations of
[Comment Emailed with an attachment: "Letter -Request to
Amend.pdf"]

In accordance with Executive Order No. 37, please find attached
our Request to Amend the Regulations of the Connecticut
Department of Motor Vehicles. Please contact me if you should
have any questions.

Thank you for your anticipated assistance.

Sincerely,

John A. Acampora, Esq.
Cohen and Acampora
8 Frontage Road
East Haven, CT 06512
O: 203-467-7337
F: 203-468-7865

The information contained in this e-mail and any files
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not necessarily reflect the l evel of factual or legal inquiry or
analysis which would be applied in the case of a formal legal
opinion. No legal opinion is expressed herein. Cohen and
Acampora, Attorneys at Law, assume no responsibility for any
loss or d amage arising in any way from your use of this email
transmission, includin g, without limitation, in connection with
any virus or other defect that mi ght affect any computer system
12/10/2013
5:28:57 PM
into which this email is received and opened . It is the
responsibility of the recipient to ensure that it is virus free .
Thank you.
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--
_000_BA268321D595B946933BF54932DA1F5714DD2539CA000
2CA1local_<
Comments re
Section 19-13-D5 of
CT State Regulations
Delivery Status
12/13/2013
6:21:15 PM
Comments re
Section 19-13-D5 of
CT State Regulations
12/13/2013
6:21:15 PM
Burdensome state
regulations

I am an APRN and business owner of a small medical practice.
The state of C T has restricted the scope of practice of nurse
practitioners by mandating a collaborative agreement with a
physician. This collaborative agreement res tricts our ability to
practice to our full potential and restricts access to quality of
care for many CT residents.

This very outdated law needs to change, especially now with the
physician sh ortage and the changes in all residents obtaining
health insurance. Current ly, there are not enough primary care
providers to care for the huge influx o f newly insured residents.
I have been looking to add nurse practitioners t o my business to
enhance access to care and so far they have not been able t o
join me because they have not been able to secure a
collaborative agreemen t from a physician.

This problem is huge! I could give you much more information
but would pref er discussing this with you further via phone
conversation or in person. Sh ould you require more
information please do not hesitate to contact me at 86 0-729-
4514.

Thank you,
Shery Marinone, APRN

Sent from my iPad
</
12/15/2013
8:38:20 PM
Regulations -
Section 15-140f-1
and Section 15-140j-
2

Dear Governor Malloy

I am writing to comment on the updating of state regulations
Section
15-140f-1 and Section 15-140j-2. If these regulations were to
change to
allow online education, for knowledge based information that is
incorporated in the basic boating safety course that leads to
certification, it would have a very positive outcome. Having the
ability
to take online courses opens up the ability for many more
residents to
advantage of that type of learning experience as it will be used
for new
boaters but also refreshers for those of us who have been
boating for years .
On line classes afford State residents to take the class when it is
best
for them.

The move to online education will free current D.E.E.P. staff
allowing
them to expand their on water skills concept to more boaters.
The on water
boating education, which is being promoted by the USCG, will
help to create
a safer boating experience on Connecticut waters.

Small changes can make big difference, from saving funds to
saving lives;
these changes warrant your consideration.

Sincerely,

Dean Rustic
12/15/2013
7:26:04 PM

Conservation Director

CT B.A.S.S. Nation

209 Deer Run

Burlington, CT 06013

(860) 916-1957

--001a11c2dd7e78d21a04ed9bdba9<
Online Boating
education
[Comment Emailed with an attachment: "Dear Governor
Malloy.doc"]

Ronald J. Frisk
Director Of Telecommunications

225 North Main Street
Bristol, CT 06010
Phone/Fax: 860.584.4411
Mobile: 860.940.5553
http://www.accare.com<http://www.accare.com/>

[ACC 25 Years]
Confidentiality Statement
The information transmitted is intended only for the person or
entity to wh ich it is addressed and may contain confidential
and/or privileged material . Any review, retransmission,
dissemination or other use of, or taking of a ny action in reliance
upon, this information by persons or entities other t han the
intended recipient is prohibited. If you received this in error, pl
ease contact the sender and delete the material from any
computer.

--
_000_8211C8B8F704154597A56038CA7DC4560F21851Amxgmai
l03accloc_<
12/16/2013
1:24:50 PM
Response to the
Governor's
Executive Order No.
37 - CHA
[Comment Emailed with an attachment: "Regulation Review
2013 to Malloy.pdf"]

The Connecticut Hospital Association (CHA) respectfully submits
the followi ng letter for consideration in response to the
Governor's Executive Order N o. 37.

If you have any questions, please contact me.

Thank you,

James Iacobellis

James Iacobellis
Senior Vice President, Government and Regulatory Affairs
Connecticut Hospital Association
(203) 294-7310
Iacobellis@chime.org<mailto:Iacobellis@chime.org>

--
_000_0D1750754D46DF4D89B756203ADCEE783956EEExchange
1cthosplo_<
12/13/2013
8:10:20 PM
Regulations -
Section 15-140f-1
2


Section
change to
allow online education for knowledge based information that is
incorporated
in the basic boating safety course that leads to certification.
Having
the ability to take online courses opens up the ability for many
more
residents to advantage of that type of learning experience as it
will be
used for new boaters and also refreshers for those of us who
have been
boating for years. On line classes afford State residents to take
the
class when it is best for them.

allowing
The on water
boating education, which is being promoted by the USCG, will
help to create
a safer boating experience on Connecticut waters.

saving lives;
these changes warrant your consideration.

Sincerely,

Dean Rustic
12/15/2013
7:21:37 PM

Conservation Director

CT B.A.S.S. Nation

209 Deer Run


(860) 916-1957

--001a11c1e98086ecfd04ed9bcb4b<
Public funding for
daycare and
education for
teachers

Governor Malloy,

While I appreciate what the state is trying to do regarding early
childhood e ducation I'm disappointed that there are not
programs in place to pay for th e education of the workers.
Because of our combined income my wife does not q ualify for
grants. We cannot afford to send her to school and she will lose
h er job once everything is in effect.

You're answer to it is that it only applies to those seeking state
funded ch ildren. Unfortunately that means almost all day care
facilities. I would lik e to see some funding be made available to
current workers that will be unem ployed once the law takes full
effect with reasonable income requirements.
</
12/15/2013
12:16:28 PM
obsolete regulations

Thank you for the opportunity to comment. See attached.

--
Director of Health
Town of Wallingford
203-294-2065
wlfdhealth@sbcglobal.net

--------------070500050604000703070900<
12/13/2013
3:42:44 PM
Online Boating
Course

Please see the attached letter on this topic.=C2 Thank you for
taking th is into consideration.
------=_Part_115121_1152422083.1387171066211<
12/16/2013
5:17:46 AM
Regulations

Since Senator Chapin sent a mailer recently with a paragraph
about eliminating regulations that are unnecessary,
burdensome and ineffective, and is more than 4 years old, I can
think of one that fits most of the qualifications but may be a
federal regulation. Why not eliminate it in our state at least. It
is the one that requires everyone boarding an airplane to
remove his or her shoes because a terrorist once had an
explosive in his and was discovered before it did any damage.
Terrorists do not use any old plans that were unsuccessful! And
pat downs should go, too! Thank you. Merry Christmas and
Happy New Year! Audrey Battista
------=_NextPart_000_001C_01CEF7EE.46605AC0<
12/13/2013
10:29:59 AM
Record Retention &
Record Completion
Alignment FW:
Record Retention &
Record Completion
Alignment
[Comment Emailed with an attachment: "State of CT Public
Health Code 19-13-D.pdf"]

Please see attached and below... Hospital for Special Care is
requesting th is minor change in DPH regulations as a part of the
Governor's review proce ss. We believe this was a technical
oversight that was simply missed when D PH changed the record
retention period for acute care hospitals. The additi onal 15 year
retention period that only applies to chronic disease hospital s is
both costly and burdensome. Please feel free to contact us with
any qu estions.

Jason Jakubowski
Vice President for Government Relations
Hospital for Special Care
2150 Corbin Avenue
New Britain, CT 06053
(860) 827-4858
www.hfsc.org<http://www.hfsc.org>

From: Deborah Lobb
To: Jason Jakubowski
Cc: Laurie Whelan; Deborah Lobb
Subject: Record Retention & Record Completion Alignment

I believe that when the state medical record retention was
changed from 25 years to 10 years, section 19-13-D5, Chronic
Disease Hospital was not inclu ded in this change. I believe this
was just a general oversight and should be brought into
alignment.

I am respectfully requesting changing of legislative wording so
that Sec. 1 9-13-D5 coincides with record retention and
completion requirements with Se c. 19-13-D3 (acute care).

1. Change from 25 years retention to 10 years retention

2. Change from 14 days to 30 days completion ( consistent
12/11/2013
3:35:27 PM
with Acute Care, Joint Commission requirements)

Long-term Hospital: Chronic Disease Hospital: Sec 19-13-D5;
page 38 (d) Medical Records (4) Medical records shall be
filed in an accessible manner in the hospital and shall be kept
for a minimum of twenty-five year s after discharge of patients,
except that the original medical records may be destroyed
sooner if they are microfilmed by a process approved by the s
tate department of health. (5) Medical records shall be
completed within fo urteen days after discharge of the patient
except in unusual circumstances which shall be specified in the
medical staff rules and regulations. Persis tent failure by a
physician to maintain proper records of his patients, pr omptly
prepared and completed, shall constitute grounds for
suspending or w ithdrawing his medical staff privileges.

Acute Care wording: Sec. 19-13-D 3; page 10 (d)Medical
Records (6) Medical records shall be filed in an accessible
manner and shall be k ept for a minimum of ten years after
discharge of patients, except that the original medical records
may be destroyed sooner if they are preserved by a process
consistent with current hospital industry standards. The hospital
shall provide the Department of Public Health with a list of the
process o r processes it uses. (7). Medical records shall be
completed within thirty days after discharge of the patient
except in unusual circumstances which s hall be specified in the
medical staff rules and regulations. One of these specified
circumstances shall be that the hospital discharge summary shall
be completed and shall accompany patients at the time of
discharge to anoth er health care facility. Persistent failure by a
physician to maintain prop er records of his patients, promptly
prepared and completed, shall constitu te grounds for
disciplinary action with respect to medical staff privileges .

Chronic & Convalescent Nursing Homes and rest homes with
nursing supervisio n; Sec 19-13-D8t; page 78 (o) Medical
Records (5) A ll medical records, originals or copies, shall
be preserved for at least te n (10) years following death or
discharge of the patient.

Deborah B. Lobb, RHIA, CHP, CHC, CTR
Director, Corporate HIM & Privacy Officer
Hospital for Special Care
2150 Corbin Avenue
New Britain, CT 06053

Direct: (860) 827-4822
Fax: (860) 827-4837
Email: dlobb@hfsc.org<mailto:dlobb@hfsc.org>

This message originates from an operating entity of Center of
Special Care, Inc. The information contained in this message
may be privileged and confi dential. If you are the intended
recipient you must maintain this message i n a secure and
confidential manner. If you are not the intended recipient,
please notify the sender immediately and destroy this message.
Thank you.

--
_000_5A118B84A95C4B4398F862C5950BEDDC4BC60400HSCEX
CHNG01cscl_<
comments
regarding state
regulations

Thank you for this opportunity.

Most of my experience with state agencies is with the
Department of Public Health, primarily HIV/AIDS and Chronic
Disease and Tobacco Cessation progra ms.

Regulations/contract language being interpreted differently
between depar tments

Definitions of budget expenditures are different between
departments

How budgets are calculated -for example, while the cost
standards allow for direct, allocable as direct, and indirect
(administrative and general e xpenses), I have never had any
state employee allow for allocable as direc t. It is either direct or
indirect. In 2007-2008 I spent many days of my time learning
the cost standards and budgeting accordingly only to be told
that the department didn't do it that way.

Inconsistent definition of the limitation of A and G expenses in a
budget: sometimes it is 15% of the total direct expenses,
sometimes it is 15% of the total grant. A grant RFP has one
definition but the department uses an other.

Audits of expenditure reports occurring months, and often
times years AFTE R expenditures have been made. This does not
allow for any opportunity to take any corrective action. One
such audit resulted in our agency expendin g an entire grant of
$94,000, only to be told that we needed to return $17, 000, or
almost 20% of the total grant. This is a significant loss.

Required to complete many types of financial reports, with
redundancy: re port salary and fringe benefits by each
employee rather than having the sal ary and fringe line item
12/13/2013
3:34:22 PM
summaries being enough.

Again, thank you for this opportunity. Please feel free to be in
touch wi th any questions.
=09

Linda Estabrook, MPH
Executive Director
Hartford Gay & Lesbian Health Collective
P.O. Box 2094
Hartford, CT 06145-2094
Phone: 860-278-4163 Ext. 14
Fax: 860-278-5995
Email: lindae@hglhc.org
Web: http://www.hglhc.org

Follow HGLHC on Facebook and Twitter!

"Proudly Serving the LGBT Community Since 1983"

Our Mission - The Hartford Gay and Lesbian Health Collective
empowers ind ividuals of diverse sexual orientations, gender
identities and gender expre ssions to lead healthy lives through
the provision of health and support se rvices, education and
advocacy.
This communication, together with any attachments hereto or
links contained herein, is intended for the use of the intended
recipient(s) only and may contain information that is
confidential or legally protected. If you are n ot the intended
recipient, you are hereby notified that any review, disclos ure,
copying, dissemination, distribution or use of this
communication is S TRICTLY PROHIBITED. If you have received
this communication in error, pleas e notify the sender
immediately by return e-mail message and delete all cop ies of
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or lin ks herein, from your system. Any views or opinions
expressed in this e-mail are not necessarily those of the
Hartford Gay & Lesbian Health Collective, its subsidiaries and
affiliates (HGLHC). E-mail transmission cannot be gua ranteed to
be error-free or secure from viruses, and HGLHC disclaims all li
ability for any resulting damage, errors, or omissions.

</
State Regulations
Section 15-140f-1
2 -

Dear Governor Malloy -

Section
change to
allow online education, for knowledge based information that is
incorporated in the basic boating safety course that leads to
certification, it would have a very positive outcome. Having the
ability to take online courses opens up the ability for many more
residents to advantage of that type of learning experience as it
will be
used for new boaters but also refreshers for those of us who
have been
boating for years. On line classes afford State residents to take
the
class when it is best for them.

allowing
The on
water boating education, which is being promoted by the USCG,
will help
to create a safer boating experience on Connecticut waters.

saving
lives; these changes warrant your consideration.

Thank You!

Kevin J. Noel

Mohawk Valley Basscaster Club Member
12/16/2013
9:18:47 AM

49 Siegas Road


860-470-3385

------_=_NextPart_001_01CEFA69.BBE76AAB<
John J.
Mathieu
Norwich Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/16/2013
12:23:05 PM
Vincent Anton Bristol Energy and
Environmental
Protection, Dept Of
Handguns in state
forests/parks
23-4-1(c) and 26-
66-2

12/16/2013
12:32:31 PM
Cheryl
Dunson
League of Women
Voters of CT
Hamden I don't know EO-37 Under the governing Principles applicable to the League of
Women Voters across the U.S., the League of Women Voters of
Connecticut believes that democratic government depends upon
informed and active participation in government, and that
responsible government should share in the solution of
economic and social problems that affect the general welfare
and promote the conservation and development of natural
resources in the public interest.
In issuing Executive Order No. 37, the Governor includes among
its stated goals to identify those *regulations+ that have become
outdated, unnecessarily burdensome, insufficient, or
ineffective. In the preamble, E.O. 37 states that the
procedures required under Connecticut law for promulgating
and amending regulations can be time-consuming and
cumbersome and, as a result, regulations that should be
repealed or modified are left unchanged.
E.O. 37 apparently is applicable to all Regulations of State
Agencies included within the State Administrative Code, ranging
from Title 19 Public Health and Safety, Title 17a Social and
Human Services, Title 21 Consumer Protection, to Title 28 Civil
Preparedness and Emergency Services, and Title 22a
Environmental Protection.
As our state continues to struggle with high unemployment and
low job growth, we understand the need to examine our states
practices. Despite the seemingly all-inclusive scope of the
directive announced by the Governor, E.O. 37 fails to
acknowledge any benefits of regulatory action beyond economic
and job development. Absent is any recognition of public health
and safety, improvement of the general welfare or protection of
our natural resources as a goal of government. Agencies are
directed to endeavor to encourage economic progress and the
development of jobs in Connecticut, and only seek to regulate
when there is a clear need for regulation. Clearly, cost-benefit
analysis should include public and societal costs, not solely
immediate costs of regulated entities.
Executive Order 37 adds more complexity to the review process,
notwithstanding its stated goal of streamlining the process. The
directive establishes a broad category of regulation of
significant impact and mandates that any regulatory action
relating *to+ a regulation of significant impact requires rigorous
12/16/2013
12:46:59 PM
impact analysis, a review of costs and benefits based on the
best available empirical and scientific information, and
engagement with external experts and academic institutions to
inform such impact analysis.
What category of regulation requires this expensive and time-
consuming agency process? *A+ny regulation that may have an
adverse impact on small businesses, as well as one with a
significant financial impact on medium or large businesses, or
anticipated significant cost to the state or to any municipality
is included. Finally, a regulation may be deemed to be of
significant impact if, solely in the judgment of the Governors
Office, the Office of Policy & Management, or the agency, based
[only] on public comment received, the potential regulation
presents a substantial shift in policy or is anticipated to place
substantial burdens on citizens or the private sector.
Connecticut provides an array of economic, advisory, and
technical assistance to the business community. Connecticut
also serves to protect the well-being of its citizens. The
balancing of these needs is the basis for responsible growth. The
League of Women Voters of Connecticut believes that an
informed, transparent and accountable process for promulgating
and amending state regulations can benefit the citizens,
businesses and municipalities of Connecticut, when that process
recognizes the need to balance business interests with
protecting public health and safety, preserving our natural
heritage, and meeting the needs of our most vulnerable
members of society.
Joan Wessell Connecticut
Association of
Area Agencies on
Aging
Aging, State
Department of
Title III Older
Americans Act
17b-423-2 - 19 Review of the Community Service Policy Manual for services
provided under Title III of the Olders Americans Act of 1965
reveals that the regulations are out of date and do not reflect
significant changes to the Older Americans Act implemented by
the reauthorizations in 2000 and 2006. The following includes
portions of the Older Americans Act which are not reflected in
the State regulations. This is by no means a full listing and the
recommendation is to do a complete review and rewrite of the
policy manual to alignment the document with the Older
Americans Act of 1965, as amended (OAA).

1. Add the new target population groups identified in the OAA
such as "individuals residing in rural areas", "older individuals
with limited English proficiency" and "older individuals at risk of
institutional placement".

2. Remove Title III F Disease Prevention and Health Promotion
Services and replace it with Title III D Evidence-based Health
Promotion programs.

3. Remove references to Title III D - In Home Services to reflect
changes made to the OAA.

4. Remove references to USDA Commodities and Cash and
replace with regulations and information regarding the Nutrition
Services Incentive Program (NSIP).

5. Add a provision which includes the development of Aging and
Disability Resource Centers as defined in the OAA.

6. Revise the percentages of tranfer allowances between
supportive services program funding and nutrtion services
program funding to reflect the OAA allowable transfers

7. Remove references to the Selection of Nutrition Providers
and the Bid Procedures for Contacts with Caterers and replace
with the current practice which was developed by the Area
Agencies on Aging in conjunction with the State Department on
Aging.

12/16/2013
1:43:52 PM
8. Update the Operating Requirements for Nutrition Service
Providers to reflect the requirement identified under the OAA.

9. Remove references to the Adminstration on Aging and
replace with the current name of the governing body
"Administration for Community Living" (ACL).

This list is not an all inclusive list of changes required to align the
Community Services Policy Manual for Title III of the Older
Americans Act with the Older Americans Act of 1965, as
amended. A complete review and revision is recommended.

Thank you for the opportunity to provide input into this
important endeavor.

Joan Wessell,
Executive Director
Senior Resources - Area Agency on Aging

on behalf of the Connecticut Association of Area Agencies on
Aging

Joan Wessell Aging, State
Department of
Fiscal Policies for
Title III Prog
17a-306-20 -45 A review of the Manual of Fiscal Policies for Title III Programs of
the Older Americans Act needs a complete review and revision
to bring it up to date with current OMB Circulars governing
Federal funding.

The review should include provisions allowed in the following
OMB documents:

OMB Circular A-110 Uniform Administrative Requirements for
Grants and Agreements with Institutions of Higher Education,
Hospitals and Other Non-Profit Organizations now referred to as
2CFR Part 215

OMB Circular A-122 Cost Principles for Non-Profit Organizations
now referred to as 2 CRF Part 230

OMB Circular A-133 and all Compliance Supplements through
2013

45 CFR Part 74 and revisions dated 2003 and 2007

This list is not all-inclusive and it is recommended that the Fiscal
Policies be reviewed and revised to reflect current government
regulations regarding Federal funds.

Thank you for the opportunity to provide input into this
important task.

Joan Wessell,
Executive Director
Senior Resources - Area Agency on Aging

on behalf of the Connecticut Association of Area Agencies on
Aging
12/16/2013
1:59:31 PM
Richard Jacob Yale University Public Health, Dept
Of
CT DPH Code CGS 19a-630 CGS 19a-630 defines an infirmary as caring "for the students,
faculty and staff of such institution and their dependents." The
regulations of the Department of Public Health use the same
wording, but they fail to include the key phrase "and their
dependents."

This omission is a burden for Yale Health, the staff-model HMO
that serves as the principal source of care for Yale students, over
70 percent of Yale employees, and their dependents. Yale Health
operates a 17- bed infirmary. Because DPH regulations do not
recognize infirmary beds that are available for dependents, Yale
Health maintains two licenses for its 17-bed infirmary: an
infirmary license for 13 beds, and a separate Chronic and
Convalescent Nursing Home license for the four beds available
to dependents. Maintaining separate licenses imposes a
significant cost and burden on Yale Health.

It would make more sense for Yale Health to maintain just one
Infirmary license that is available to "all member patients." We
recommend that DPH conform its regulations to the underlying
statute.
12/16/2013
2:44:50 PM
Richard Jacob Yale University Consumer
Protection, Dept Of
CT Comprehensive
Drug Laws, Section
Connecticut's regulations regarding controlled substances
duplicate and largely overlap existing federal regulations
administered by the US Drug Enforcement Administration. This
creates a regulatory burden, more than doubles the licensing
costs to individual practitioners, and establishes confusion
among the regulated community as to which rules (federal or
state) apply. These burdens are especially high on scientific
researchers, who are defined under Connecticuts statutes as
controlled substances Practitioners, a classification otherwise
reserved for those directly involved in prescribing or
administering controlled substances for medical or veterinary
purposes.

Connecticut's controlled substances regulations are largely
written for the supply chain of these materials and front line
medical and veterinary professionals responsible for their
prescribing and administering in humans and animals. We
suggest that all references to scientific research and research
laboratories be removed from the regulations, beginning with
the Definitions in 21a-240 (27). We further recommend that
scientific researchers and investigators who are not working
with human subjects or patients be removed from the category
of Practitioner (21a-316).
12/16/2013
2:44:57 PM
Richard Jacob Yale University Energy and
Environmental
Protection, Dept Of
Water Discharge
Permits
RCSA 22a-430-3 RCSA 22a-430-3 General Conditions Applicable to Water
Discharge Permits

The Department of Energy and Environmental Protection has set
multiple standards for wastewater discharge. It is not clear
which reporting standard applies under certain circumstances; it
would be helpful to regulated entities for DEEP to clarify the
regulations.

Section 22a-430-3(j)(11)(E) of DEEP regulations establishes
reporting requirements if the results of wastewater discharge
testing are above certain levels; this provision is commonly
referenced in individual permits as well as many General
Permits.

(E) The permittee shall notify the director within seventy-two
hours and in writing within thirty days when he or she knows or
has reason to believe that the concentration in the discharge of
any listed substance or any toxic substance as listed in appendix
B or D of this section has exceeded or will exceed the highest of
the following levels:
(i) One hundred micrograms per liter;
(ii) Two hundred micrograms per liter for acrolein and
acrylonitrile; five hundred micrograms per liter for 2,4-
dinitrophenol and for 2-methyl-4, 6-dinitrophenol; and one
milligram per liter for antimony;
(iii) An alternative level specified by the commissioner, provided
such level shall not exceed the level which can be achieved by
the permittee's treatment system.
(iv) A level two times the level specified in the permit
application;

However, the General Permit for the Discharge of Groundwater
Remediation Wastewater to a Sanitary Sewer and the General
Permit for Miscellaneous Discharges of Sewer Compatible (MISC)
Wastewater set much higher threshold for reporting to DEEP.

Subsection (E)(i) of DEEP regulations requires reporting of
concentration of any listed or toxic substance as listed in
Appendix B or D that exceeds 100 micrograms per liter.
12/16/2013
2:45:10 PM
However, both the General Permit for the Discharge of
Groundwater Remediation Wastewater to a Sanitary Sewer and
the General Permit for Miscellaneous Discharges of Sewer
Compatible (MISC) Wastewater set limit on total volatile
organics limit of 5,000 micrograms per liter. If any individual
organic compound that is listed in Appendix B or D exceeds 100
micrograms per liter, is reporting required under this section?

Subsection (E)(ii) of DEEP regulations requires reporting of a
concentration of acrolein and acrylonitrile (both volatile organic
compounds) that exceeds 200 micrograms per liter. Again, if
these substances exceed 200 micrograms per liter, is reporting
required or does the General Permits 5,000 microgram limit
apply?

Section (E)(ii) of DEEP regulations also requires reporting of
2,4-dinitrophenol and for 2-methyl-4, 6-dinitrophenol above
500 micrograms per liter. The General Permit for the Discharge
of Groundwater Remediation Wastewater to a Sanitary Sewer
and the General Permit for Miscellaneous Discharges of Sewer
Compatible (MISC) Wastewater gives limits for total phenols as
1,000 micrograms per liter, and 10,000 micrograms per liter,
respectively. If 2,4-dinitrophenol and for 2-methyl-4, 6-
dinitrophenol levels exceed 500 micrograms/L, is reporting
required under this section?

Section (E)(iii) of DEEP regulations allows the Commissioner to
set an alternate level different from the discharge limit specified
in an individual or General Permit. What are those alternate
levels?

In Section (E)(iv) of DEEP regulations, is the level two times
the levels specified in the permit application based upon
discharge testing conducted as a part of wastewater discharge
permit applications? If so, this number still may be well below
discharge permit limits.

The difference creates confusion for regulated entities; we
suggest that DEEP reexamine the reporting levels and clarify the
requirements, perhaps by deleting certain sections.
Environmental
Protection, Dept Of
Nitrogen Oxide
Emissions

5. Control of nitrogen oxides emissions

We have comments on multiple sections of the DEEP air quality
regulations concerning nitrogen oxide emissions: applicability;
emissions testing and monitoring; and reporting and
recordkeeping.

Applicability

DEEP regulations require that operators must check ambient
ozone levels before turning on emergency generators at any
time from May through September. The ozone-check must be
performed regardless of whether the generator is being turned
on to generate power or merely to test its reliability, as required
by Medicaid.

When this regulation was adopted it was targeted toward large
generators above a certain generating capacity (a Major Source
under the rules terminology), but over the years to DEEP has
incrementally expanded the application of this rule beyond
Major Sources that were the original target of the regulations.
DEEP currently interprets the rule to apply to many relatively
small sized commercial/institutional emergency generators,
thereby extending the rule to thousands of sources including
schools, nursing homes, supermarkets, apartment buildings, etc.
Operators of many of these generators are probably unaware of
the DEEP rule.

The federal Environmental Protection Agency has recognized
through its Tailoring Rule that it is ineffective to apply a rule to
so many sources that a large proportion of them will be out of
compliance due to ignorance or lack of outreach. In
Connecticut, most of the smaller sources now covered by the
ozone check rule are unaware of this interpretation and most
likely do not have any resources to manage compliance with this
regulation. We recommend that DEEP take a similar approach
and restore the application of ozone check to Major Sources of
emissions.

12/16/2013
2:45:21 PM
Emissions testing and monitoring

We recommend three changes to the rules about testing of
equipment that generates NOx emissions (22a-174-22(k) of
DEEP regulations).

First, testing is currently required every 5 years on the
anniversary of the previous test. Many sources are tested
several months before the deadline in order to avoid being late;
as a result the deadline creeps earlier in the year with each
testing cycle. It is ideal to test the equipment in the winter
because there is demand for the heat generated by operating
the source at full output. However, some sources that were
originally tested in the winter are now being tested at the end of
fall when the heating demand is less. When tests are scheduled
for the warmer months it is difficult to perform the tests
because there is not enough demand for the heat generated
when the equipment is operating at maximum capacity.

We recommend the following change to the regulation:

Section 22a-174-22(k) (1) The owner or operator of a stationary
source subject to an emission limitation under this section shall
conduct an emission test to demonstrate compliance with this
section no later than one year after becoming subject to this
section. Each such emission test shall be conducted in
accordance with section 22a-174-5 of the Regulations of
Connecticut State Agencies.
Compliance with the emission limitations of this section shall be
determined based on the average of three (3) one-hour tests,
each performed over a consecutive 60-minute period. Any
analysis of nitrogen content conducted as part of such emission
testing shall be in accordance with Method D-3228 of the
American Society for the Testing of Materials. If the
commissioner determines that three (3) one-hour tests are not
reasonable given the location, configuration or operating
conditions of a stationary source, the commissioner may
approve testing where compliance with the emission limitations
of this section shall be determined based on the average of four
(4) fifteen-minute tests, each performed over a consecutive
fifteen-minute period. Any owner or operator of a stationary
source who has not installed and operated a continuous
emissions monitor at such source shall conduct emission testing
once every sixty-two months five years from the date of the
previous test or sixty-two months five years from the date the
previous test was due, whichever is earlier.

Second, the testing section does not provide any alternative for
sources that technically cannot test in accordance with the rule.

We recommend the following addition to the regulation:

(2) The owner or operator shall demonstrate compliance with
emission limitations of this section using sampling and analytical
procedures approved under 40 CFR 60, Appendix A, or under
procedures in section 22a-174-5(d) of the Regulations of
Connecticut State Agencies. If such testing is deemed technically
infeasible by the Commissioner the owner or operator shall
propose alternative compliance methods subject to approval by
the Commissioner.

Third, the regulation defines maximum capacity in terms of fuel
burned, but it is equally valid to measure maximum capacity by
the amount of electricity or steam generated. In fact, measuring
capacity in this way gives owners an incentive to find ways to
operate generators more efficiently, and thus get credit for
achieving lower emissions. The federal Environmental
Protection Agency allows flexibility in defining maximum
capacity. Connecticut should also allow alternative methods of
demonstrating maximum rated capacity such as megawatt
output or steam output or some other measurable method. We
recommend the following addition to the regulation:

(A) If the commissioner determines that operating at or above
ninety percent (90%) of maximum capacity for a fuel burning
source or a process source during sampling is not reasonable
given the location, configuration or operating conditions of a
source, the commissioner may approve testing of a fuel burning
source or process source at an alternative maximum capacity
where compliance with the emission limitations of this section
shall be determined based on operating at or above ninety
percent (90%) of the alternative maximum capacity including
output based methods such as kilowatts or pounds of steam
produced approved by the commissioner; and

Reporting and record keeping

Section 22a-174-22(l)(c) requires non-GPLPE sources to maintain
records for a emissions limits that do not apply to them. The 25-
and 50-ton limits apply only to sources subject to subsections
(b)(2) and (b)(3); this subsection should be amended to include
the qualifying clause, For any premises for which subsections
(b)(2) or (b)(3) of this section applies.

l) Reporting and record keeping.
(1) The owner or operator of any source subject to this section,
shall keep the following records:
(A) For an emergency engine, daily records of operating hours of
such engine, identifying the operating hours of emergency and
non-emergency use;
(B) For any premises for which subsections (b)(2) or (b)(3) of this
section applies, records (e.g. fuel use, continuous emissions
monitoring, operating hours) to determine whether the NOx
emissions from such premises on any day from May 1 through
September 30, inclusive, are in excess of one hundred thirty-
seven (137) pounds for premises located in a severe
nonattainment area for ozone or two hundred seventy-four
(274) pounds for premises located in a serious nonattainment
area for ozone.
(C) For any premises for which subsections (b)(2) or (b)(3) of this
section applies, Monthly and annual records (e.g. fuel use,
continuous emissions monitoring, operating hours) to determine
whether NOx emissions from such premises in any calendar year
are in excess of twenty-five (25) tons for premises located in a
severe nonattainment area for ozone or fifty (50) tons for
premises located in a serious nonattainment area for ozone;
Environmental
Protection, Dept Of
Radiation
Regulation
19-24 The DEEP regulations concerning radioactive materials were
written at a time when DEEP was responsible for oversight of X-
ray equipment and non-Nuclear Regulatory Commission (NRC)
regulated radioactive materials like those from accelerators.
However, in 2005 the NRC changed their definition of Byproduct
material and assumed a phased in responsibility for oversight of
radioactive material produced in accelerators. Connecticut is
not an NRC Agreement State and DEEP does not issue licenses
for work with radioactive material. DEEP retains oversight of x-
ray equipment, and its regulations should focus on activities and
equipment it does regulate.

The CT DEEP regulations specific to radioactive materials in
section 19-24-1 through 14 are duplicative and often conflict
with NRC regulations. For example, section 19-24-5 of DEEP
regulations list exposure limits that are not consistent with
exposure limits set by the NRC. In addition, section 19-24-11 of
DEEP regulations details requirements for Reports of Incidents
or Loss of Radioactive Material. Again these requirements for
reporting are different than the NRC reporting requirements.
There is no need to require entities regulated by the NRC to
comply with a duplicative body of State regulations.
Accordingly, DEEP should amend sections 19-24-1 through 14 to
eliminate those provisions that are specific to radioactive
material and not x-ray generating equipment.

It would also be helpful for DEEP to reexamine the regulations
because they are outdated and confusing.
12/16/2013
2:45:33 PM
Environmental
Protection, Dept Of
Solid Waste
Regulations
Section 22a-209-
15(f) (7)
DEEP regulations define standards for the disposal of medical
waste. Under the regulations, it is industry practice to sterilize
medical waste in an autoclave, which is sufficient to render it
safe for disposal in an incineration plant. However, DEEP
regulations require the additional step of shredding waste; this
step is prudent for needles and other sharps but is
unnecessary for other forms of medical waste that do not
present a hazard of cuts or punctures.

We recommend that Section 22a-209-15(f)(7) of DEEP
regulations be amended to read,

Unless it is physically altered so as to render it unrecognizable
as biomedical waste, or if it is being sent directly to a trash to
energy incineration plant, decontaminated biomedical waste
shall be subject to the requirements of this section.

Clarifying this requirement to make clear that only truly defined
sharps waste must be rendered unrecognizable would be a
relief for those treating and shredding of waste on-site.
12/16/2013
2:46:08 PM
Charles
Brown
Connecticut
Association of
Directors of Health
Hartford Public Health, Dept
Of
Provision of public
health services
CT Agencies
Regulations 19-
13-B1
Current provisions of 19-13-B1, specifically sections B, E, F, and
H should be removed as the specific public health nuisances
listed are antiquated and not relevant in todays society. This
modification would modernize current Connecticut public health
law as it related to public health nuisances.

Revision would reflect more contemporary understanding of
public health nuisances. The following potential changes would
be an option to removing the section referenced:

B. Change the wording to make it more general "Spoiled or
adulterated food products"
F. Change the wording to "Transportation of solid waste,
garbage, sewage or any other waste product except in leak
proof, covered, sanitary containers and/or vehicles."
H. Change the wording to "The by-product of any trade or
activity shown to affect public health or produce serious
offense."
12/16/2013
3:39:32 PM
James Palmer None Wallingford Public Health, Dept
Of
Certificate of Need The absurd idea behind forcing health care providers to obtain a
Certificate of Need was to prevent health care providers from
overcharging consumers in an attempt to cover their own costs
of expansion by restricting the supply of health care providers
available to consumers. This has to be the only example of a
good or service in the entire world where costs were expected
to decline as a result of restricted supply. And, in fact, costs have
not declined, either in Connecticut or nationally (a similar
regulation is applicable in every state.) A brief look at the
Department of Public Health web site shows that about half of
Certificate of Need applications have been denied recently. If the
actual process of submitting a Certificate of Need application
can't be scrapped, then going forward, all of the applications
should be approved.

Competition is good for consumers. It drives prices down.
Businesses hate competition and often try to convince the
government to step in and limit it. In this case, they were
unfortunately successful.

Costs will never decline by restricting supply unless demand also
declines, which, in the case of health care, it never will. That's
basic economics.
12/16/2013
3:45:35 PM
Charles
Brown
Connecticut
Association of
Directors of Health
Hartford Public Health, Dept
Of
Provision of public
health services
CT Agencies
Regulations 19a-
76-2
Current Connecticut law provides that local health departments
are required to perform 8 basic public health services, outlined
in CT Agencies Regulations 19a-76-2. The Connecticut
Association of Directors of Health (CADH) seeks modification of
this regulation. Specifically, it seeks to replace the current 8
mandated services with the 10 essential services of public, as
described in Public Health in America (Public Health Functions
Steering Committee. Public Health in America. Washington, DC:
USPHS Office of Disease Prevention and Health Promotion;
1994.).

This modification is necessary to modernize current Connecticut
public health law to accurately reflect the mission and essential
services of public health. Since 1994, the 10 essential services
have been the nationally recognized framework used to (1)
explain what public health is, (2) clarify the role of public health
within the larger health care system, and (3) provide
accountability by linking public health performance to health
outcomes.

CADH further proposes that the modified regulation be based on
the Operational Definition of a functional local health
department, published in 2005 by the National Association of
County and City Health Officials (NACCHO). Revision is critical to
ensure that, in this difficult fiscal climate, local health
departments are operating within the framework developed by
the Centers for Disease Control and Prevention and other key
federal funders of state and local public health work in
Connecticut.

In short, modification is necessary to ensure:

Increased ease of applying for national public health
department accreditation, which may become a prerequisite for
accessing funds from the Centers for Disease Control and
Prevention and other key federal funders of local public health
work in Connecticut.
Elimination certain mandateslike providing nutrition services
and planning for genetic disease controlthat most health
departments in Connecticut cannot and do not fulfill.
12/16/2013
3:46:27 PM
Maximum flexibility to towns to promote public health in the
manner that best meets the needs of the local population
served.

CADH has proposed language to replace the existing regulation.
Susan
Giacalone
Insurance
Association of
Connecticut
Hartford Insurance Dept Homeonwer's
Insurance
Requirement
38a-824-3 (a)(2) &
(3)
. Regulation 38a-824-3. Subdivisions (2) and (3) of the
subsection (a) of the regulation should be eliminated or revised.
These two provisions prohibit insurers from requiring
homeowners to purchase homeowners replacement coverage
in amounts above eighty percent (80%) of the replacement cost
while also prohibiting limiting the sale of homeowners policies
to eighty percent (80%) of the replacement value without
offering coverage in amounts not less than the greater of the
market value of the property or fifty percent (50%) of the
replacement value. The two provisions impact an insurers
ability to properly assess risk and manage its book of business
while potentially encouraging homeowners to be underinsured,
as evidenced with the recent natural disasters. These limitations
are unique to Connecticut and do not exist in any other New
England state.
12/16/2013
4:03:58 PM
Janet P.
Brooks
land
use/environmental
attorney
East Berlin,
CT
Energy and
Environmental
Protection, Dept Of
state inland
wetlands
regulations
RCSA 22a-39-1 --
22a-39-13
I nominate the states wetlands regulations as a suitable
candidate for modification because they fill 3 of the 4
characteristics that the governor has identified: outdated . . .
insufficient or ineffective. Executive Order No. 37 1.

Sections 22a-39 -1 through 22a-39-13 have, for the most part,
been unrevised since their promulgation in 1974. There have
been 2 major revisions to the wetlands act, in 1987 and 1996,
along with about another dozen less comprehensive
amendments. The DEEP regulations do not reflect the current
statutory program at all. They are misleading and downright
wrong in numerous sections. Some sections the Attorney
Generals office said would not be defended (I was an assistant
attorney general from 1987-2006; for example, the invalidation
of municipal regulations by DEEP exceeds DEEPs statutory
authority).

Moreover, the state of Connecticut has adopted no upland
review area (URA). The state Supreme Court has upheld the
authority of municipal agencies to adopt such areas. In a survey
I undertook this fall, reviewing 95% of all municipal regulations,
only 2 municipalities and the state of Connecticut have no
established upland review area. Ironically, DEP issued a
guidance document in 1997 providing a basis for establishing a
100 foot upland review area. The majority of towns (105), at
DEEPs urging, have adopted a 100 foot URA.

Adopting a URA is a defensive approach to an Appellate Court
decision issued in 2003 in Prestige Builders, LLC v. Inland
Wetlands Commission, 79 Conn. App. 710 (2003), cert. denied,
269 Conn. 909 (2004). The Appellate Court held that a wetlands
agency was not authorized to exercise jurisdiction over activities
that were outside the wetlands or watercourse, unless the
agency had adopted by regulation an upland review area. Since
2003 DEEP and the Attorney Generals Office have urged
municipalities to adopt certain language in their regulations to
satisfy the Prestige Builders decision. According to my review
this past fall, 118 towns adopted such a regulation. The DEEP
has not heeded its own advice. It has no such protective
regulation.
12/16/2013
8:31:46 PM

The DEEP has created model regulations for the towns to adopt
which the overwhelming majority of towns have done. The
DEEP should take some of its own medicine. With relatively little
effort DEEP could use the model regulations as a basis for
crafting up-to-date regulations which would be effective and
helpful to the public who wish to participate in state wetlands
proceedings.
Charles
Bernier
Clinton Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/17/2013
3:50:50 PM
CCM Comments [Comment Emailed with an attachment: "CCM Comments -
Obsolete Regulations.pdf"]

Please see the attached document which references obsolete
and burdensome r egulations to towns and cities.

Best,

Mike Muszynski
Senior Legislative Associate
Connecticut Conference of Municipalities (CCM)
900 Chapel Street, 9th Floor
New Haven, CT 06510
Phone: (203) 498-3064
Cell: (203) 500-7556
Fax: (203) 498-5832

--
_000_C3F713258265F941A04E075A24696F801FA591vmex2k10
CCMPRI_<
12/16/2013
9:09:14 PM
Boating Certificate
Registrations
[Comment Emailed with an attachment: "mvbc support
letter.doc"]
format=flowed

Content-Disposition: inline

I wanted to write to you in support of online requirements for
boater
safety courses.
Please see attached.
Regards

Peter Gumprecht

------=_Part_222575_22362989.1387220465586<
12/16/2013
7:01:05 PM
On line boaters
licence

If a on line boaters license will help free up our state employee"s
to perf orm other needed jobs, I am for it. There are only three
things I wou ld like to driven into new boaters heads. Number
one is for boaters to keep there proper distance from anchored
boats and boats that are fishing along the shoreline. Number
two is that of proper procedure of boat ramp use, te ach them
not to tie up the ramp buy unloading and loading of there boats
an d vehicle on the ramp and to not stand in the middle of the
ramps with thei r boats while loading them with people or
supplies , but to move over to th e side out of the way. And the
third and most important is, please teach th em that all boat
ramps are no wake areas if they have no wake markers or no t.
Thank You Thomas
LaPorta
--2119117045-58382386-1387208154=:53956<
12/16/2013
7:35:54 AM
CWWA Comments -
Executive Order 37
[Comment Emailed with an attachment: "Comments -
Burdensome State Regulations CWWA 121613.doc"]

Attached are comments prepared by the CT Water Works
Association in respons e to Executive Order 37.

Thank you for the opportunity to comment.=20

Elizabeth Gara
CWWA
Tel. 860-841-7350
--_c6b0b570-b687-4b47-84c0-a51e20328f20_<
12/16/2013
11:08:46 PM
CHCC response to
E.O. 37
[Comment Emailed with an attachment: "Draft
S9_S10Modification CHCC response to EO # 37 12.16.13.pdf"]

Please see the attached comments submitted on behalf of the
Connecticut
Heating & Cooling Contractors Association in response to
Executive Order #
37.

Please feel free to contact either myself or CHCC Executive
Director
Jennifer Jennings at (860) 533-1163 or jjennings@chcca.net with
any
questions or if we may provide you with additional information.

Thank you in advance for your consideration.

Sincerely,

Andy Markowski,
on behalf of CHCC

--

Andrew E. Markowski, Esq.
Statehouse Associates, LLC
Government Relations
304 W. Main Street, #205
Avon, CT 06001
Cell: (860) 707-3620
Tel: (860) 256-8295
Fax: (860) 256-8296
aem@statehouseassociates.com

------------------------------------------------------
12/16/2013
4:03:21 PM
Contents of this communication may be privileged and/or
confidential. If
you have received this in error, please notify sender and delete
from your
system.

--001a1133fec68a858204edad25b5<
Executive Order 37 -
Comments from
COST
[Comment Emailed with an attachment: "COST Comments -
Executive Order 37.docx"]

Attached are comments from COST relative to Executive Order
37.

Thank you for the opportunity to comment.=20

Betsy Gara
Executive Director
COST
1245 Farmington Ave.=2C 101
West Hartford=2C CT 06107

--_658debd6-aee8-43f4-b0e3-bb9e2ebf5d90_<
12/17/2013
4:48:26 PM
NFIB/CT LC
Comments Pursuant
to E.O. # 37
[Comment Emailed with an attachment: "NFIBCT LC Response to
EO#37 12.16.13.pdf"]

Please see the attached comments from the Connecticut
Leadership Council of
the National Federation of Independent Business (NFIB), in
response to
Executive Order # 37.

Please do not hesitate to contact me to discuss further. Thank
you in
advance for your consideration.

Sincerely,

Andy Markowski
State Director
NFIB/Connecticut

--

Andrew E. Markowski, Esq.
Statehouse Associates, LLC
Government Relations
304 W. Main Street, #205
Avon, CT 06001
Cell: (860) 707-3620
Tel: (860) 256-8295
Fax: (860) 256-8296
aem@statehouseassociates.com

------------------------------------------------------
Contents of this communication may be privileged and/or
confidential. If
you have received this in error, please notify sender and delete
12/16/2013
3:49:36 PM
from your
system.

--089e011834d85a815704edacf4aa<
Online Boating
Course
[Comment Emailed with an attachment: "Online boating
courses.doc"]

Please see the attached letter on this topic.=C2 Thank you for
taking th is into consideration.
------=_Part_115121_1152422083.1387171066211<
12/16/2013
5:17:46 AM
comments on
regulations

format=flowed

X-OriginalArrivalTime: 17 Dec 2013 05:01:17.0485 (UTC)
FILETIME=[04C5CDD0:01CEFAE5]

Dear Ms. Decker,
Please add my concurrence to the comments of Margaret Miner
of Rivers
Alliance regarding review of regulations. It is always good to
review
regulations from time to time. Our committee, Program Review
and
Investigations, reviews state programs every year to determine
the most
efficient way to carry out the stated mission. We measure
results using
Results Based Accountability (RBA) techniques.

We must remember, however, that regulations that businesses
might view
as unnecessary or burdensome were set in place to protect
vulnerable
citizens, some living in areas highlighted by environmental
justice
campaigns, as well as the state's quality of life. For example, we
know
that residents living near highways and certain manufacturing
facilities
have an elevated risk of cancer due to air pollution. We only
have to
look at China or Bangledesh to see the mistakes that are made
when
regulations are weakened.

We would be happy to discuss RBA with you if that would help
the
regulations review process.

Mary Mushinsky
12/17/2013
12:00:47 AM
Co-chair, PRI Committee

</
Regulations Review
Submission[1]
[Comment Emailed with an attachment: "Regulations Review
Submission1.doc"]

Please see the attached testimony concerning deletion or
modification to
obsolete state government regulations.

Respectfully submitted,

James T. Fleming

President

CAR Association

36 Trumbull Street

Hartford, CT 06103

Tel: 860-293-2500

Fax: 860-527-2582

email: jfleming@ctcar.org

------=_NextPart_001_006B_01CEFA66.3555D9B0<
12/16/2013
1:53:32 PM
CBIA's Regulations
Comments

Below are CBIA's Regulatory Comments in response to Executive
Order 37. I f you have any questions please feel free to contact
me directly.

ENVIRONMENT

1. INCORPORATION OF THE REGULATORY TRANSPARENCY
PROVISIONS OF EXECUTI VE ORDER #37 INTO THE REGULATION
APPROVAL PROCESS.
CBIA is extremely pleased that the Governor included in
Executive Order #3 7 provisions for improving administrative
aspects of the regulatory adopti on process in Connecticut. We
believe these provisions will result in a m ore streamlined
process and better outcomes for our state. To the extent
applicable, these measures should be incorporated into the
Regulation Revi ew Committee's procedures for approving
regulations. This could be done t hrough legislation, through
incorporation into the committee's rules, or a combination of
both. There are many important and potentially impactful
regulations currently under development at DEEP. CBIA would
appreciate t he opportunity to work with the Governor's Office
and the legislature on t his important initiative early in 2014.

2. PRELIMINARY ANALYSIS: Alignment of resources with
regulatory prio rities

As a first step to determining which regulations are "outdated,
unnecessar ily burdensome, insufficient, or ineffective," requires
identifying existi ng state and federal legislative and executive
mandates that require a dis proportionate amount of resources
relative to those activities that direct ly serve the agency's ability
to address our most significant environmenta l challenges.
Notwithstanding that this critical precursor analysis has not yet
12/16/2013
8:41:54 PM
been con ducted, CBIA offers the following recommendations
with respect to our curr ent environmental regulations:

3. HAZARDOUS WASTE REGULATIONS - R.C.S.A. 22a-449(c)-
100, et.seq.

Background/Issue: There is a longstanding frustration on
the par t of Connecticut industry regarding the complexity of the
state's hazardou s waste regulations. These frustrations stem
from two primary sources. F irst, the degree to which
Connecticut's regulations differ from federal re quirements.
Second, to the extent Connecticut's regulations reference fede
ral regulations, those references are to versions of the federal
regulatio ns that are decades old. Our current state regulations,
for example, refe r to the 2001 federal regulations. Therefore, a
Connecticut company seeki ng to be in compliance with state
and federal hazardous waste regulations must not only comply
with CURRENT hazardous waste regulations, but also mu st find
a copy of the 2001 federal regulations, and substitute in a large
number of state modifications to the language of those 2001
federal regula tions. This is obviously extremely burdensome for
Connecticut businesses.

Solution: Undertake a revision to Connecticut' s
hazardous waste regulations in a manner that 1) minimizes
changes to the current federal regulations, doing so only where
there is a compelling st ate interest; 2) clarifies that when
federal regulations are updated, that references to federal
requirements in our state regulations that are unal tered by
state requirements shall be automatically valid commensurate
with the federal update, or within a limited period of time
following a federa l update, unless or until the state modifies
the updated federal language ; and 3) provides the regulated
community with a single document containin g the language of
the latest federal requirements as modified by any state -specific
requirements.

4. SPILL REPORTING REGULATIONS
Background/Issue: In 1971, the General Assembly
mandated that an extremely broad array of spills (caused by
accident or otherwise) by a br oad array of individuals (including
operators of any vehicles - including cars) be reported
"immediately" to the state and, as of 1994, to the DEEP (then
DEP). According to the statute, the reports are to contain
informa tion specified by regulations to be adopted by DEEP.
Those regulations ha ve never been adopted. Thus, businesses
could only interpret the statute to mean that every spill, of any
size, needed to be reported immediately. This resulted in a
deluge of reports to the DEEP, the vast majority of wh ich were
very minor in nature. To help address this, the legislature amen
ded the statute in 1995 to limit reportable spills to those "which
pose a potential threat to human health or the environment."
However, DEEP's int erpretation is that they are the only entity
qualified to determine if a s pill poses such a threat. Therefore,
businesses continue to operate "at r isk" if they don't file a
report with DEEP for every spill - no matter how minor. And the
agency continues to get thousands of calls each year for very
minor spills.
Solution: Adopt regulations, consistent with t he
regulatory transparency provisions of Executive Order #37 that
establis h simple and clear reporting thresholds for the most
commonly spilled mate rials, based on the records of reported
spills at DEEP (a surprisingly sma ll list). These quantities should
be based on the volume spilled for liqu ids and weight spilled for
solids. For all other materials, there should be a minimum
thresholds established, grouping these materials into a limit ed
number of categories.

5. WATER DISCHARGE PERMITTING - R.C.S.A. 22a-430-3 and -
4
Background/Issue: The statutory foundation of these
regulations is so overly broad as to place an impossible burden
on DEEP. For example, subsection (a) of C.G.S. section 22a-430
requires a permit for, among a p lethora of other similar
absurdities, a person pouring a glass of water fr om their faucet
onto the ground.
Solution: Revise subsection (a) of C.G.S. sect ion
22a-430 to reduce the universe of discharges requiring a permit
to tho se discharges that potentially pose a reasonably
foreseeable risk to envir onmental quality or human health.
Then revise R.C.S.A. 22a-430-3 and -4 i n accordance with the
revised statute and the regulatory transparency prov isions of
Executive Order #37.

6. GENERAL PERMITS HAVING THE POTENTIAL TO IMPACT 25
OR MORE CONNECTI CUT BUSINESSES.

Background/Issue: General permits are useful tools for
helping D EEP meet its enormously broad permitting obligations
through the issuance of one document that imposes legal
obligations on categories of businesses without having to
develop and issue a permit one business at a time. Ho wever,
some general permits place legal requirements on dozens or
even hu ndreds of businesses and therefore constitute, in our
view, de facto regul ations[1] which DEEP can adopt with few, if
any, protections provided unde r the Uniform Administrative
Procedures Act.

For example, DEEP has issued several general permits associated
with the d ischarge of storm water that are nearly 100 pages in
length and bear no pr actical distinction from a regulation.
Procedures for issuing such "state ments of general applicability"
should include at least some of the protec tions afforded under
the Uniform Administrative Procedures Act, as well as the
regulatory transparency provisions=20of Executive Order #37.

Solution: Declare by statute that environmenta l
general permits that have the potential to impact 25 or more
business ar e substantially similar to a regulation as defined by
state statute, such that certain specified aspects of the Uniform
Administrative Procedures Ac t, as well as the regulatory
transparency provisions of Executive Order #3 7 apply to their
issuance. We're confident this approach would also have
insured long ago that the many Connecticut businesses required
to periodic ally test their fire protection systems could do so
without risking a viol ation for discharging without a permit.

7. REGULATIONS CONCERNING THE RENEWAL OR
MODIFICATION OF EXISTING PER MITS
Background/Issue: Current regulations concerning air,
water, and other permitting unnecessarily burden both DEEP
and regulated businesses in circumstances where a business is
being transferred, expanded or upgrad ed. These circumstances
require a permit modification but the current pro cess is
cumbersome, lengthy and expensive. Similarly, when a permit
expir es and is due for renewal, the same problems arise, even
when little or no change has occurred at the permitted facility.

Solution: Modify the regulations concerning th e
renewal, transfer or modification of permits to significantly
streamline the process where no significant change in activity is
occurring or where such significant change will reduce the
environmental impact of the activ ity.

8. EMERGENCY AIR POLLUTION EPISODES - R.C.S.A. Section
22a-174-6

Background/Issue: This regulation sets forth requirements
for ai r pollution emergency episodes. It has not been updated
since 1993, and t o our knowledge, the emergency episode steps
called for by the regulation have not been triggered in decades,
if ever.

Solution: The Department should review the sta
ndards in the regulations to see if they are still appropriate. In
additi on, some of the=20steps called for under various
emergency episodes need t o be revisited. For example, if an
emergency is triggered, no "incinerato rs" can be operated.
Since Connecticut relies so heavily on resource reco very,
shutting down all of these units could result in other health
hazard s. Moreover, the resource recovery facilities have
modern air pollution c ontrols that were not required when this
regulation was initially adopted in the late 1970s or early 1980s.

9. PROCESS WEIGHT REGULATIONS - R.C.S.A. 22a-174-18(f)
Background/Issue: The origin of this regulation dates back
to re gulations adopted in California in 1949 and later revised
there in 1959. Subsequently, this type of regulation was
adopted by states across the nat ion before the Clean Air Act
came into existence. The original purpose of this regulation was
to control particulate emissions from certain industri es that
processed large volumes of material with exhausts that vented
thro ugh point source discharges, all of which could be
controlled with air pol lution control equipment. It was not
intended to address small emission s ources, like welding
operations, paint booths or abrasive blasting operati ons.
Applying this regulation to all operations that are not process
indu stries, as some DEEP personnel have suggested, would
make certain activiti es, such as welding, illegal in Connecticut.
Solution: Section 22a-174-18(f) should be dele
ted as obsolete.

10. AIR INVENTORY STABILIZATION FACTOR (ISF) - R.C.S.A. 22a-
174-26(4)(C)
Background/Issue: This regulation defines a fee assessed
on bus inesses that operate under permits known as "Title V"
permits, named after that section of the federal Clean Air Act.
There are over 70 such busine sses in Connecticut.
The fee is created by federal law but Connecticut modified the
federal for mula for determining the annual fee in a manner that
has exponentially inc reased fees affected businesses must pay
relative to other states.
The federal law calls for the fee to be=20determined by
multiplying the ac tual emissions at the facility times a per ton
fee - defined as $25 adjust ed for inflation since 1989. The
current per ton fee adjusted for inflati on is $46.25.
However, Connecticut places an additional factor into
determining the fee, known as the Inventory Stabilization Factor
(ISF). The ISF is based on a comparison of the total statewide
actual emissions from stationary source s in 1990 divided by the
total statewide actual emissions from stationary sources in the
most recent calendar year. Ironically therefore, as Connec ticut
businesses continue to make improvements in lowering
regulated emiss ions, the ISF serves to increase the fee. So in
effect, businesses are pe nalized for improving air quality.
The ISF has grown from 1.94 in 1997 to 14.11 in 2012.
Fortunately, DEEP h as exercised discretion making a final
determination of an "appropriate" I SF. Currently, DEEP has
subjectively assigned the ISF at 6.51. Neverthe less, this results
in fees for affected Connecticut businesses of $301, ti mes their
facility's emissions - compared to affected facilities in other
states now paying $46.25 times their facility's emissions.
Solution: R.C.S.A. 22a-174-26(4)(C) should be
modified to place a cap on the ISF. For initial consideration, we
would su ggest the cap be limited to no more than 5% of the per
ton fee. At the cu rrent per ton rate, this would allow for a
maximum ISF of (46.25 x .05) =3D 2.31 yielding an adjusted per
ton fee of $106.83.

11. E-GOVERNMENT AND ELECTRONIC SUBMITTALS
Background/Issue: Most environmental regulations include
recordkeeping and reporting requirements. CBIA appreciates
the significant effo rt DEEP has made to incorporate e-
government into its regulatory programs. We want to take this
opportunity to encourage the agency to continue to make this a
priority and to point out two examples of current programs whe
re such innovation is urgently needed:

Community Right-To-Know, Tier II submittals. Having a
statewide database, updated (via electronic submittal) annually
and for modification as neede d, and accessible by local
authorities 24/7 would make better sense and h ave a
significant impact. Not only does this eliminate paper and
mailings , but it provides a method for the state to keep current
inventories of al l extremely hazardous chemicals

This is less about our ability to compete and more about
increasing the in formation our local emergency responders can
access when deploying resourc es in an emergency.

Similarly, the annual requirement to submit a "Form R" under
the program i s now performed electronically using EPA's CDX
internet based system. Sub mitters essentially fill out the
standard forms on line. Each submittal i s verified by the
software then submitted electronically. However, the St ate of
Connecticut requires submitters to print a hard copy of this data
a nd submit it via US Mail as well.
Solution: Continue to expand E-government capabilities.
For Tier II submittals, maintain a secure database for the
collection of, and controlled access to, this information. For
Form Rs, determine what, if a ny, value there is in collecting
paper copies, then find a way to get that same value from the
EPA's centralized system.

ENERGY:

1. TAXES AND FEES ON ENERGY BILLS AND RENEWABLE
REQUIREMENTS
Background/Issue: These fees (including RGGI, CL&M) are
what, in large part, drives Connecticut's energy cost to be higher
here than in other nea rby states and it will only get worse as
our Renewable Portfolio Standards (RPS) become more
aggressive. Additionally, the degree to which private- sector
businesses benefit from these funds is unclear - as the data has
no t been assembled. However, there are clearly some major
businesses in Con necticut that believe these taxes and fees only
serve to make them less co mpetitive with other states.
Solution: Accelerate transformation of energy efficien
cy programs from a rate-payer subsidy model to an open-
market, privately f inanced model, and modify our RPS to be
more in line with other northeaste rn states. In the interim,
provide a better accounting of the dollars pai d into these funds
by manufacturers and other private-sector businesses co
mpared to how much they receive from the funds.

RECOMMENDATIONS FOR REPEAL/MODIFICATION OF CT
REGULATIONS:
LABOR:
31-19-1 - REPEAL
Employment of women between 1 a.m. and 6 a.m.
This section regulates the employment of women between the
hours of 1-6 a. m., as well as the transportation facilities that
must be available near t he workplace in order to employ a
woman at those hours. This section is o utdated and has a basis
in the false assumption that women are incapable o f working
the same hours as their male colleagues.
31-60-6 - MODIFY
Minors under the age of eighteen (wages)
This section is inconsistent with Connecticut General Statutes
section 31- 58(j) and should be modified. Section 31-58(j) allows
employers to pay "l earners, beginners, and person under 18
years of age" 85% of the minimum f air=20wage for the first 200
hours of employment. This is beneficial to e mployers and the
learners, beginners, and persons under 18 years of age be cause
it makes it less expensive for an employer to take a chance on
these inexperienced individuals. However, regulation 31-60-6
limits this to on ly the first job held by the learner, beginner, or
person under 18 years o f age. Therefore, if one of these
individuals proved to be unable to be s uccessful in their first
job, a subsequent employer does not have the oppo rtunity to
give them a chance at the same temporarily discounted wage
rate .

31-60-16 - MODIFY
Employee in a bona fide professional capacity (overtime)
This regulation should be modified to mirror corresponding
federal regulat ions. Pursuant to 31-60-16(a)(1)(a), the
regulation exempts from overtime requirements professionals
who have obtained advanced knowledge in a fiel d of science, or
learning acquired "by a prolonged course of specialized i
ntellectual instruction and study." In other words, an employee's
exemptio n from overtime requirements is based on formal
schooling and degree statu s.
Conversely, federal regulations recognize work experience and
do not rely solely on degree status. In order for an employee to
be exempt from overt ime requirements under the
corresponding federal regulations, they need "a dvanced
knowledge through a combination of work experience and
intellectua l instruction."
The state regulation should be modified because as currently
written, it y ields impractical results. For example, an engineer
who has been doing th at work for 30 years with only an
associate's degree is not exempt from th e state overtime laws,
whereas a newly hired colleague who is a recent col lege
graduate with a bachelor's of science degree in engineering
would be exempt under the law. The work experience of a
person who has been perfor ming the job should be taken into
account.

31-222-6 & 31-222-7 - MODIFY
Employers becoming subject who were not previously subject &
payment of co ntribution (Unemployment)
These=20sections reference an employer giving notice to the
unemployment c ompensation administrator within 15 days of
becoming subject to the unempl oyment compensation act.
Public Act 13-288 changed that threshold from 15 days to 30
days.
31-236-26d - MODIFY
Absence from work
This section establishes that three instances of no-call, no-show
unexcuse d absence at work can result in an employee's
termination for willful misc onduct. However, rather than have
each day of unexcused absence be consid ered a single instance,
the labor department has defined one instance as b eing "one or
two consecutive days." In other words, according to the chart in
this regulation, an employee has not engaged in three
"instances" of u nexcused absence until they have missed 5 or 6
consecutive days of work. The business community suggests
that each day of unexcused absence should count as a single
instance of unexcused absence.
31-250-8 - MODIFY
Requirements and administrative procedures for a voluntary
shared work une mployment compensation pilot program.
This section allows any unit of four or more employees of a
particular emp loyer to participate in the highly successful
shared work program. The bu siness community suggests
allowing participation of any unit of two or mor e employees
rather than the current four or more employees. This would al
low more small businesses to participate in the program and
give them addi tional options in their efforts to retain workers
and avoid layoffs.

TRANSPORTATION:
14-270-18 - MODIFY
Restrictions on travel time
This regulation prevents oversize or overweight tractor trailers
from trav eling on state roads between sunset and sunrise, on
Saturday, Sundays, hol idays, and up to a half-day before each
holiday. Ultimately, these restri ctions severely limit a tractor
trailer's ability to deliver products, mac hinery, or large
equipment during months where there are several major hol
idays. The result is more highway congestion issues as these
tractor trai lers are forced to travel during rush hour times
during a=20fewer number o f weekdays.
A pilot program was put in place during 2013 by ConnDOT that
allowed overs ize/overweight vehicle travel during Saturdays
and Sundays from daylight u ntil noon. This gave pilot program
gave manufacturers or large goods, such as laser cutting
machines, additional time to deliver their products to c
ustomers. Additionally, it resulted in less oversized or
overweight tract or trailers from being on CT roads during any
given day.

Bonnie D. Stewart, Vice President & Counsel, CBIA
350 Church St, Hartford, CT 06103
(W) 860.244.1925 - (M) 860.944.8788 - (F) 860.244.8481
Bonnie.Stewart@cbia.com - www.cbia.com
Twitter @CBIAbonnie - LinkedIn
www.linkedin.com/in/bonniestewart/

________________________________

[1] See, 4-166(13) which defines a "Regulation" as, "each agency
statement of general applicability, without regard to its
designation, that impleme nts, interprets, or prescribes law or
policy, or describes the organizatio n, procedure or practice
requirements of any agency. . ."=20(Emphasis add ed).

_____________________________________________________
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--
_000_03404A59D46B7D44BB628D3F27C1BFAE6259720DCBIAE
MAILcbiaco_<
Home Health and
Hospice regulatory
recommendations
[Comment Emailed with an attachment: "Regulatory Revision
Recommendations 12.16.13.pdf"]

On behalf of the licensed and certified CT home health and
hospice provider s, the CT Association for Healthcare at Home
submits the attached
recommendations for updates/revisions to the current DPH
Home Health Care A gency regulations, the DSS Provider Manual
for Home Health and
the DSS Provider Manual for Hospice.

[https://m360.cthealthcareathome.org/CONTENT/3277075/Trac
y.jpg]

--
_000_1fb2b14c4509410e9827a3bcefb5ab83BLUPR04MB593na
mprd04pro_<
12/16/2013
9:14:51 PM
CCPA Comments to
EO #37
[Comment Emailed with an attachment: "CCPA Comments to EO
# 37.pdf"]

Good afternoon,

My name is Brunilda Ferraj and I work with the Connecticut
Community Provid ers Association (CCPA). Attached please find
CCPA's comments regarding Gove rnor Malloy's Executive Order
#37. If you have any questions, please do not hesitate to contact
me at bferraj@ccpa-inc.org<mailto:bferraj@ccpa-inc.org > or
860-257-7909.

Thank you,
Brunilda

Brunilda Ferraj, MSW
Public Policy Specialist
Connecticut Community Providers Association (CCPA)
35 Cold Spring Rd, Suite 522
Rocky Hill, CT 06067
860-257-7909 (P)
860-257-7777 (F)
bferraj@ccpa-inc.org<mailto:bferraj@ccpa-inc.org>
www.ccpa-inc.org<http://www.ccpa-inc.org/>
[cid:image001.png@01CE7806.F59C2130]
[fb_icon]<https://www.facebook.com/pages/Connecticut-
Community-Providers-As
sociation/350895115039685>[Twitter]<https://twitter.com/CCP
A_Org>[LinkedIn]
<http://www.linkedin.com/company/connecticut-community-
providers-associatio n-ccpa-
/C:/Documents%20and%20Settings/karchibald/My%20Documen
ts/Downloads> [RSS] <http://providerinsider.com/feed/>
[Pinterest] <http://pinterest.com/ ccpainc/>

--
_000_DEDE4571ABB0484CBE8D45E186B7F680115CCFDAGN09c
e6exg6exgh_<
12/16/2013
8:38:33 PM
David Ladasky Southbury Energy and
Environmental
Protection, Dept Of
Carrying Handguns
in State Forests
23-4-1(c) and 26-
66-2

23-4-1(c) of the Connecticut Agencies Regulations- Add an
12/18/2013
12:40:48 AM
Stephen
Maroney
West
Hartford
Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/18/2013
11:21:12 AM
Francis Manzi Hamden Energy and
Environmental
Protection, Dept Of
Carrying handguns
in State Forests
23-4-1(c) and 26-
66-2

12/18/2013
12:40:37 PM

You speak as if you are interested in helping small business owners. Your words dont follow your
actions.
We own a small retail outlet that happens to sell cigarettes, as thousands of other families do . On July
1
st
2013 you had signed into law a sales tax on our cost of cigarettes. Its apparent that you never
owned or operated a retail outlet that was subject to collecting sales tax for the State. The States
reasoning for this was to help prevent fraud. This couldnt be further from the truth. The State really
wanted to collect 90% of the tax money earlier.
If the State wanted to prevent fraud, all they had to do was have all the licensed cigarette wholesalers
provide for the State, a dollar amount that was sold to each licensed retailer as the Beverage Alcohol
Industry did a number of years ago. Instead you impose a 6.35% sales tax on the cost of a product that
could sit on our shelves for a number of months before they are sold. These early out of pocket dollars
could have helped pay for other purchases.
You have to agree that this is not a very friendly way of doing business in the State of Ct. This should be
repealed as quickly as it was signed into law. To the best of my knowledge this is the only product that
has incurred such an injustice.
Hopefully you will address this issue.
Regards
Paul A Baudouin

MAUREEN E. GRIFFIN

November 24, 2013
Governor.regulations@ct.gov, David.Alexander@cga.ct.gov
John.A.Kissel@cga,ct.gov
I am a 61 year old small business owner in the State of Connecticut for over 20 years.
I am a licensed cosmetologist, and a salon owner. I have been the owner and Sole operator for
all these years, starting my business from scratch with barely a dime in my pocket.
Within my salon business , I offer Hair and Skincare, as well a Healing Energy Treatment s (Jin Shin
Jyutsu). I have been Certified as a practitioner for many years after attending over 5 training sessions.
Each training session is a week long Intensive consisting of daily 8-10 hour long classes. The training
is expensive and requires travel and lodging where the training is offered. I have invested a lot of time
and effort into this training.
I understand that the State Of Connecticut is now going to require a license in Massage Therapy to
practice this healing modality.
I know that other states , such as New Jersey , have a separate test and license for practitioners of Body
Energy Work such as Jin Shin Jyutsu and Reiki and the like.
Massage therapy training is very expensive. $5000.00 and up depending on the school.
It also requires me to close my business to take these classes. Very difficult since I work alone.
I have begun classes at a local college but the time and expense is an extra burden especially at this
point in my career. Other practitioners are experiencing the same problem.
Since I am approaching retirement age, I would like to restructure my business, but these new
requirements just keep making it harder and harder to survive and run a successful business.
Why not rethink your plan with grandfathering or different licensing for practioners of these different
Types of treatment, which by the way do not require a client to disrobe or be massaged in any way ?

Thank you for your consideration, Maureen E. Griffin
Ps: I also hold a Real Estate Broker License in our state

I

Duplicative Regulations:

Recommend the following five Public Health Code Regulations be repealed; governance is
duplicated under 19-13-B42 (most current regulation that incorporates the sanitary aspects of
ALL food related industry and general sanitation)

1. 19-13-B40: Sanitation of Food, Fair Grounds, Ice Plants and Trailer Coaches
(effective 10/8/1963)

2. 19-13-B41: Sanitation of public fair grounds, horse shows, horse races, and automobile
races (effective 4/11/1973)

3. 19-13-B44: Sanitation of trailer coaches (effective date 3/6/1974)

4. 19-13-B48: Itinerant Food Vending and Catering (effective date 10/5/2005)

5. 19-13-B49: Catering and food service (effective date 10/3/2005)

KEEP: 19-13-B42: Sanitation of places dispensing food or beverages
(Revision date 7/3/2007)

U.S. Supreme Court Places Its Thumb On The
Land Use Scale

By: Tim Hollister, Joe Williams, Chris Smith, Matt Ranelli, and Beth Critton

Somewhat lost amid the tumult of U.S. Supreme Court decisions on same_sex marriage,
affirmative action, and voting rights, was the unusual specter of the Court weighing in on
the conduct of local and state land use proceedings, and issuing a decision that not only
favors the property owner, but also describes property owners seeking permits as
vulnerable to government extortion.

Koontz v. St. Johns River Water Management District , issued June 25, 2013, is a
once_in_a_generation decision, for its subject matter, outcome, and tone.
This article summarizes the decision and its likely impact on land use proceedings.

The Koontz backstory is that in 1987 and 1994, the Supreme Court established what
became known as the Nollan / Dolan doctrine, which holds that exactions, which are
permit conditions imposed by a municipal, regional, or state agency, must provide a nexus
a logical connection between the impact of the proposed land use and the condition
that tries to mitigate that impact and rough proportionality some measurable balance
between the land use impact and the condition imposed by the permit.

In Nollan (1987), the Court struck down a requirement that a property owner grant the
public an easement to cross his oceanfront lot as a condition of a permit to build a house,
holding that the application did not justify requiring public access, even along a beach.

In Dolan (1994), the Court invalidated a requirement that a property owner, who wanted to
build a plumbing supply store, dedicate an easement across her land for a public bike trail.

Nollan / Dolan thus established a minimum national standard for exactions, a standard
rooted in the Takings Clause of the Fifth Amendment to the U.S. Constitution, which allows
government to take interests in private property only for public use and only upon paying
just compensation. Since 1994, state courts and lower federal courts have raised and
resolved differently two questions not answered by Nollan / Dolan: does the requirement for
nexus and rough proportionality between the proposed land use and the condition apply
when government makes demands on a property owner who refuses them, such that the
permit is then denied? And does Nollan / Dolan apply when the government, instead of
demanding an interest in land such as an easement, requires money?

Koontz owned 14 acres of vacant land near Orlando and sought a permit from the Water
Management District to improve three of his acres. In exchange, he offered to preserve his
remaining 11 acres as open space, but the District pressed Koontz for more, asking him to
develop one acre and dedicate 13, or pay the District to enhance 50 acres owned by the
District and located several miles away. Koontz refused both demands. The District then
denied his permit. Koontz sued the District in state court under state law to try to get his
development approved, but asserted that the Districts proposed conditions violated federal
law, Nollan / Dolan, In its June 25 decision, the Supreme Court said yes on both
unresolved questions: Nollan / Dolan applies where a permit applicant refuses the
conditions and the agency denies the permit, and it applies where the governments
demand is for money, not property. Thus, the Court confirmed the broad scope of Nollan /
Dolan as a protection of property rights, arising from the Takings Clause. But it is the
Courts explanation of these results that is extraordinary. The Court described Nollan and
Dolan
as reflecting Two realities of the permitting process.
The first, it said, is that (emphasis added) land_use permit applicants are especially
vulnerable to . . . coercion because the government often has broad discretion to deny a
permit that is worth far more than property it would like to take. In other words, a
property
owner, engaging in old_fashioned free enterprise by seeking a way to enhance the value
of its land by obtaining a permit to develop it, is often at the mercy of government officials
interested in extracting more of the enhanced value than is justified by mitigating the actual
impacts of the proposed land use. By conditioning a permit on the owners deeding over
a public right_of_way, for example, the government can pressure an owner into voluntarily
giving up property. The second reality is that land uses often impose costs on the public
that government may rightfully offset, such as by requiring dedications of land.
Nollan /Dolan, the Court observed, aligns these two realities by allowing exactions but
requiring anexus and rough proportionality; thus, it allows the government to force property
ownersto mitigate the actual impacts of their own activities, but restrains it from arbitrary
action, regulatory overreaching, or outright extortion. The Courts observation about an
imbalance of power in land use proceedings is not news to property owners. But the Courts
repeated use of the word extortion to describe a possible outcome of land use permit
proceedings, and its characterization of land use permitting as often involving flagrant
misuse of the unequal bargaining power between the applicant and the government, are by
any measure unprecedented and breathtaking the Court putting a federal thumb on the
side of property rights in proceedings that are mostly a creature of stateand local law.

The decisions second reverberation is its description of permit conditions / exactions that
fail the nexus / proportionality test as essentially a misuse of the power of eminent domain,
a direct (or per se) violation of the Fifth Amendments Takings Clause, as opposed to a
so_called regulatory taking. The Court explained that the test for whether an exaction
is unconstitutional is whether that condition, if issued by the land use agency as an
administrative order rather than as a demand added to a permit, would require payment
of just compensation. Thus, when the Water District demanded that Koontz dedicate 13
of his acres as open space to obtain a permit to develop the rest of his land, the question
was whether, if the agency did this by direct order instead of permit condition, it would
have taken the property, requiring payment of compensation. (It likely would.) Thus, the
Koontz decision directs that the exactions are, or are at least closer to, direct condemnation
/ eminent domain, than to government regulatory takings (destroying a propertys value
through excessive regulation). As is often the case after a broadly_worded decision like
Koontz, in the immediateaftermath, property owners and property rights advocates declared
resounding victory, while government officials described apocalypse. The reality, however,
is that the decision will now play out during the next few years as owners, regulators, and
courts try to apply the decision to real_life situations. The impact will be neither
revolutionary nor catastrophic. (In fact, the Court clarified the breadth of Nollan / Dolan
protections, but did not rule on the merits of the Koontz development, which is based on
Florida, not federal, law.) So, we expect Koontz, over time, to have the following
consequences:

1. First and foremost, land use agencies will need to think twice about conditions
and demands imposed on permits, because it is now clearer that any demand
that is not based on a solid logical nexus and rough proportionality will be suspect,
and in the most egregious cases of agency overreaching, property owners will have
a stronger, clearer basis to challenge agency action and potentially to sue for
just compensation.

2 The decision strengthens the hand of property owners who have the stamina, time,
and resources to challenge permit conditions, by broadening the legal analysis and
bringing exactions clearly under the federal Fifth Amendment; the holding solidifies
a third type of Takings Clause protection of property owners, in addition to
prohibiting takings that are not for public use and takings without payment of just
compensation.

3. Specific types of government permit conditions / exactions that will now require more
careful scrutiny include: open space dedications, utility upgrades, road improvements,
anything off_site, anything on the governments own land, anything involving money (such
as fees_in_lieu), and anything that stretches logic and proportionality beyond reason.
All of the above said, the realities are, and will remain, that property owners and developers
will still be pressured to accept and often will accept unreasonable demands where
there is more value to them in accepting than fighting. Constitutional challenges to permit
conditions will still be expensive, time_consuming, and reserved for the most egregious
situations. The Koontz decision will likely change the tone of land use proceedings
involving
permit conditions by allowing land owners and their representatives to challenge a broader
range of demands, while causing government agencies to consider exactions more carefully
This communication is being circulated to Shipman & Goodwin LLP clients and friends and
does not constitute an attorney client relationship. The contents are intended for
informational purposes only and are not intended and should not be construed as legal
advice. This may be deemed advertising under certain state laws. 2013 Shipman &
Goodwin LLP. before crafting them and insisting on their acceptance. The legal analysis to
be applied when government agencies push hard on conditions will be better understood by
all concerned. The decision will specifically help land owners most in the relatively small
cadre of cases where the governments reaction is egregious and the property owner is
willing to take the fight to court. The change will be incremental, and evident most in
extreme situations.

Going back to our start, it is an extraordinary day when the U.S. Supreme Court puts its
thumb directly on the state, regional, and local land use scale, and in Koontz it
unmistakably did so. The decision will require government officials to consider more
carefully the conditions they impose on permits and in some cases, the decision will give
property owners a broader and clearer legal basis to challenge those conditions.
Dear Senator Kissel,

I am writing to you in response to your recent mailing to businesses. First, I want to
commend you for giving me this opportunity to express my views on state regulations and
laws. I have never seen a state Senator solicit this type of information.

Yes, I AM sick of burdensome state regulations and laws which are harming my business.
As a builder and developer I am subject to many regulations. Three of the most onerous
State statutes that have caused me a lot of problems, expense, and delay are as follows:

1. Sec. 8-25. Subdivision of land. This section of the statute needs clarification. It is
apparent to me that the drafters of this statute had in mind that the developer would
give 10% of his land to the Town as open space. The statute talks about the value of
the open space not exceeding 10%. However, the amount of open space should also
not exceed 10%. The statute is not clear in this regard. Some towns have abused
this lack of clarity and have taken more than 10% of one=s land without just
compensation. This is not right and illegal under federal law. I propose amending
the statute by adding the underlined and italicized words to the statute as follows:

Sec. 8-25. Subdivision of land (a) No subdivision of land shall be made until a plan
for such subdivision has been approved by the commission. ....
Such regulations shall also provide that the commission may require the provision of open
spaces, parks and playgrounds, when, and in places, deemed proper by the planning
commission, which open spaces, parks and playgrounds shall be shown on the subdivision
plan; and the total area of such open spaces, parks and playgrounds shall not exceed ten
per cent of the area of the land to be subdivided. Such regulations may, with the approval of
the commission, authorize the applicant to pay a fee to the municipality or pay a fee to the
municipality and transfer land to the municipality in lieu of any requirement to provide open
spaces. Such payment or combination of payment and the fair market value of land
transferred shall be equal to not more than ten per cent of the fair market value of the land
to be subdivided prior to the approval of the subdivision. The fair market value shall be
determined by an appraiser jointly selected by the commission and the applicant. A fraction
of such payment the numerator of which is one and the denominator of which is the number
of approved parcels in the subdivision shall be made at the time of the sale of each
approved parcel of land in the subdivision and placed in a fund in accordance with the
provisions of section 8-25b.

2. Sec. 8-18 Definitions. In this section the definition of Acluster development@ has
caused me great expense, problems, and delay. The definition reads in part:
Acluster development@ means a building pattern concentrating units on a particular
portion of a parcel so that at least one-third of the parcel remains as open space to
be used exclusively for recreational, conservation and agricultural purposes except
that nothing herein shall prevent any municipality from requiring more than one-
third open space in any particular cluster development; ....

This statute is being abused by some towns. First of all the developer should have the
choice, not the mandate, that a Acluster development@ be proposed. One local Town
demands that such Acluster development@ be used if the parcel to be developed exceeds 10
acres or 5 lots, and they require 50% open space. And what do I receive in return? Only
the right to make smaller lots, but not more lots than I would otherwise get, and the
mandate that I set the houses back 100' (instead of the customary 50') from an existing
road. This is a Ataking@ without just compensation, illegal under federal law. If I have a 12
acre parcel I have to give away 6 acres of my land for the right to develop the remaining 6
acres. This statute must be changed! It should state that a cluster development can be
proposed at the developer=s option; and that the amount of open space to be set aside will
be at least one-third, with no requirement that it be more than one-third. One Town is
using this statute to circumvent their own zoning regulations, thwart development, and
block more reasonably priced housing. We need to change this onerous statute!

3. Sec. 8-18 Definitions I have recently had a disagreement with a nearby Town over
the definition of the word Asubdivision@ as it is used in zoning matters. I wanted to
subdivide only 10 of my 32 acres but the Town insisted that the remaining 22 acres
constituted a building lot, even though it lacked the required frontage. I had a
written opinion from the well-respected zoning attorney Timothy Hollister from
Shipman & Goodwin supporting my position, but the town would not agree and
caused me to incur extra expense and lost time in my pursuit of a simple subdivision
application that proposed all of the lots on an existing street. Can you imagine if you
owned 500 acres and wanted to give each of two children a 1 acre building lot? The
town would claim you really had 3 lots, one of then being 498 acres in size? Then
they would demand an inordinate amount of that land to be given to the town as
open space. This is absurd! To alleviate such problems with other developers
throughout the State, I propose that the definition be amended by adding the words
shown italicized and underlined and deleting the two words sale or in Sec. 8-18 as
follows:

Sec. 8-18. Definitions. As used in this chapter: "Commission" means a planning
commission; "municipality" includes a city, town or borough or a district establishing a
planning commission under section 7-326; "subdivision" means the division of a tract or
parcel of land into three or more parts or lots made subsequent to the adoption of
subdivision regulations by the commission, for the purpose, whether immediate or future, of
sale or building development expressly excluding development for municipal,
conservation or agricultural purposes, and excludes parts or parcels labeled ANOT A
BUILDING LOT@ on a proposed subdivision plan, and includes resubdivision; ....

I really appreciate this opportunity to advise you of my concerns. I would be happy to
discuss these issues with you or anyone else at any time. I can provide any additional
information you seek. I hope you can help me to get the statutes changed.

Sincerely,

Charles Rinaldi
Enfield

Diageo North America, Inc.

801 Main Avenue
Norwalk, CT 06851

December 12, 2013
Via email - governor.regulations@ct.gov; Commissioner Rubenstein, Department of Consumer
Protection
Dear Sir/Madame,
In response to Governor Daniel Malloys October 16, 2013, Executive Order No. 37 that invites
public comment on ineffective regulations over four years old, we submit our suggestions with
respect to such regulations pertaining to alcohol beverages under the jurisdiction of the
Department of Consumer Protection (Department).
The Problem
At present, there is considerable confusion among members of all three tiers of the alcohol
beverage industry regarding what is, and is not permitted. At Diageo, we believe it is imperative
that the regulatory structure give clear direction in various trade practice matters.

Guiding Principle for Regulatory Reform

We also believe that a proper regulatory structure should consider real world business practices
and establish realistic limits regarding permissible ways for industry members to promote
alcohol beverages.

Historical Regulatory Context
When Prohibition ended, the federal government passed the Federal Alcohol Administration Act
(FAA Act) to address the excesses that led to the ban on the sale and distribution of alcohol in
the U.S. As implemented, the FAA Act offers clear guidance to industry members designed to
avoid practices that led to suppliers domination of retailers and the promotion of excessive
consumption of alcohol. Of course, the FAA Act has evolved over the years in recognition of
changes in society and the industry. With regard to the tied house laws, there has been a
general acknowledgment that with the increasing size and influence of wholesalers and retailers
in the industry, there is less need for regulatory protection of such entities from the once
predatory trade practices exhibited by suppliers in previous eras.
While state policymakers appropriately retain general authority over alcohol beverage policy,
the FAA Act provides state alcohol beverage control authorities with general guidance
concerning the regulation of alcohol beverage trade practices and marketing. In fact, a number
of states (e.g., Hawaii and New Mexico) have adopted the FAA Act as part of their alcohol
beverage laws and regulations to govern trade practices, marketing and advertising. Other
states have used the FAA Act as a starting point for developing their own regulatory framework
concerning alcohol. These individual state actions have resulted in varying degrees of control.
Similar to the FAA Act, the best state alcohol beverage laws and regulations provide for clear
and reasonable exceptions to broad-based prohibitions against unlawful inducements, i.e.,
providing something of value to retail licensees that unduly influence the purchasing decisions
of retailers.
As is the case with the FAA Act, many states have updated, reinterpreted or completely re-
written their laws, regulations and policies concerning alcohol regulation over the years. We
view these efforts to update and revise alcohol beverage laws and regulations as positive
developments. Policymakers are acknowledging that the law is not static, but must evolve to
preserve the three-tier system while taking into account that society, the retail environment,
and consumers demands have changed significantly since the mid-1930s.
Specific Regulatory Requests: On-premise sampling, retailer entertainment, elimination of
burdensome requirements
On-premise sampling
In recent weeks the Department has clarified its position with regard to off- premise sampling
along with supplier and/or wholesaler participation in such activities. We were pleased with this
clarification and have subsequently urged the Department to extend this position to on-premise
sampling. At present, there is no regulatory language permitting or prohibiting on-premise
consumer sampling. We believe that in Connecticut, both on- and off-premise sampling should
be treated and enforced equally, and that suppliers and wholesalers should be able to
responsibly promote their brand products and educate consumers through these activities.
It is important to understand why industry members seek opportunities to engage in off-
premise and on-premise consumer samplings. Innovation is the life blood of growth in the
alcohol beverage industry, in particular within the spirits category. Consumer sampling is critical
to the introduction of new products by allowing consumers to learn about and try product
innovations. When suppliers and/or wholesalers conduct sampling activities the focus is on
interacting and engaging with consumers to promote awareness of suppliers products. The
involvement of suppliers, their agencies, or their wholesalers is essential to effectively sample,
as their trained personnel have the requisite knowledge concerning the attributes of these new
products. Any services provided by suppliers or wholesalers in connection with sampling
promotions are not intended to provide something of value to retailers or to unlawfully induce
future sales, but simply to facilitate a meaningful consumer experience of the product being
sampled.
It is also important to note that most states allow both on- and off-premise sampling. In fact,
according to our state by state summary of sampling permissibility, 40 states allow some form of
off-premise sampling and 45 states allow some form of on-premise sampling.
Retailer Entertainment
Diageo believes that limited retailer entertainment activity to facilitate relationship building
between suppliers and retailers, and between wholesalers and retailers, is an appropriate and
acceptable business practice in the alcohol beverage industry. Retailer entertainment activities
can range from sharing a cup of coffee or a meal with a retailer employee or, in limited
circumstances and with Diageo employees in attendance, going to a ball game, golf outing or
concert. In addition, retailer entertainment can mean a private event for the trade where only
retailers are invited and education and sales training are provided on designated Diageo
products. In fact, the Department has recently approved this latter type of retailer
entertainment in Connecticut. Without clearly marked boundaries, regulations are
inconsistently followed and subject to misinterpretation by all parties. Therefore, we urge the
Department to issue regulatory language clarifying the permissibility of retailer entertainment.
To justify this position, we first note that the FAA Act does not prohibit retailer entertainment
and, similarly, no state to our knowledge expressly prohibits it. In fact, though the laws and
regulations of most states are silent on the issue, there are 15 states whose laws expressly
permit some form of retailer entertainment. The alcohol beverage law in Texas, for instance,
permits suppliers to provide entertainment to retailers up to $500 per retailer employee, per
single occasion. Under Illinoiss Trade Practice Policies, suppliers and/or wholesalers may
provide retail licensees or their employees with normal and customary hospitality, i.e., lunch,
dinner, and tickets to sporting events provided they are accompanied by a representative of the
supplier or wholesaler.
Further, while it does not have jurisdiction as an alcohol beverage regulatory agency, the
Internal Revenue Service has specific business guidelines concerning retailer entertainment.
When engaging in reasonable entertainment of retailers, Diageo follows IRS regulations, state
laws, and our global company policies governing gifts and entertainment.
Elimination of burdensome and unnecessary regulations that have little rationale for existing
It is our belief that if the rules are clear, there is no need to require pre-notification or reporting
of impending activities. Diageo promotes compliance from the highest levels, and it is in our
best interest to follow relevant laws. We urge the Department to review its regulations with
this understanding in mind and eliminate unnecessary requirements that burden both industry
members and staff at the Department. One specific pre-notification requirement should be
eliminated is the requirement to provide the Department with notice before donating alcohol
beverage products to non-profit entities. Instead, we suggest that the Department offer
language permitting charitable donations of alcohol beverages and money, and, if desired,
require that suppliers, wholesalers or retailers retain records of such giving.
An additional burdensome and unnecessary reporting requirement is the regulation that
requires giving the Department prior notice of promotional funds granted by suppliers to
wholesalers for marketing activities. Under Sec. 30-6-A29 of the Departments regulations, out-
of-state shippers and manufacturers are required to file a report with the Department that
details the promotional funds they intend to pay to wholesalers. To the best of our knowledge,
alcohol beverage suppliers do not customarily file such reports and the Department does not
actively monitor the activity related to such filings. Therefore, since these reporting
requirements related to marketing funds serve no purpose and perpetuate unnecessary
ambiguities in the law, they should be eliminated.
A related requirement under Sec. 30-6-A29 is that promotional funding from suppliers to
wholesalers must be provided on a non-discriminatory basis, and apportioned on the basis of
the population in wholesalers authorized territories. Though on its face basing the allocation of
promotional support on population appears to achieve the goal of avoiding discrimination,
population as the basis of apportionment is unrelated to the reality of how promotional funding
is most effectively distributed and inappropriate for this purpose. A better basis for allocating
marketing support among wholesalers that is grounded in business reality, is one based upon
the level of sales of suppliers products which affords businesses with the freedom to adapt to
changing needs over time.
In Summary
To conclude, we urge the Department to communicate clear guidance to industry members
expressly permitting: (1) on-premise consumer sampling including the opportunity for suppliers,
their agency representatives, or wholesalers to pour their products, similar to what is already
permitted under the existing interpretation of off-premise regulations; and (2) reasonable
retailer entertainment. Furthermore, we urge a review of the current regulatory language to
focus on clarifying the regulations and making them consistent with modern business realities
by removing unnecessary notice and reporting requirements
Thank you for your consideration. We look forward to working with the Administration, the
Department and members of the legislature to accomplish the goal of providing a clearer and
updated regulatory structure for the alcohol beverage industry.
Respectfully,
Dwayne A. Kratt

Duplicative Regulations:

Recommend the following Public Health Code Regulations be repealed and CT adopts the FDA
Food Code. The Food Code is a national document already adopted by many states, both large
(California) and small in population (RI).

1. 19-13-B40: Sanitation of Food, Fair Grounds, Ice Plants and Trailer Coaches
(Effective 10/8/1963)

2. 19-13-B41: Sanitation of public fair grounds, horse shows, horse races, and automobile
races (effective 4/11/1973)

3. 19-13-B42 Sanitation of Places Dispensing Food or Beverage (Rev 7/3/07)

4. 19-13-B44: Sanitation of trailer coaches (effective date 3/6/1974)

5. 19-13-B48: Itinerant Food Vending and Catering (effective date 10/5/2005)

6. 19-13-B49: Catering and food service (effective date 10/3/2005)

DPH has recently reinstated the Food Advisory Committee due to the many issues with the
multiple regulations. Adoption of the FDA Food Code creates less of a burden for industry by
adopted the nationally recognized document, and will eliminate the duplicative efforts created
by Food Protection Regulations. The FDA Food Code has a train-the-trainer element and is
reviewed bi-annually. The Food Code is a national guidance document governing food safety
and has been an effective tool for over 30 years, yet CT will not accept and embrace uniform
inspections process based on the most current science governing food safety.

Respectfully,

Director of Health
Town of Wallingford, CT 06492

December 13, 2013

The Honorable Dannel Malloy
Office of the Governor
State Capitol
210 Capitol Avenue
Hartford, CT 06106


The Connecticut Hospital Association (CHA) respectfully submits the following list for
consideration in response to the Governors Executive Order No. 37, through which the
Governor asks for input on regulations that may be in need of review and revision as either
outmoded, unnecessarily burdensome, insufficient, or ineffective.

The Department of Public Health (DPH) has oversight for all of the regulation sections identified
below.

A. Specific changes are needed to Section 19-13-D3 and 19-13-D4a:

1. 19-13-D3(d)(8), the informed consent section, should be better aligned with more
recent federal requirements.

2. 19-13-D3 (I)(3), the infection control section, should be better aligned with federal
requirements, including that infection control program meetings should be held as
needed, and are not required monthly, which is unnecessarily burdensome.

3. 19-13-D4a, the regulation for childrens hospitals, is outdated and should be more
consistent with the more recently updated requirements of 19-13-D3, where
applicable.

B. The following outdated medical records provisions should be revised:

1. 19-13-D4a(d)(4); 19-13-D5(d)(4); 19a-59-1(c): The record retention period should be
changed to ten years.

2. 19-13-D5(d)(5): The timeframe for completion of medical records should be
changed to thirty days after discharge of the patient.

Governor Dannel Malloy
December 13, 2013
Page 2

C. The following regulations should be reviewed to ensure that they align with other state
laws and federal laws. Issues we identified include:

1. 19a-279-1 through 19a-279-15, inclusive. Issue: Whether these are necessary in
light of the federal rules for organ procurement. Requested action: Repeal or align
with federal requirements.

2. 19a-504c-1. Issue: Whether a patient should be required to sign his/her discharge
plan now that discharge plans are more fluid and often updated per federal
requirements. Requested action: Repeal or align with federal requirements.

3. 19a-36-A1 through 19a-36-A56, inclusive. Issue: Whether these sections are
outdated, evidence-based, and/or fail to properly reflect reliance on modernized
data collection systems. Requested action: Review for, and delete, outdated
provisions; modernize the data collection process.

4. 19a-36-D1 through 19a-36-D38, inclusive. Issue: Whether these sections are
outdated, evidence-based, and/or conflict with or duplicate federal rules and
requirements for oversight. Additionally, federal CLIA rules are being updated to
allow more flexibility in patient and provider access to lab results. Connecticuts
access rules will need to be aligned with those federal changes. Requested action:
Align with federal provisions to remove unnecessary duplication and clarify access
rights and processes.

D. The following regulations, in whole or in part, contain outdated language, incorrect or
outdated citations, or fail to align with other sections of law or the Public Health Code. Some
of the sections cite statutes that were repealed or transferred several decades ago, which
can make the regulations very difficult to understand. We believe all of the sections listed
below should be updated, unnecessary sections deleted, and the citations and references
modernized to provide accurate information on enabling and controlling statutes.

Sections 19-13-D1; 19-13-D1a; 19-13-D2; 19-13-D14; 19-13-D44; 19-13-55a; 19-13-56; 19a-
127n-1 and 19a-127n-2; 19a-490k-2; 19-13-D14; 19a-586-1 through 19a-586-3; inclusive;
19a-643-1 through 19a-643-206, inclusive; 19a-7h-1 through 19a-7h-4, inclusive; 19a-177-1
through 19a-177-9, inclusive; 19a-179-1 through 19a-179-21, inclusive; 19a-180-1 through
19a-180-10, inclusive; and 20-10-1 through 20-10-6, inclusive.

Sincerely,

James D. Iacobellis
Senior Vice President, Government and Regulatory Affairs

JDI:ljs
By E-mail

1
CONNECTICUT
National Federation of Independent Business CONNECTICUT
304 W. Main Street, #205 ! Avon, CT 06001 ! 860-248-NFIB ! www.NFIB.com/CT

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Thank you foi the oppoitunity to comment on iegulations in Connecticut anu youi effoits
containeu in Executive 0iuei # S7. NFIBCT suppoits the initiatives containeu in this
Executive 0iuei anu looks foiwaiu to an ongoing iegulatoiy iefoim effoit in the state of
Connecticut. NFIBCT has notifieu anu encouiageu oui membeiship to submit comments
on behalf of theii own small businesses, anu many of them aie uoing so.

A non-piofit, non-paitisan oiganization founueu in 194S, NFIB is Connecticut's anu the
nation's leauing small-business association. In Connecticut, NFIB iepiesents thousanus of
membeis anu theii employees. NFIB membeiship is scatteieu acioss the state anu ianges
fiom sophisticateu high technology enteipiises to "Nain Stieet" small businesses to single-
peison "Nom & Pop" shops that opeiate in tiauitional ways. NFIB's mission is "To piomote
anu piotect the iight of its membeis to own, opeiate, anu giow theii businesses."

NFIB membeis aie entiepieneuis. Nany of oui membeis staiteu theii small businesses
with an iuea. They investeu the necessaiy time, eneigy anu iesouices (incluuing peisonal
financial investments) iequiieu to stait anu giow theii business ventuie. A gieat ueal of
financial iisk is involveu with staiting anu iunning a business. Because of the challenges in
staiting anu keeping a business iunning, it is ciitical that Connecticut have a "we have youi
back" attituue towaiu small businesses in Connecticut. This is paiticulaily impoitant since
8u% of all jobs, on aveiage, aie geneiateu fiom small businesses in the piivate sectoi.

In the 2u12 euition of "!"#$$ &'()*+(( ,-./$+"( 0 ,-).-)1)+(" by the NFIB Reseaich
Founuation, "0nieasonable uoveinment Regulations" iankeu as the S
th
gieatest pioblem of
concein fiom small business owneis, up fiom its 6
th
position in 2uu6 anu its 9
th
position in
2uu4. Nuch like taxes, this geneiic pioblem categoiy costs small businesses in seveial
ways: unueistanuing anu keeping up-to-uate with compliance iequiiements, costs of
consultants, employee time, management time, uiiect outlays, lost piouuctivity anuoi
sales, foigone oppoitunities, etc. The feueial goveinment alone pioposes appioximately
1Su new iules eveiy yeai that cost business owneis ovei $1uu million pei iule in
compliance costs. Auuing state anu local laws anu iegulations that sometimes uuplicate
feueial iegulations, meiely iaise the cost anu fiustiation level foi small business. A

2
CONNECTICUT
compiehensive cost-benefit analysis of state agency iegulations anu specific attempts to
minimize the iegulatoi impact on small businesses is long oveiuue, anu foitunately,
Executive 0iuei # S7 begins to move the ball in the iight uiiection. Fuitheimoie, it is
NFIBConnecticut's sinceie hope that iefoim uoesn't enu with Executive 0iuei #S7, but
that this is meiely the beginning.

Beyonu just ieviewing both existing iegulations anu the mannei in which iegulations aie
piomulgateu, NFIBCT also suggests an examination of how iegulations aie applieu anu
enfoiceu. Specifically, NFIBCT feels that theie is a neeu foi a moie balanceu anu less
aibitiaiy appioach to iegulatoiy enfoicement. In this vein, small business owneis woulu
welcome moie euucation on behalf of the agencies ielateu to iegulatoiy compliance.

>&Q<-+7(*2 =+;*)&AA E(+*@

In auuition to the many lauuable goals containeu in Executive 0uei # S7, NFIBCT woulu
ask foi the auministiation's suppoit in consiueiing the establishment of a small business
iegulatoiy faiiness boaiu in Connecticut. The concept of a Regulatoiy Faiiness Boaiu was
fiist uiscusseu uuiing the bieakoutwoikshop poition of the uoveinoi's Economic Summit
in the fall of 2u11. The concept is moueleu aftei an existing piogiam by the 0niteu States
Small Business Auministiation anu is quite simple: Small business owneis seive on a
volunteei boaiu that ueals with matteis of iegulatoiy faiiness, paiticulaily when it comes
to compliance oi agency enfoicement matteis. Nost impoitantly, these small business
owneis act as the "eyes anu eais" of the iegulateu community, anu as such the Regulatoiy
Faiiness Boaius can holu heaiings oi iounutable events to ieceive input fiom the small
business community oi uiscuss specific iegulatoiy matteis of impoitance. The Boaiu also
can act as a liaison between the small business community anu specific agencies on
iegulatoiy matteis with a goal of establishing a moie ieasonable, balanceu anu faii
appioach to enfoicement, paiticulaily when it comes to issues of excessive fines.

Accoiuing to the 0niteu States Small Business Auministiation's 0ffice of Auvocacy, "uiving
small employeis a voice eaily in the |iegulatoiyj piocess is key to ieuucing the negative
impact of iegulations on small businesses, incieasing the level of iegulatoiy compliance,
anu passing on cost savings to state economies." That is why the uevelopment of
iegulatoiy ieview boaius is vital, paiticulaily in touay's challenging economy.

Cuiiently, seveial states (Bawaii, Naine, Nissouii, 0klahoma, anu Wisconsin, to name a
few) anu the feueial goveinment have iegulatoiy ieview boaius that, among othei things,
heai the conceins anu issues of small businesses anu auvocate on theii behalf in the
legislativeiegulatoiy piocess. Auuitionally, foui states (Aiizona, Coloiauo, Kentucky, anu
Rhoue Islanu) have iegulatoiy ieview 2-.3-#"( with similai goals. At the feueial level, a

S
CONNECTICUT
veiy successful iegulatoiy faiiness boaiu(s) is cuiiently auministeieu thiough the 0ffice of
the National 0mbuusman of the 0.S. Small Business Auministiation.

Connecticut is ceitainly stiuctuially unique with a iegulatoiy piocess that allows the
legislatuie's Regulations Review Committee to seive as a check anu balance on iulemaking
agencies. Auuitionally, the legislatuie has enacteu some positive iegulatoiy iefoim
measuies ovei the yeais that ueal specifically with enviionmental oi tianspoitation
matteis, stieamlining peimitting piocesses, anu iequiiing pioposeu iegulations to contain
a small business iegulatoiy impact statement. Bowevei, with no iegulatoiy ieview boaiu
oi othei similai piogiam to speak of, Connecticut is at a competitive uisauvantage with
othei states that have establisheu such piogiams.

K*&+A >;B& 8(* >&5;&R

0nfoitunately, theie is a geneial feeling that the neeus of Connecticut's small businesses
aie not being consiueieu enough when laws, iegulations anu new piogiams aie wiitten in
Connecticut. 0nfoitunately, new taxes, fees anu costs impact small business ievenue;
iesouices they have eaimaikeu foi giowth oi investment in theii business anu to hiie new
staff. The fewei the taxes, assessments, anu iegulations, the easiei it is to stait anu giow a
business. Some special aieas of concein follow. Aumitteuly, some of these aieas may
iequiie statutoiy changes in auuition to iegulatoiy changes, howevei the auministiation of
iegulations plays a laige pait in the oveiall piogiam(s).

S)&LB-(2L&)7 9(LB&)A+7;() 62A7&L T .&B+*7L&)7 (8 ?+,(*
R.C.S.A. S1-222-1 - 17; S1-2SS-1 - 27; S1-2S6-1 - S8

Special Assessments to Pay foi 0nemployment Insuiance 0veiages

Nany small business owneis feel that the State of Connecticut consiueis small business anu
businesses in geneial, as a souice of funus foi the State of Connecticut. 0n limiteu basis
this is fine; howevei, in iecent yeais small businesses have been consiueieu a "cash cow"
by the state. Noie than any single iegulation, an anti-business attituue, while often
unintenueu, huits small businesses because the attituue affects how all policies aie
conceiveu anu wiitten. The State of Connecticut neeus to think about business fiist not
aftei a bill oi iegulation has been passeu. They neeu to plan bettei anu buuget bettei so
that they uon't neeu to assess special taxes on businesses in CT. The tax assessments aie
buiuensome to businesses, anu not buugeteu foi by businesses. The impact of the special
assessments limits hiiing in CT as they attach eainings that coulu be useu foi othei
puiposes. Also, the State of Connecticut shoulu not ioll all businesses into one. Small

4
CONNECTICUT
businesses uo not have the same financial iesouices as the big guys. They aie much moie
financially fiagile; consequently the impact of goveinment policies on them is significantly
gieatei.

Relateu to special assessments is the neeu to oveihaul the unemployment insuiance
piogiam in Connecticut. What was oiiginally intenueu as a safety net has giown to a
piogiam that is out of touch with the neeus of Connecticut's employeis, paiticulai small
employeis. The following is a list of the issues with the piogiam, how the piogiam impacts
small businesses anu what neeus to be changeu to fix the piogiam.

What is wiong with the 0nemployment Insuiance piogiam.

Small businesses aie having a uifficult time hiiing qualifieu people. Theie is veiy little
incentive foi canuiuates in Connecticut to apply foi jobs oi woik if they aie able to make
the same money oi neaily the same collecting unemployment as they can by woiking. The
incentive to woik has been impacteu by cuiient policies.

If someone is laiu off anu they aie given 26 weeks of unemployment compensation (as in
the past), the unemployeu aie moie motivateu to get out anu finu a job anu quickly because
theii unemployment benefits aie limiteu. The piioi piogiam motivateu the woikei anu it
limiteu the expense foi the State of Connecticut anu businesses. Bowevei, uuiing the
iecession, the benefit peiiou was extenueu to 99 weeks. The extension has placeu a huge
financial buiuen on businesses as the costs go on anu on without ielief, paiticulaily those
who have hau to lay off staff. The taxes impact the ability foi businesses to hiie again. The
longei they pay the taxes, the longei it takes them to hiie, anu the pioblem iemains cyclical.
It is obviously veiy uifficult to pay the taxes anu hiie new people.

The unintenueu consequence of the cuiient piogiam is that many qualifieu woikeis uon't
want to woik. They want to stay home anu collect theii benefits until the benefits aie
closei to iunning out. The othei negative consequence to this is many qualifieu woikeis
become unqualifieu as theii skills aie not being maintaineu, anu potential employeis aie
conceineu by theii long absence fiom the woikfoice. Sauly, the iesult is that many
unemployeu woikeis have become peimanently unemployable; paiticulaily those in theii
late Su's anu 6u's. Nany of the long-teim employeu may have also hau to obtain othei state
benefits, which coulu have been avoiueu if the piogiam weie shoiteneu. This is not goou
foi Connecticut oi the unemployeu.

Solution

Encouiage laiu off woikeis to go back to woik by limiting the benefits to 26 weeks oi
theieabouts. Encouiage them to take pait-time woik to extenu theii unemployment

S
CONNECTICUT
benefits. At piesent, the unemployeu aie uiscouiageu to woik pait-time as it loweis the
amount of theii benefits. Stiengthen the iequiiements, oveisight anu veiification of woik
seaich by those who aie unemployeu.

Woiking pait-time woulu keep woikeis in the woik foice anu leau to full-time woik, not
cieate a population of peimanently unemployeu woikeis. It woulu also motivate
canuiuates to apply foi pait-time oi entiy level jobs, as it woulu not impact theii
unemployment iate. This woulu benefit the unemployeu anu businesses. Bowevei, it is
ciitical to iequiie pioof that the unemployeu aie looking foi woik anu iequiie that they
woik pait-time oi volunteei to keep engageu in the community while they aie seeking
employment.

If an employee is fiieu foi theft oi failing to follow theii employment agieement, etc. they
shoulu not be offeieu unemployment. Theie neeus to be peisonal iesponsibility when
woikeis accept positions. We shoulun't incentivize bau job peifoimance. When this
occuis, businesses pay taxes foi woikeis that uiu not peifoim as expecteu. This isn't
"having the back" of the small business anu uoesn't teach peisonal iesponsibility.
Remembei, businesses uon't want to fiie woikeis. It costs them money. When an
employee is let go, oveiwhelmingly, it is foi goou ieason.

0thei 0nemployment Compensation Issues
R.C.S.A. S1-222-6 - 7
This section has been ienueieu obsolete as a iesult of P.A. 1S-288 anu shoulu theiefoie be
mouifieu as appiopiiate.

#7%&* DAA<&A

Some othei issues impacting small businesses incluue:

?;:&)A;)Q - This geneiic pioblem applies acioss many state agencies. License fees aie
simply a tax by anothei name. The fiequency of the papeiwoik iequiiements is anothei
time anu compliance buiuen. 0ne suggestion is to extenu out licensing ienewals to longei
time peiious. Extensions will ieuuce papeiwoik anu costs foi small businesses anu
auministiative woik by the State of Connecticut. Teims coulu be S oi 1u yeais as opposeu
to annually oi semi-annually.

/*(B&*72 "+G =;-;)QA U Tax filings shoulu be baseu on the most iecent yeai's feueial tax
filing to align uepieciation scheuules anu iepoiting iequiiements. Nost small businesses
opeiate on a calenuai yeai so this woulu save consiueiable time, effoit anu accounting fees.
Foi example insteau of filing 9Su1S anu again at yeai-enu, it coulu be uone on 12S11S.

6
CONNECTICUT

.<B-;:+7& +)@ (5&*-+BB;)Q *&V<;*&L&)7A ,2 A7+7& +)@ 8&@&*+- +Q&):;&A - Theie aie
many aieas wheie state anu feueial oveisight(s) anu iequiiements aie uuplicate anu thus,
not only buiuensome, but unnecessaiy. Foi auministiative anu compliance ease,
Connecticut shoulu unueitake a ieview of aieas wheie is may make sense foi the state to
simply uefei to the feueial oveisightiequiiements iathei than uuplicate a
piogiamiequiiement. Foi example, why aie theie sepaiate uiug iegistiations foi both
the State of Connecticut (Bepaitment of Public Bealth) anu the feueial goveinment (Biug
Enfoicement Auministiation). Why not just simply iuentify naicotics piesciibeis by theii
feueial licenses anu skip state iegistiations.

W'(<A&%(-@;)QX (8 A7+7& 8&&A 8(* AL+-- ,<A;)&AA&A - The state shoulu look towaiu
pioviuing small business owneis the ability to fill out one foim, anu wiite one single check
(oi EFT), to pay each anu eveiy fee that may be iequiieu of them on an annual basis. Foi
example, the business entity tax, license ienewal fees, etc., coulu all be paiu at one thiough
one check oi EFT by a small business. This pievents small business owneis fiom having to
make multiple payments to multiple state agencies at multiple times anu keep tiack of
multiple pieces of papeiwoik.

Rev. 6/16/10 1
STATE OF CONNECTICUT DEPARTMENT OF PUBLIC HEALTH
DRINKING WATER SECTION
www.ct.gov/dph/publicdrinkingwater

WATER COMPANY LAND PERMIT APPLICATION

This application must be submitted when a water company intends to sell, lease, transfer or assign Class I or II
water company land or intends to change the use of Class I or II water company land per Connecticut General
Statutes (CGS) Section 25-32. The following information should be supplied by the current administrative
official of the water company. Refer to the Regulations of Connecticut State Agencies (RCSA) Sec. 25-37d-1
through 9 for information on the water company land application review process. Electronic submission of
applications and attachments is permissible, provided that the applications include signatures.

Section A. Public Water System and Applicant Information

PWS Name:
Project Name:
Project Address:
PWSID Number: CT PWS Type (select one): Community NTNC TNC
Town: DPH Project Number (if known):

Print Name of PWS Administrative Official:
Title:
Address:

Phone Number:
Fax Number:
E-mail Address:

Name of Consultant (if applicable)
Company Name:
Address:

Phone Number:
E-mail Address:

Rev. 6/16/10 2

Section B. Basis for Requesting Approval or Permit (select all that apply)

Formal Enforcement Action (Administrative Order, Consent Order, Notice of Violation (Civil Penalty))
Violation Identified in Sanitary Survey Report
Project Identified in Approved Water Supply Plan
Federal or State Grants or Loans DWSRF STEAP Funds STAG Funds
Proactive (system improvements or enhancements)
Other:

Section C. Type of Approval or Permit Requested (select all that apply)

Water Company Land Sale, Lease, Transfer or Assignment (Complete Sections D, E and G)
Check one of the following: Sale Lease Transfer Assignment
Water Company Owned Lands Change in Use (Complete Sections D, F and G)

Section D. Project Description
Provide a general summary of the proposed project, including the total acreage of each class of water
company land to be disturbed or the total acreage of each class of water company land which will be subject to
the sale, lease, transfer or assignment or change in use. Refer to CGS Sec. 25-37c for land classification
definitions. You may attach additional sheets, if necessary.

Section E. Supporting Information- Sale, Lease, Transfer or Assignment
Each of the following items should be labeled with the section and number (i.e. Section E #4). If the item is
not applicable, provide the number and indicate N/A.
1. Provide a scaled site plan that shows all water company land to be sold, leased, transferred or assigned.
2. Indicate the proposed methods of protective restrictions and enforcement the applicant or other parties
will impose on the parcel to be subject to the permit. (If restrictions do not apply uniformly throughout a
parcel, attach a map that shows the restrictions that apply to each portion of the parcel.)
3. Provide a draft copy of the sale, lease, transfer or assignment agreement.
4. Provide copies of the notification letter sent to the chief elected and chief executive officials of the towns
in which the proposed sale, lease, transfer or assignment will occur. Submit both sides of the certified
mail green return receipt or United States Postal Service delivery confirmation.
5. Provide a copy of the Capacity Evaluation for Water Company Purchase, completed by the entity to
which the land will be sold, leased, transferred or assigned.
6. Provide copies of any deed restrictions or variances.
7. If the applicant is required to prepare a water supply plan pursuant to CGS Section 25-32d, indicate
whether the proposed sale, lease, transfer or assignment is consistent with the current approved plan.
8. Provide the sale of a source notification letter required by CGS Section 25-33l and any subsequent
correspondence, if applicable.
9. For the lease of Class I water company land associated with groundwater sources, provide copies of the
sanitary easements indicating restrictions within the affected sanitary radius.

Rev. 6/16/10 3

Section F. Supporting Information- Change in Use
Each of the following items should be labeled with the section and number (i.e. Section F #4). If the item is
not applicable, provide the number and indicate N/A.
1. Provide a final scaled project site plan including existing conditions, horizontal and vertical extent of site
disturbance including access and permanent and temporary land disturbance. Describe the nature and
necessity of the impervious materials used at the site (i.e. pavement). Include any evaluation conducted
to determine the impact of the impervious area on the recharge of the water supply sources.
2. Provide copies of the notification letter sent to the chief elected and chief executive officials of the towns
in which the proposed project is located. Submit both sides of the certified mail green return receipt or
United States Postal Service delivery confirmation.
3. Provide a brief outline of the project (i.e. site preparation, demolition, construction, stabilization); include a
spill prevention and emergency response plan or drinking water quality management plan.
4. Indicate the proposed methods of protective restrictions and enforcement that the applicant or other
parties will impose on the parcel to be subject to permit, and demonstrate that such change will not have
a significant adverse impact upon the present and future purity and adequacy of the public drinking water
supply. (If restrictions do not apply uniformly throughout parcel, attach a map which shows the
restrictions which apply to each portion of the parcel.)
5. Indicate alternatives that were considered and why this option was chosen.
6. Describe the benefit to the water system as a result of the proposed change to the water company land.
7. Provide copies of any deed restrictions, variances or permits required by other regulatory agencies.
8. Provide a copy of the Revocable License Agreement, if applicable.
9. If any part of the sanitary radius of a groundwater source wellhead is owned by another entity, provide
copies of the sanitary easements, if applicable.
10. If the applicant is required to prepare a water supply plan pursuant to CGS Section 25-32d, indicate
whether the proposed change in use is consistent with the most current approved plan.
11. Describe the short and long term land improvements designed to protect the water source(s), such as
primary or secondary stormwater treatment, addition of native vegetative buffers or other low impact
development management practices.

Section G. Certification Statement

I certify to the best of my knowledge that the information provided in this application is complete and correct. I
understand that the information I provide will be used by the Department of Public Health, Drinking Water
Section to determine if a Permit for the Sale, Lease, Transfer or Assignment or Change in Use of Water
Company Land can be granted.

Signature of PWS Administrative Official Date

Name of PWS Administrative Official (print or type) Title

Page 1 of 6

To: Office of Governor Dannel P. Malloy

From: Betsy Gara
Executive Director, COST

Date: December 16, 2013

Re: Executive Order No. 37 - Outdated, Unnecessarily Burdensome, Inefficient or
Ineffective Regulations

Thank you for the opportunity to assist your office in identifying regulations and policies
which are outdated, unnecessarily burdensome, inefficient or ineffective. The Connecticut
Council of Small Towns (COST) applauds your continued efforts to improve the efficiency of
state government.

Comptrollers Office
Resident State Trooper Program
Municipalities recently received notice that the state was increasing the fringe benefit rate
associated with overtime paid to resident state troopers. Unfortunately, towns were not informed
of this change in policy until after their local budgets were adopted and these amounts were not
budgeted. Notice of changes in the fringe benefit rate after local budgets have already been
adopted is an ongoing issue.

Moreover, there continue to be questions regarding how the fringe benefit rate is calculated. It is
our understanding that the new fringe benefit rate includes an increase to cover the costs of
pensions for the entire state police department, which unfairly penalizes Connecticuts small
towns.

The resident state trooper program has been in place for over 60 years. Over the years, more and
more small towns have chosen to utilize resident state troopers to provide greater public safety
protection to their citizens. In fact, of the states 1,200 troopers, 117 are resident troopers
assigned to specific towns. Although the cost to communities has gone up to 70 percent, it has
still been viewed as the best way for small communities to have a strong law enforcement
presence.
COST urges that concerns regarding the fringe benefit rate be addressed to ensure that
communities can appropriately budget and afford continued participation in this program.
Page 2 of 6

Municipal Employees Retirement System
Pension and benefit costs are increasingly driving up municipal budgets. For municipalities
participating in the Municipal Employees Retirement System (MERS), this is due to inequities in
how the system is funded. According to the Office of Legislative Research, the employee
contribution rate has not changed since MERS was established in 1947.

State law caps the municipal employee contribution rate at 2 % of earnings subject to Social
Security taxes or 5% of earnings not subject to Social Security taxes. In the past 12 years,
however, the employer contribution rate has been increased 12 times.

As a result, from FY 02 FY 12, for employees covered by social security, the employer share
for regular employees has increased from 37% to 70% and from 35% to 75% for hazardous duty
employees. For employees not covered by social security, the employer share for regular
employees has increased from 55% to 84% and from 63% to 88% for hazardous duty employees
for the same time period.

This imbalance in funding the Municipal Employees Retirement System is straining the budgets
of municipalities, forcing reductions in critical services or increases in property taxes.

COST supports efforts to increase the employee contribution by 1% annually over the next three
years for a total increase of 5.25%. This is a modest proposal which will more equitably fund the
system and ensure its continued financial viability.

Connecticut Siting Council

Annual Municipal Reports Section 7-163b, CGS
Current law requires annual municipal reports to be filed with the Connecticut Siting Council.
COST recommends that this provision be repealed. The report requires municipalities to report
on the location, type and height of each existing telecommunications tower and each existing and
proposed antenna subject to local jurisdiction. Municipalities generally dont have this
information readily available and the Council refers towns to its database for the information.
Inasmuch as the Council already has this information and is the permitting authority of record,
the annual reporting requirement is unnecessary.
State Department of Education
Minimum Budget Requirement
The state enacted the Minimum Budget Requirement (MBR) and, formerly, the Minimum
Expenditure Requirement (MER) to ensure that towns appropriate the statutorily set foundation
level for each student. In addition to supporting legislation to provide towns with greater
flexibility to reduce costs under the MBR, COST recommends that concerns be addressed
regarding the administration of the MBR, specifically, the waiver process.

Under the current process, the state Department of Education may provide waivers from the
MBR under certain circumstances. However, if towns are successful in achieving savings from
negotiating health insurance contracts or sharing services with other communities, it is our
Page 3 of 6

understanding that SDE will not authorize a waiver. Instead, it will determine whether the town
is subject to forfeiture penalties. The State Board of Education may provide a waiver from the
forfeiture penalties for good cause, however, putting towns in the position of having to gamble
whether they will be penalized for achieving cost savings. In view of efforts to promote cost
savings on the municipal level, these provisions should be revised to authorize the SDE to issue a
waiver if a town can demonstrate that it has achieved costs savings without undermining
educational programs.
Department of Emergency Services & Public Protection (DESPP)
Public Safety Answering Points Consolidation
COST recognizes that consolidation will help reduce costs. However, concerns have arisen regarding
how consolidation may impact public safety in our communities. DESPP should utilize a process in
which towns are partners in a state-facilitated process rather than state-mandated process - to encourage
PSAPs to regionalize. COST continues to support an incentive-based approach to encourage the
consolidation of Public Safety Answering Points where appropriate and involve municipalities in
decisions regarding consolidation.

Trooper Barracks - Consolidation
DESPP is undertaking the consolidation of trooper barracks in an effort to reduce state costs.
Concerns have arisen regarding how this may impact public safety in our communities. Again,
we believe that many of these issues could be addressed by involving municipal officials as
partners in discussions about how to achieve consolidation without jeopardizing public safety in
our communities.

Issuance of Firearm Permits
Under current law, chiefs of police or wardens are authorized to issue firearm permits. However,
many smaller communities do not have organized police departments. We therefore recommend
that this provision be revised to authorize the chief elected officials of the municipality to
designate a state trooper as the issuing authority for firearm permits.

Department of Labor

Prevailing Wage
COST has long supported increases to the prevailing wage thresholds, which are statutorily set.
There other issues relative to the regulation of prevailing wage laws that may be addressed
administratively.

Recently, some towns have been advised by legal counsel that they cannot accept donated labor
because it would violate the states prevailing wage requirements. Small towns and cities often
rely on volunteers to provide services that benefit the community. COST supports efforts to
clarify that municipalities are permitted to use qualified (duly licensed) volunteers who are
willing to donate labor on projects subject to prevailing wage laws.

In addition, the state should explore ways of more accurately determining wage rates. Under the
current process, the state adopts wages as determined by the federal Department of Labor. While
this may be a cost-effective approach, it results in some disparities. For example, why are the
Page 4 of 6

labor rates for performing work on a multimillion dollar facility the same as the wage rates for
renovating or constructing a salt shed or locker room? The current process for determining
building wage rates disproportionately increases the costs of relatively small projects.
Emergency Medical Services Primary Service Areas
COST supports efforts to overhaul the process for 1) designating and changing primary service
areas and 2) by which municipalities can petition to change or remove a primary service area
responder. Although a task force has been convened to develop recommendations to address this
issue, given the importance of this issue to the safety and health of town residents, we believe it
addressing this should be an administrative priority.

Non-Transient Community Water Systems Approval Process
The process for obtaining approval for non-transient community water systems, e.g. convenience
stores, coffee shops, is very time-consuming, undermining local economic development
initiatives. While we understand that staff and resources at the department are limited, the delays
in processing these applications must be addressed.

Change of Use Permits Section 25-32, CGS; Section 25-37d-1, RCSA
COST supports narrowing the definition of activities that warrant a Change of Use permit from
the state Department of Public Health to exclude activities that are performed to maintain or
upgrade municipal water systems. Under the current process, DPH requires a change of use
permit for anything that constitutes one shovel of dirt. This captures a wide range of routine
activities that require municipal water staff to submit a permit application and accompanying
information, see attached, to DPH and wait for approval to perform certain maintenance tasks.
In addition to unnecessarily tying up the resources of municipal staff, this requirement also
delays projects that need to be completed under certain weather conditions or during certain
times of the year.

Reimbursement Formula for Potable Water Systems Section 22a-471-1, RCSA
COST recommends revisions to Section 22a-471-1, RCSA, to update the formula for allocating
funding to assist communities with areas served by contaminated wells. Under the existing
formula for reimbursing municipalities that must install water systems to provide potable water
to residents, reimbursement is limited to smaller-sized pipes to meet the short-term needs of the
resident. This is an inefficient reimbursement method because if reimbursement could be used to
install pipes sized to provide sufficient water capacity to these areas, residents would have a
long-term solution to water supplies need for public health and fire protection. For example, this
is currently an issue in the Town of Durham, which is struggling to address contamination issues
resulting from a superfund site.

Water Quality and Treatment Projects Sec. 25-33a, CGS; Section 25-33b-1-5, RCSA;
Section 16-1.59b, RCSA
These provisions were enacted by the state to implement the Safe Drinking Water Act in the
1970s. COST recommends updating the regulations to ensure that this program is a viable
mechanism for assisting communities in meeting water supply needs.
Page 5 of 6

Public Utilities Regulatory Authority (PURA)
Telephone Pole Attachment Process
The process for negotiating telephone pole attachment agreements is extremely cumbersome and
confusing. The lack of a central, statewide pole administrator 1) undermines the coordination of
storm response efforts; 2) creates confusion regarding pole relocations in connection with street
projects, such as street widening and tree trimming; 3) subjects municipalities to duplicative fees
and inconsistent contractual obligations; 4) and impedes the ability of municipalities to connect
to the states Nutmeg Network.

COST strongly supports the appointment of a single, statewide pole administrator to assist
municipalities in: 1) Negotiating municipal attachment agreements; 2) Developing a database
that assists municipalities and other stakeholders in identifying pole locations; 3) Providing
towns with assistance in preparing and submitting applications; 4) Addressing concerns
regarding communication between pole owners and attachers; and 5) Resolving issues that may
impede municipal access to the states Nutmeg Network a public broadband fiber network.
In addition, COST supports efforts to move to a single software/database system that could be
administered by the Single Pole Administrator, such as the NOTIFY system currently in use by
CL& P.

Recognizing these concerns, the Public Utilities Regulatory Authority has initiated a docket to
determine whether to proceed with a single pole administrator. We urge support to make
resolution of this issue an administrative priority.

Department of Revenue Services

The state Department of Revenue Services should clarify via regulations that the state and
municipal real estate conveyance tax is applicable to an entire land transaction. Currently, some
real estate developers have taken advantage of an apparent loophole in the law by selling the land
in a separate transaction from the sale of the residence built on the land in order to reduce the
liability of the real estate conveyance tax.

COST supports efforts to increase Medicaid reimbursement levels for emergency ambulance
transportation services. Because reimbursement levels were reduced in previous years,
municipal employers have had to shoulder more of the costs for this care. This is a particular
problem in rural areas where patients have to be transported over a large geographic area.
Shifting more costs onto already escalating municipal health insurance premiums is imposing a
significant burden on small towns and cities.
Department of Transportation
The process for obtaining approval from the state Department of Transportation (DOT) on road
and bridge projects is very time-consuming, delaying projects.
Page 6 of 6

A new law adopted last session may help address some of these issues. The act created a local
transportation capital program to allow DOT to request authorization of special tax obligation
bonds to provide funding to municipalities or local planning agencies for state or municipal road
and facility improvements. We will continue to solicit input from our members regarding
specific concerns with the approval process for roads and bridges and provide you with more
detailed information on this issue.
Municipal Economic Development Projects
Municipalities often find it difficult to move forward with various municipal economic
development projects given the number of approvals required from various state agencies.
Smaller communities would certainly benefit from efforts to create a one-stop shopping
mechanism to assist municipalities in obtaining technical expertise and direction in addressing
concerns resulting from the oversight of multiple state agencies.
COST will continue to solicit input from its members regarding burdensome or
inefficient regulations to assist your office in its efforts to improve the administration of various
programs and services. If you have any questions, please contact me at 860-841-7350.
Thank you for the opportunity to comment.

Connecticut Council of Small Towns
1245 Farmington Ave., 101
West Hartford, CT 06107
Tel. 860-676-0770; bgara@ctcost.org
www.ctcost.org

December 16, 2013

Governor Dannel P. Malloy
State Capitol
210 Capitol Avenue
Hartford, CT 06106

Re: CCPA Comments to Executive Order #37, Streamlining State Regulations


The Connecticut Community Providers Association (CCPA) appreciates the opportunity to
comment on Executive Order #37, which aims to streamline state regulations and recall or review those
regulations that are duplicative, outdated, unnecessarily burdensome, inefficient or ineffective. We
believe this is an important first step towards ensuring that all regulatory benefits justify their costs.

CCPA is the premiere state trade association representing organizations that provide health and human
services and supports for children, adults and families in the areas of mental health, substance use
disorders, developmental disabilities, child and family health and well being, and other related issue
areas. Community providers deliver quality health and human services to 500,000 of Connecticuts
residents each year, ensuring compliance with DMHAS, DCF, DSS, DPH, and DDS regulations throughout
each step of the way. However, over many years, and with the implementation of ACA and focus on
accountability and payment structure reform, administrative burdens upon behavioral health providers
have grown enormously and without coordination.

Administrative burdens are, in some cases, duplicative across state health and human service agencies
and often layered upon each other. While oversight, accountability, licensing, data collection, payment
reform, outcomes and other contractual and regulatory requirements are necessary and welcomed by
the provider community, the lack of regulatory cohesion is concerning and must be addressed in order
to refocus efforts towards providing the highest quality and most cost-effective services possible.

Within this context, CCPA supports Executive Order #37 and respectfully submits the following list of
regulatory barriers experienced by nonprofit community providers:

1. DATA REPORTING REQUIREMENTS: Data reporting requirements across state health and human
service agencies are overwhelming nonprofit providers, as each agency has developed its own set of
standards, resulting in a wide range of data being collected, and perhaps underutilized, by multiple
agencies.

CCPA Comments to EO #37 2

Issues associated with multiple data reporting requirements are compounded by the recent trend in
utilizing evidence based treatment models and electronic health records. For example, a recently
released RFP by a state agency required the use of an evidence based practice (EBP), electronic
health records system that meets national standards, and the utilization of the GAIN assessment
system. Given that EBP have proprietary data reporting requirements, a provider interested in
pursuing such an RFP would be required to submit four different data sets to (1) the state agency,
(2) the EHR system, (3) the proprietor of the EBP, and (4) GAIN.

It is proposed that data reporting requirements are streamlined across all state health and human
service agencies (DCF, DPH, DMHAS, DSS) in order to effectively allocate provider resources and
ensure that only necessary, useful data is being reported and utilized with the goal of improving
service provision.

2. LICENSING REQUIREMENTS: Lack of coordination between state agencies that license and fund
behavioral healthcare organizations is a barrier to service provision. Currently, nonprofits that
provide substance use services must be licensed by DPH. Additionally, if a provider also serves both
children and adults with co-occurring mental health and substance use disorders, they must be
licensed by both DMHAS and DCF.

These multiple licensing requirements pose structural barriers for providers who employ a holistic,
family centered approach in which they attempt to integrate both mental health and substance use
services for adults and children. The division of mental health and substance use licensing
perpetuates the division between services rather than recognizing that individuals are increasingly
being diagnosed with co-occurring disorders such as depression and substance use. Furthermore,
the volume of licensing reviews and redundancies in such reviews is a burden to providers in terms
of resources and time.

It is proposed that the licensing of mental health and substance use services be reviewed and
streamlined, if possible, to ensure consistency when serving children and adults with co-occurring
behavioral health disorders.

3. AUDIT REGULATIONS: Multiple and overlapping audit requirements are a barrier to service
provision for nonprofit community providers, as providers dedicate much time and resources to
ensure compliance with each audit, including those by: DSS, DCF, DPH mental health audits, DPH
substance use audits, or ECC audits. Multiple, overlapping audits have far reaching implications for
all nonprofit community providers, considering that audit penalties can often result in thousands of
dollars owed back to the state by providers. The stakes are higher for providers with multiple sites,
as each site is required to undergo an individual review process, which may take anywhere between
one month to an entire year to complete. It is proposed that the state review all audit requirements
for nonprofit community providers to identify and address overlaps, inconsistencies, or
redundancies within the state auditing processes.

4. REGULATIONS REGARDING PRIVILEGES AND DISCLOSURES: Behavioral health organizations must
comply with HIPAA, 42 CFR Part 2 (the substance abuse confidentiality regulations) (Part 2) and
the Connecticut mental health privileges. Chapter 899 of the CT statutes contains language
regarding privileges and disclosures. With healthcare reform and the focus on coordinated and
integrated care, the CT statutes provide challenges to doing so, especially around referrals and
following-up with referral sources. Once a referred individual is seen, authorizations can generally
CCPA Comments to EO #37 3

be executed, if the client agrees to do so. This differs from other types of health providers,
physician practices etc. that need to comply with HIPAA, (which allows for disclosures for treatment
purposes or coordination of care), but not with these other CT state statutes. The CT regulations
pose a barrier to coordination of care which is not in line with healthcare reform.

5. INTEGRATION OF BEHAVIORAL AND PHYSICAL HEALTH SERVICES: Co-location of behavioral health
services in primary and other health care settings provides improved, integrated care for individuals
with co-occurring physical and behavioral health conditions, resulting in better outcomes. Current
DPH licensure regulations restrict clinic practice to physical locations specifically approved by the
Department. There is no provision- short of full licensing of a new site- for the deployment of
clinical resources from a licensed clinic to an off-site location in order to facilitate coordination of
care and the delivery of services in the most appropriate setting for the patient.

Precedent for the provision of off-site services by a licensed clinic can be found in the Department
of Children and Families licensure regulations for Outpatient Psychiatric Clinics for Children. In the
Departments regulations clinic off-site services are defined as follows:
Clinic services provided at a location which is not physically a part of the licensed clinic
but whose services emanate from the licensed clinic. Such locations may include the
recipients home, acute care hospital, school, recreational center or similar provisional
location. Off-site services do not require separate licensing but shall be specified in the
licensing process as locations where services are provided.

It is proposed that the Public Health statutes governing the licensure of psychiatric clinics for adults
and the licensure of facilities for the treatment of substance abusing persons be amended to allow
licensed clinics to provide off-site services in a similar fashion as is provided for in the DCF
licensure regulations, with specific reference to physician offices and other health care settings.

Thank you very much for your consideration. CCPA looks forward to working in collaboration with the
administration to address the abovementioned regulatory concerns of nonprofit community providers.

Sincerely,

Brunilda Ferraj, MSW
Public Policy Specialist
Connecticut Community Providers Association (CCPA)
35 Cold Spring Rd, Suite 522
Rocky Hill, CT 06067
860-257-7909 (P)
860-257-7777 (F)
bferraj@ccpa-inc.org

To: Office of Governor Dannel P. Malloy
From: Guy Russo
President, Connecticut Water Works Association (CWWA)
Re: Public Comments - Executive Order No. 37
Outdated, Unnecessarily Burdensome, Inefficient or Ineffective Regulations

Thank you for the opportunity to submit comments in response to Executive Order No. 37
regarding outdated, unnecessarily burdensome, inefficient or ineffective regulations. The
Connecticut Water Works Association (CWWA) commends your efforts to identify opportunities
to eliminate and/or update burdensome regulations.

Our members, who are comprised of municipal water departments, private water companies
and regional water authorities, identified the following laws and regulations that are outdated,
burdensome or otherwise inefficient.

Recognizing the value of periodically reviewing and updating agency regulations, we encourage
you to consider adopting a process that allows for public comment on a regular basis.

We would further note that there are some cases where the concern may not be with the
regulations as written, but with the interpretation or application of the regulations by agency
staff. There is often an unwillingness by agency staff to find a practical interpretation of the
regulations, and an overreliance on a literal read that may not meet the regulatory intent or
lead to a reasonable application. There can also be an escalation of expectations by agency
staff that may lead to a request for information that is inconsistent with the regulations or their
intent. These issues may not be able to be remedied with a rewrite of any particular
regulation, but must be addressed by setting clear expectations for agency staff so they do not
overreach their authority.

Water Planning State Department of Public Health

1. Water Supply Plans Section 25-32d-3, Regulations of Connecticut State Agencies
(RCSA)

Recommendation: Address delays in reviewing and approving Water Supply Plans, which
are required to be prepared and submitted to the state Department of Public Health (DPH)
by water companies serving 1,000 or more persons, by 1) narrowing the scope of the plans
to data that is relevant to water supply planning; 2) standardizing the format for plan
Page 2 of 11

submittals; 3) eliminating requests for information which are already on file with DPH; and
4) ensuring that plans are reviewed and approved within one year from submittal.

Rationale: The Water Supply Plan is a long range planning document which includes an
analysis of present and future water supply demands based on a fifty-year planning horizon.
Although it is a useful planning tool, the format and approval process must be streamlined
and standardized to ensure that the data is useful and in a format that certain water supply
data made publicly available to support statewide water use planningIt is not necessary or
appropriate to require information in the plans that is already available and provided to the
department through routine reporting or ongoing regulatory inspections. Recapping all that
data in a single place is simply not necessary.

Under the current process, water companies may wait from one to four years to obtain
approval of its water supply plan from the state Department of Public Health (DPH), with
some companies waiting as long as 6 years. Even more frustrating, however, is that once
the plan is submitted to DPH, DPH is taking several months to several years to make the
initial review and request additional information/clarification from the water companies.
Although DPH acknowledges these concerns and has made some progress in addressing
them, continued delays result in situations where companies are asked to provide
additional information on system components that have changed considerably. In addition,
staff or consultants may have changed, requiring companies to expend considerable
resources to piece together the information DPH is requesting. DPH also requires that the
information requested be provided in 30 days. Moreover, DPH is requesting responses to
comments on issues that had already been approved in previous plans, on issues that have
already been resolved since the plan was submitted, or on activities that occurred following
the submittal of the plan.

The current process imposes significant and unnecessary costs on both water companies
and DPH staff, who are required to expend countless hours and thousands of dollars
completing, updating and reviewing water supply plans that include information which is
irrelevant, outdated or redundant. Water companies identified numerous examples of
irrelevant and outdated data required to be provided, including:
Fire flow test data Rather than require summary data regarding fire flow testing, the
department has required complete fire flow test data, which is a significant quantity of
information that is not relevant to water supply planning
Dam surveys, inspection reports, which are already provided to the department
Storage tank inspection reports
Sizes of chemical feeds, tanks, plant schematics, details of meter replacement program
Size, type, age, material & condition of piping by street
Tables to monitor when water distribution pipes are replaced by street address, future
main replacements and when radio read meters are to be installed
Survey of the tops of each well and comparison to 100-year elevation
Page 3 of 11

Redundant information such as a distribution map, service map, easement descriptions
and maps, which were already provided to the department
Copies of studies that have been submitted to DPH
Operator Certifications which are already on file with DPH

CWWA appreciates DPHs efforts to initiate a process to reformat the water supply plans.
However, this effort has been bogged down for a variety of reasons. Given the considerable
amount of department staff time that must directed to the review and approval of these
plans, standardizing the format, narrowing the scope of the plans and ensuring timely
reviews and approvals, should be a top priority. Addressing these issues will also help
address concerns regarding the process for reviewing the plans to determine whether
certain water security related information may be disclosed under the state Freedom of
Information Act.

2. Connecticut Plans for Public Water Supply Coordination Section 25-33, CGS; Section
25-33h-1, RCSA

Recommendation: Review the regulations for Public Water Supply Coordination to 1)
streamline the process; 2) consolidate the Public Water Supply Management Areas; and 3)
ensure that plans are completed and approved for the entire state.
Rationale: It is essential for public water utilities to be able to adequately plan for the
current and future water supply needs of the customers and communities they serve.
There are existing mechanisms in place in Connecticut that require water companies to
prepare individual water supply plans and authorize the development of a coordinated
approach for a broader state plan under the Water Utility Coordinating Committee (WUCC)
process. Although the WUCC governing laws have been in effect since 1985 and various
plans have been filed, the implementation has fallen far short of expectations.

To date, only 4 of the 7 defined areas (WUCCs) for state water planning have been
convened and only 1 plan has been approved. Unfortunately, the lack of coordinated
planning for public water supplies has created a significant gap as the state strives to
develop a Statewide Water Plan because these efforts should serve as the cornerstone of
any broader state planning efforts.

DPH Regulatory Reviews and Processes
3. Change of Use Permits Section 25-32, CGS; Section 25-37d-1, RCSA

Recommendation: Limit the activities that trigger a Change of Use permit from the state
Department of Public Health to land use activities that are substantially different from the
current use of the property for water supply purposes or activities that could potentially
affect the purity and adequacy of the potable water supply. Maintenance and/or upgrades
to existing water utility infrastructure should not require a permit.

Page 4 of 11

Rationale: Under the current process, a wide range of routine activities may trigger a
request for a Change of Use permit. For example, stone revetment, which is performed to
protect embankments from erosion, as well as the installation of underground electrical
wires to a wellfield to prevent storm damage, have been considered a change of use by the
department. In fact, the Department has frequently used the guideline of one shovel of
dirt disturbance at a wellfield as requiring a change of use permit. However, none of
these activities are a change of use but necessary activities to maintain or protect the
system. In addition, the installation of a replacement well should not be considered a
change of use since it is replacing a well that has already been approved and the activity is
for water supply purposes. However, DPH requires a Change of Use permit for this activity.
The breadth of information required to be submitted as part of the Change of Use
Application, see Appendix I, is simply not appropriate given the routine nature of many of
these activities the department considers a change of use. The department should limit the
scope of activities that trigger the permit requirements which would free up staff to focus
on core public water supply oversight tasks.

4. Expedite Permit Processing and Other Approvals

Recommendation: Develop a Licensed Water Professional Program to assist state agencies
in processing permits and approving water supply plans in a timely manner.

Rationale: CWWA supports the creation of a Licensed Water Professional program,
modeled after the successful Licensed Environmental Professional program administered by
the state Department of Energy and Environmental Protection, which has streamlined
certain regulatory approval processes related to brownfields remediation. The program has
expedited brownfields remediation while significantly reducing state costs by reducing the
administrative burden on staff at the state Department of Energy and Environmental
Protection (DEEP) to process such approvals.

CWWA supports legislation to authorize Licensed Water Professionals to assist the state
Department of Public Health in reviewing and approving certificates of public convenience
& necessity and water supply plans. Due to insufficient staffing levels and cumbersome
administrative processes, the review and approval of water supply plans and certificates of
public convenience and necessity often takes several years. These delays result in
additional costs to public water suppliers and their customers.

Funding and Approval for Improvements to Deliver Potable Water

5. Expand Capacity of Potable Water Systems Section 22a-471-1, RCSA

Recommendation: Ensure that funding available to assist communities in installing water
systems in areas served by wells that have become contaminated may be used to ensure
that water service pipes are adequately sized to provide sufficient capacity in these areas.

Page 5 of 11

Rationale: In areas where a well or wells have been contaminated, water companies are
often called upon to install water systems to provide potable water to meet the public
health and safety needs of residents. However, under the existing formula established in
the regulations, reimbursement is limited to the installation of smaller-sized pipes to meet
the short-term needs of the area, which does not provide adequate capacity for public
health and fire flow. The formula does not provide any flexibility for the utility to obtain the
anticipated reimbursement and then absorb the incremental costs of the increased
capacity as is typically done for developers or other projects. This formula should be
updated to ensure that systems may be installed that will provide sufficient capacity in
these areas.

6. Update Mechanism to Fund Water Quality and Treatment Projects Sec. 25-33a, CGS;
Section 25-33b-1-5, RCSA; Section 16-1.59b, RCSA

Recommendation: Update Section 25-33a, CGS and Sections 25-33b-1through 5 of the RCSA
to create a relevant mechanism to fund water quality and treatment projects.

Rationale: Section 25-33a, which was created in the late 1970s to support the states
implementation of the Safe Drinking Water Act, has not been updated for a number of
years. As a result, the program is no longer a viable mechanism for funding water quality
and treatment projects which are needed to meet the public health needs of Connecticuts
residents.

Similarly, the ratemaking tool in Section 16-1.59b, RCSA that allows for special surcharges,
as approved by the Public Utilities Regulatory Authority (PURA), to be implemented to cover
the costs of construction projects for compliance with Safe Drinking Water Act
requirements was put in place when the initial compliance programs were initiated and new
plants constructed to meet the new rules. It would be helpful to clarify this language to
ensure that this mechanism may be allowed to be used for plant improvements or upgrades
to implement current technology at those plants.

7. Water System Acquisitions Sections 16-46, 16-262n, 16-262o, and 16-262m, CGS

Recommendation: Streamline the existing process or establish a specific process for water
system acquisitions.

Rationale: Hundreds of small water systems continue to operate in Connecticut to
supply water to residents and businesses. Unfortunately, many of these systems do not
have the financial or managerial capacity to properly maintain systems and comply with
stringent water quality and treatment standards. As a result, the state Department of
Public Health must expend considerable resources in addressing compliance issues.
Recognizing this, the state has encouraged consolidation of these systems to ensure
investment in the systems and compliance with state and federal public health laws.
However, the current process is very cumbersome and creates disincentives for water
Page 6 of 11

companies interested in acquiring failing or other water systems.

The current regulatory framework results in a lengthy approval process that causes an
administrative burden for the regulators (DPH, DEEP and PURA) as well as excessive legal
fees for the utilities, and ultimately results in delays in ensuring the proper management
of smaller water systems. In some cases these delays have resulted in the approval
process taking over 3 years to complete even in the cases of small acquisitions
(condominium complexes for instance).

Because no regulatory process currently exists to handle these types of acquisition, the
state is forced to utilize several regulations that are not intended for this type of change
of ownership in these cases. The regulatory requirements in place are intended for the
disposal of water company lands and termination of water supply. These regulations
have been required for the transfer of water company lands (wells or reservoirs) where
there is no intention of changing or modifying the use of the land. The following outlines
the regulatory process required for a typical change of ownership:

1. Before any water company can consider selling its sources/land, it must be sure
that its water supply plan(s) is updated to reflect the sale and it must have any
unused sources abandoned and any purchase water agreements in place.

2. C.G.S. 25-32d(e), CGS - Water Supply Plans requires a water company when
submitting a revision to the water supply plan which involves a forecast of land
sales, abandonment of any water supply source, sale of any lands or land
reclassification, shall provide notice (CMRR) to the CEO of the municipality in
which the land or source is located, the Nature Conservancy, the Trust for Public
Land and the Land Trust Service Bureau and any organization on the list
prepared under subsection (b) of Section 16-50c.

3. C.G.S. 25-33, CGS - Requires that a water company give notice (certified
mail, return receipt (CMRR) to the Commissioner of Health of its intent to sell
a water supply source. This must be done in advance of submitting an
application for a permit to sell such source. Include in the letter the following:
sources to sell and purchase price. Commissioner of Health determines what
water companies get notices. C.G.S. 25-32(b), CGS. Requires that a water
company obtain a permit from the Commissioner of DPH for the sale of water
sources and classified lands. This should also include a verification of Class III
land application. Also, under the DPH Drinking Water Section, a General
Application is required to be submitted along with any application that requires
an approval permit from the DPH. Not more than fifteen days prior to
submitting an application to DPH for a permit to sell water supply sources or
classified lands, a water company must give notice (CMRR) to the chief elected
official or CEO of the municipality in which such lands are located.

Page 7 of 11

These regulations require widespread public notice required to notify all stakeholders of
their interest in the land. Although this process is important when a water utility is
disposing of water supply lands, to give an opportunity for other utilities or municipalities
to take ownership of the lands for drinking water purposes, they are unnecessary, costly
and burdensome when there are two parties that have come to an agreement to sell the
assets of a water system. While the state has taken some steps to address this by
authorizing the acquiring water company to obtain a reasonable acquisition premium,
the process itself remains burdensome. Under current law, DPH and PURA must
concurrently review applications, hold hearings in many cases and render joint decisions
when an entity acquires the holdings/assets of another water company, voluntarily or
involuntarily, or when a new water company is created and constructed. This process
needs to be streamlined, or a new regulatory process established for the sale of water
company assets from one utility to another when there is no intention of changing use of
the assets. Consideration should be given to an expedited process and preapproval
certification for acquiring entities that have clearly demonstrated that they have the
technical, financial and managerial capacity to acquire such systems. Recently, DPH has
outlined a framework for such regulations that is a step in the right direction, and would
significantly reduce administrative burden and cost.

8. Permitting Use of Excess Water during Emergencies

Recommendation: Clarify that permits are not required for the use of excess water
during emergencies.

Rationale: Section 22a-358, C.G.S. requires a permit for a public water system to sell
water reserves in excess of those required to maintain an abundant supply of water to
customers in its service area. The state Department of Public Health has interpreted this
statute to require a permit application to be submitted and approved even if the sale of
excess water is for emergency use only. The type of information requested as part of the
permit application, however, is generally not applicable to the sale of excess water for
emergency use. Moreover, the time needed to complete an application and obtain the
necessary approval may undermine the provision of water for emergency purposes.

DEEP Diversion Programs

9. Diversion Permit Requirements for Certain Wells Connected to a Public Water Supply
Distribution System

Recommendation: Revise the definition of connected in a system to eliminate the
requirement that a water company must obtain a diversion permit for wells that withdraw
less than 50,000 gallons per day (gpd) when they are connected in a public water supply
distribution system that withdraws more than 50,000 gpd.

Page 8 of 11

Rationale: Generally, diversion permits are only required for wells that withdraw more than
50,000 gallons per day, recognizing that anything beneath this threshold is unlikely to
impair the environment or aquatic resources. However, the state Department of Energy &
Environmental Protection (DEEP) requires a permit for a well withdrawing less than 50,000
gpd if it is connected to a well system that withdraws more than 50,000 gpd. The
inefficiency that DEEPs interpretation creates is that two systems with existing sources less
than 50,000 gpd can't be connected to each other even if the withdrawal from the sources
will remain below 50,000 gpd. If they are connected, then all sources must be permitted at
significant cost even if withdrawals will remain below the supposedly minimal impact
threshold of 50,000 gpd.

PURA Regulations/Policies

10. Imposition of Late Charges on Water Utility Bills PURA Policy

Recommendation Allow water companies to impose late charges on unpaid bills after 28
days rather than one full month to eliminate confusion when late charges appear on the
next months bill.

Rationale Electric and gas companies are permitted to impose late charges on a
customers bill after 28 days rather than one full month. This allows the late charges to be
included on the next months bill rather than the bill that is issued after the second month.
Customers are often confused when they receive a bill with late charges for an unpaid bill
from two months ago.

11. Installation of Service Lines that Cross Intervening Property Lines Section 16-11-64,
RCSA

Recommendation: Provide that a water utility may allow a property owner to install a water
service pipe that crosses intervening properties provided the property owner demonstrates
to the water utility that 1) an alternative ownership of a suitable strip of land to establish
frontage on a road is not feasible; (2) the proposed service line will ultimately serve no
more than one premises; 3) proper easements are in place prior to the installation of the
line; 4) the construction complies with the Companys Rules and Regulations; and 5) there
is adequate water pressure to serve the property.

Rationale: Under the current regulations, a utility or property owner must submit a written
request to the Public Utilities Regulatory Authority (PURA) and a docket is initiated for an
exception to allow a service pipe to cross intervening properties only under very
exceptional hardship circumstances and then only on a case by case basis. However, there
are circumstances when installing a service line that crosses an intervening property line is
more feasible and prudent than installing a main extension. Under the regulations, the
ability to request an exception is very limited and cumbersome. As the vast majority of
Page 9 of 11

these are approved, it would seem that there would be a benefit to simplifying the process
for installing such lines is needed to address these concerns.

12. PURA Oversight regarding the Sale, Lease, Assignment or Mortgage of Real Property
Section 16-43(2), CGS and Land Transactions

Recommendation: 1) Increase the value of property that may be sold, leased, assigned,
mortgaged or otherwise disposed of subject to the approval of the Public Utilities
Regulatory Authority (PURA) from an appraised value of $50,000 or less to $100,000 or less
and 2) Increase the value of land subject to a public hearing under Sec. 16-50c(b), CGS from
$50,000 to $100,000.

Rationale: This provision has not been updated to reflect changes in property values,
unnecessarily subjecting relatively minor land transactions to regulatory oversight and
public hearings.

13. DEEP Permit Processing Timeframes

Recommendation Continue to Improve the Efficiency of DEEP Permit Processing.

Rationale: The state Department of Energy & Environmental Protection (DEEP) has
implemented LEAN practices and taken other steps to improve the permit process. For
example, DEEP has implemented an intake process to provide timely notice to applicants
that an application is incomplete or somehow deficient. This has been successful in
providing applicants with an opportunity to correct any deficiencies needed to process the
permit, improving the efficiency of the overall permitting process.

In addition, CWWA and other stakeholders worked with DEEP several years ago to create
additional categories of general permits. These efforts were successful in building more
flexibility and certainty into the general permit process by moving forward with the
following initiatives: 1) Filing-only Permits A filing only permit eliminates unnecessary
delays experienced by water utilities for activities that have no or minimal environmental
impact; 2) Duration of General Permit Extending the duration of the general permit from
five years to ten reduced costs associated with filing general permit applications; 3)
Renewal Application Changes to the renewal application process included a streamlined,
short-form process, which helped to provide certainty that previously authorized activities
may continue without interruption; 4) New Categories of General Permits DEEP developed
new categories of general permits which will greatly improve efficiency, such as the 1)
Interconnection and Transfer of up to 100,000 gpd and 500,000 gpd; and 2) Withdrawal of
up to 100,000 gpd Bedrock Aquifer.

Page 10 of 11

14. DEEP Permit Processing Scope of Review Authority

Recommendation: Limit DEEPs scope of authority in reviewing permit applications to issues
directly related to the effect of the diversion on water resources.

Rationale: DEEP appears to be exceeding its statutory authority in reviewing and approving
certain permits. Although DEEP may request information from an applicant for a permit to
divert water for a new consumptive use regarding the effect of the diversion on issues such
as stream flows or aquatic habitat needs, DEEP should not be permitted to request
information that is not impacted by the diversion, such as a business operation on the
property or the property itself. In addition, DEEP should not be using water diversion
permit applications to regulate activities that are not physically or hydraulically related to
the regulated diversion. Rather, DEEPs jurisdiction should be limited to the hydraulic and
related impacts resulting from a diversion of water.

15. General Permit for Water Treatment Wastewater Discharges

Recommendation: Modify the general permit for water treatment wastewater discharges
to create a workable general permit by: 1) expanding the definition of water treatment
facility to include potable water storage tanks; 2) clarifying that certain discharges are
exempt from monitoring and record-keeping requirements; 3) increasing the maximum
daily flow of all discharges on one site; 4) raising or eliminating the maximum groundwater
discharge limits for iron and manganese; 5) deleting the monitoring requirement.

Rationale: These changes are needed to improve the efficiency of this General Permit and
better reflect industry practices.

16. Burdensome and Unnecessary Agency Data Collection and Reporting Requirements

Recommendation: Ensure that agencies review and update regulations to eliminate
redundant, outdated and irrelevant regulations on a regular basis.

Rationale: The state Department of Public Health is in the process of adopting
comprehensive regulations (Section 19-13-B102, RCSA) which include certain reporting and
monitoring requirements, including raw water monitoring, herbicide and pesticide
monitoring. These reporting requirements should replace existing water company
reporting requirements or water companies will be subjected to costly, duplicative
reporting requirements.

In addition, the state is currently exploring how to develop a data collection framework to
assist the state in statewide water use planning. The state should review existing data
collection requirements on water companies to ensure that new data requirements do not
impose duplicative requirements on water companies.

Page 11 of 11

Conclusion

Again, thank you for the opportunity to provide input on laws, regulations and agency
interpretations that impose unnecessary and/or duplicative requirements on water companies.
We believe this effort will help ensure that water companies can continue to provide
Connecticuts residents and businesses with a safe, ample supply of public water supplies to
meet the states public health, safety and economic development needs.

CWWA
1245 Farmington Ave., 103
West Hartford, CT 06107
Tel. 860-841-7350
www.cwwa.org

The Connecticut Automotive Retailers Association (CARA) represents more than 240 new
franchised motor vehicle retailers in the state of Connecticut. CARA member dealers employee
over 13,000 people in dealerships around this state and account for 15.3% of all retail sales. We
appreciate the Governors efforts to ease unnecessary regulatory burdens on Connecticut
businesses.

CARA respectfully requests that the Governors Taskforce on Obsolete State Regulations
consider deleting any existing regulations preventing dealers from using electronic records and
adopting any necessary regulations to allow the use of electronic records. Current statutes (see
CGS Sec. 14-61b. Dealer records, documents and forms maintained in electronic format)
permit auto dealers who have the ability to scan MVD documents to use electronic documents in
lieu of paper documents. However, the Department of Motor Vehicles (DMV) has failed to adopt
any updated regulations pursuant to the new statute allowing dealers to keep electronic
documents in lieu of paper records. The cost to dealerships for storage, maintenance of a manual
system and recall of these records manually is significant. It seems that DMV should now adopt
new regulations and allow dealers to use electronic records and forms. Any
regulations prohibiting this should be repealed and new regulations allowing electric
recordkeeping should be promptly submitted to Regulations Review and adopted pursuant to the
Connecticut Statutes.

Respectfully submitted,

James Fleming
President - Connecticut Automotive Reatalers Association
CONNECTICUT AUTOMOTIVE RETAILERS ASSOCIATION
36 TRUMBULL STREET
HARTFORD, CONNECTICUT 06103
James T. Fleming Telephone: (860) 293-2500
President Facsimile: (860) 527-2582
Connecticut Heating & Cooling Contractors Association
2842 Main Street #259, Glastonbury, CT 06033 Phone (860) 533-1163 Fax (860) 533-1165
www.chcca.net
MEMBERS OF: CBIA NFPA ICC

COMMENTS OF
JENNIFER JENNINGS
EXECUTIVE DIRECTOR
IN RESPONSE TO EXECUTIVE ORDER # 37
DECEMBER 16, 2013

On behalf of the Connecticut Heating & Cooling Contractors Association (CHCC), thank
you for the opportunity to provide comments in response to Executive Order # 37 with
regard to regulations that are outdated! insufficient, or ineffective. As such, CHCC
suggests modifying regulations of the Department of Consumer Protection concerning
certain heating & cooling licenses.

Specifically, CHCC suggests clarifying the scope of the existing S-9 and S-10 license
categories for certain HVAC contractors and journeypersons by including language that
reflects warm air work. This common-sense change would greatly benefit many
members of the heating & cooling industry and reflects modern HVAC industry
practices.

Please see draft suggested language that follows, which would modify subsections (e)
and (f) of R.C.S.A. Sec. 20-332-5.

Thank you again for the opportunity to comment, and please do not hesitate to contact
CHCC should you require additional information.

CHCC is a trade association whose objectives are to strengthen and further trade relations, attract, educate and train necessary
manpower, represent members at all levels of government and review and establish quality standards and procedures. The
association represents Heating & Cooling Companies in Connecticut.
2

CHCC DRAFT SUGGESTED CHANGES TO R.C.S.A. Sec. 20-332-5

(e) Limited heating cooling contractors license (S-9).
The holder of this license may perform only perform work limited to warm air hot
water or steam heating systems, and the cooling work in installation, repair,
replacement, maintenance or alteration of any warm air, air conditioning and
refrigeration system, including necessary piping for the conveyance of heating or
cooling media and associated pumping equipment and air distribution for buildings
not over three stories high, with total heating load not exceeding 500,000 BTUS
per system, steam pressure not exceeding fifteen pounds, and/or cooling
installations up to 35 tons per system. This license also covers the installation or
servicing of oil burners handling up to five gallons per hour as well as LP gas
supplied by gas containers and/or natural gas piping for work covered by this
limited license. The requirements to qualify for this license examination shall be
two (2) years as a properly licensed journeyperson or equivalent experience and
training.

The proposed changes reflect what the initial intent of the license
was to entail and limit. The license fills the gap between the
Unlimited S-1 classification and a residential light commercial
applicability.

(f) Limited heating cooling journeypersons license (S-10).
The holder of this license may perform work only while in the employ of a
licensed contractor and only limited to warm air, hot water or steam heating
systems and cooling work in installation, repair, replacement, maintenance or
alteration of any warm air, air conditioning and refrigeration system, including
necessary piping for the conveyance of heating or cooling media and associated
pumping equipment and air distribution for buildings not over three stories high,
with total heating load not exceeding 500,000 BTUS per system, steam pressure
not exceeding fifteen pounds, and/or cooling installations up to 35 tons per system.
This license also covers the installation or servicing of oil burners handling up to
five gallons per hour as well as LP gas supplied by gas containers and/or natural
gas piping for work covered by this limited license. The requirements to qualify for
this license examination shall be the completion of a registered apprenticeship
program or equivalent experience
and training.

1
Drake, Christopher
From:
Sent: Monday, December 16, 2013 9:42 AM
To: Governor Regulations
Subject: Executive Order No. 37 - Comments on Control of Noise Regulations
Attachments: WHOa68672.pdf; WHOE92845.pdf; NARUC18b517ca-d2c3-4edc-adb4-b7f9ff8d88b2.pdf;
ME-096c375.pdf; WTN13_Schomer.pdf;
CT_SITING_COUNCIL_DRAFT_WIND_REGULATIONS_-2012July16-Ambrose-Rand.pdf;
Noise-WindFarms,_Shepherd,_Hanning_and_Thorne_(includes_K-J_criteria).pdf;
kamperman-james-10-28-08.pdf; AEI_WindFarmNoise2012.pdf
The comments below are being submitted per Executive Order No. 37 on behalf of FairWindCT by Joyce Hemingson.

FairWindCT
PO Box 225
Colebrook, CT 06021

To: Office of the Governor
From: Joyce Hemingson
Re: Addition of regulations for noise from industrial wind turbines to the Regulations of Connecticut State Agencies, Department of
Energy & Environmental Protection, Control of Noise regulations, Sec. 22a-69-1 through 22a-69-7.4.

Connecticuts Control of Noise regulations date to 1978, prior to the introduction of large-scale industrial wind turbines. The
regulations need revising to protect the health of residents from these huge stationary noise sources, which can be up to 500 feet tall.
Governor Malloys Executive Order No. 37 solicits public comment on regulations that have been in effect greater than four years and
whether such regulations are outdated, unnecessarily burdensome, insufficient, or ineffective. The current Control of Noise regulations
are outdated, insufficient and ineffective regarding industrial wind turbines. They allow an industrial use to emit 61 dBA during the day
and 51 dBA at night to residential property lines.

Governor Malloy further stated, We must always ensure that were providing for the health and well-being of our citizens and
our environment, but we should always challenge ourselves to make sure were striking the right balance. And, most important, we
should invite the public to challenge us to.

It is well known that noise affects human health. The World Health Organization (WHO) recommends limiting sound to a
maximum of 40 dBA at the exterior of residences (see attached files WHOa68672.pdf and WHOE92845.pdf). Noise from industrial wind
turbines is being regulated worldwide. Germany uses a noise night limit of 35 dBA in purely residential areas. Audible sound as well as
infrasound is considered.
In the U.S., the National Association of Regulatory Utility Commissioners recommends regulating industrial wind turbine noise
(see attached file NARUC18b517ca-d2c3-4edc-adb4-b7f9ff8d88b2.pdf). Here in New England, Maine has industrial wind turbine noise
regulations in place, with a nighttime limit of 42 dBA at any protected location (see attached file ME-096c375.pdf). The Massachusetts
Department of Public Utilities opened a docket on October 31, 2013 on the Best Practices for the Siting of Land-Based Wind Energy
Facilities (including human health and safety), and on December 12, 2013, the State of Vermont Public Service Board opened an
investigation on electric generation facilities, noting that The quantity and quality of sound emissions from proposed facilities have the
potential for impacts under each of these categories -- aesthetics, air quality and public health and safety.

Noise experts know that noise levels louder than 45 dBA will cause a high negative community response and vigorous
community action in the form of appeals to officials and threats of legal action. Sound levels should determine the setback distance of
industrial wind turbines from occupied buildings. If placed too close to people, industrial wind turbines will generate lawsuits. A judges
recent ruling in Falmouth, Mass., resulted in the significant curtailment of two industrial wind turbines there. The turbines are only
allowed to run from 7 am to 7 pm six days a week, and must be shut off entirely on Sundays and three major holidays. There is a
balance between producing renewable energy and protecting public health. Science-based Control of Noise regulations can prevent
situations similar to that of Falmouth and other towns in Massachusetts and Vermont from being repeated in Connecticut.

Noise from industrial wind turbines has characteristics that are unlike most other sources of community noise. The noise from
most community noise sources is concentrated in the mid (audible) and high level energy ranges and attenuates about 6 dB every time
the distance from the noise source is doubled. The noise from industrial wind turbines is predominately in the low frequency and
infrasound ranges (below 200 Hz) and that attenuates about 3 dB every time the distance from the noise source is doubled. The bulk of
sound energy coming from industrial wind turbines is not in the audible range, but in frequencies below that. It is this non-audible, low
frequency and infrasound noise that seems responsible for the nausea, migraines and the feeling of motion sickness in some people
2
(see attached file WTN13_Schomer.pdf). Solely measuring A-weighted noise (which emphasizes the range speech is in) misses the
bulk of energy emitted. Unweighted noise measurements will show the whole story.

The Alliance for Responsible Siting in Scituate, Mass. taped a community forum in March 2013 and it includes Rick James 20-
minute explanation, Wind Acoustics 101. Watch it at http://www.youtube.com/watch?v=RkJpci_lo4o beginning at minute 13.11. This
group has also suggested amendments to the MassDEP regarding noise testing protocols that would ensure that infrasound, low
frequency sound and aerodynamic amplitude modulation are appropriately considered. Other aspects that should be covered are
discussed by Stephen Ambrose and Robert Rand in their review of the Connecticut Siting Council Draft Wind Regulations (see
attached file CT_SITING_COUNCIL_DRAFT_WIND_REGULATIONS_-2012July16-Ambrose-Rand.pdf).

Criteria for regulating and monitoring industrial wind turbine noise is given below from Appendix A on pages 14-15 of Noise:
Windfarms, by Daniel Shepherd, Chris Hanning and Bob Thorne (see attached file
Noise-WindFarms,_Shepherd,_Hanning_and_Thorne_(includes_K-J_criteria).pdf.) Appendix A is based on the 2008 criteria of George
Kamperman and Richard James, noise experts familiar with industrial wind turbines in the U.S. As you can see, noise regulations for
large industrial wind turbines must be detailed and cover various factors.

APPENDIX A

Proposed Wind Turbine Siting Sound Limits, a revision by Thorne, R, of the Kamperman James criteria (2008) to include updates to
ISO 1996-2 and UK Court of Appeal (Hulme re: Den Brook).

1. Audible Sound Limit
a. No wind turbine or group of turbines shall be located so as to cause an exceedance of the preconstruction/operation background
sound levels by more than 5 dBA. The background sound levels shall be the LA90 sound descriptor measured during a pre-
construction noise study during the quietest time of evening or night. All data recording
shall be a series of contiguous ten (10) minute measurements. LA90 results are valid when LA10 results are no more than 15 dBA
above LA90 for the same time period. Noise sensitive sites are to be selected based on wind developments predicted
worst-case sound emissions in LAeq and LCeq which are to be provided by the developer.

b. Test sites are to be located along the property line(s) of the receiving non-participating property(s).

c. A 5 dB penalty is applied for tones as defined in IEC 61400-11 at the turbine and ISO1996-2 at any affected residence.

d. A 5 dB penalty is applied for amplitude modulation as defined following. When noise from the wind farm has perceptible or audible
characteristics that are perceived by the complainant as being cause for complaint, or greater than expected, the measured
sound level of the source shall have a 5 dB penalty added. Audible characteristics include tonal character measured as amplitude or
frequency modulation (or both); and tonality (where the tonal character/tonality of noise is described as noise
with perceptible and definite pitch or tone). Amplitude modulation is the modulation of the level of broadband noise emitted by a turbine
at blade passing frequency. Amplitude modulation will be deemed greater than expected if the following characteristics apply:
i) A change in the measured LAeq, 125 ms turbine noise level of more than 3 dB (represented as a rise and fall in sound energy levels
each of more than 3 dB) occurring within a 2 second period.
ii) The change identified in (i) above shall not occur less than 5 times in any one minute period provided the LAeq, 1 minute turbine
sound energy for that minute is not below 28 dB.
iii) The changes identified in (i) and (ii) above shall not occur for fewer than 6 minutes in any hour.
Noise emissions are measured outside a complainants dwelling and shall be measured not further than 35 metres from the relevant
building, and not closer than within 3.5 metres of any reflective building or surface, or within 1.2 metres of the ground.

2. Low Frequency Sound Limit
a. The LCeq and LC90 sound levels from the wind turbine at the receiving property shall not exceed the lower of either:
i) LCeq -LA90 greater than 20 dB outside any occupied structure, or
ii) A maximum not-to-exceed sound level of 50 dBC measured as the background sound
level (LC90) from the wind turbines without other ambient sounds for properties located at one mile or more from State Highways or
other major roads or measured as the background sound level (LC90) for properties closer than one mile.
iii) These limits shall be assessed using the same night-time and wind/weather conditions required in 1(a). Turbine operating sound
emissions (LAeq and LCeq) shall represent worst case sound emissions for stable night-time conditions with low winds at ground level
and winds sufficient for full operating capacity at the hub.

3. General Clause
a. Sound levels from the activity of any wind turbine or combination of turbines shall not exceed LAeq 35 dB within 100 feet of any noise
sensitive premises.
b. The monitoring shall include all the sound levels as required by these noise conditions and shall include monitoring for the
characteristics described in Annex A of IEC 61400-11including infrasound, low-frequency noise, impulsivity, low-frequency
modulation of broad-band or tonal noise, and other audible characteristics. Wind speed and wind direction shall be measured at the
same location as the noise monitoring location.
3

4. Requirements
a. All instruments must meet ANSI or IEC Class 1 integrating sound level meter performance specifications.
b. Procedures must meet ANSI S12.9, IEC61400-11 and ISO1996-2
c. Procedures should meet ANSI, IEC and ISO standards applicable to the measurement of sound or its characteristics.
d. Measurements must be made when ground level winds are 2m/s (4.5 mph) or less. Wind shear in the evening and night often results
in low ground level wind speed and nominal operating wind speeds at wind turbine hub heights.
e. IEC 61400-11 procedures are not suitable for enforcement of these requirements except for the presence of tones near the turbine.

5. Definitions
ANSI S12.9 Quantities and Procedures for Description and Measurement of Environmental Sound, Parts 1 to 6.
IEC 61400-11 Wind turbine generator systemsPart 11: Acoustic noise measurement techniques.
ISO 1996-2 AcousticsDescription, measurement and assessment of environmental noisePart 2: Determination of environmental
noise levels.
LA90 , LA10 Statistical measures calculated under ANSI S12.9.
LAeq, LCeq Time average levels calculated under ANSI
S12.9 or ISO 1996-2.
Noise sensitive premises includes a residence, hotel, hostel or residential accommodation premises of any type.

6. References
ANSI S12.9-2008, Quantities and Procedures for Description and Measurement of Environmental SoundPart 6: Methods for
Estimation of Awakenings Associated with Outdoor Noise Events Heard in Homes, 2008.
Hulme V Secretary of State (2011). Hulme v Secretary of State for Communities and Local Government and Anor. Approved Judgment
in the England and Wales
Court of Appeal (Civil Division) on Appeal from the High Court of Justice, Case No: C1/2010/2166/
QBACF. Neutral Citation Number [2011] EWCA
Civ 638; Available from: www.bailii.org/ew/cases/
EWCA/Civ/2011/636.html.
IEC 61400-11Wind Turbine Generator SystemsPart 11: Acoustic Noise Measurement Techniques, 2nd ed. (International Technical
Commission, Geneva, 2002
plus Amendment 1 2006).
International Standards Organization, (2007). ISO
1996-2 second edition, Acousticsdescription, assessment and measurement of environmental noise part
2: Determination of environmental noise levels.
International Standards Organization.
Kamperman, G. W.; James, R. R. In: Proceedings of
the 30th Annual Conference of ASMEs Noise Control
and Acoustics Division, 2831 July 2008, Dearborn,
Michigan, USA.

As background material, Ive attached the following files:
The World Health Organizations recommendations on noise levels (WHOa68672.pdf and WHOE92845.pdf)
The National Association of Regulatory Utility Commissioners Wind Energy & Wind Park Siting and Zoning Best Practices and
Guidance for States, which recommends regulating noise (NARUC18b517ca-d2c3-4edc-adb4-b7f9ff8d88b2.pdf)
The How To Guide to Siting Wind Turbines to Prevent Health Risks from Sound, George W. Kamperman, P.E. and Richard
R. James, INCE, October 28, 2008 (kamperman-james-10-28-08.pdf)
Wind Farm Noise 2012: Science and Policy Overview, Jim Cummings, The Acoustic Ecology Institute
(AEI_WindFarmNoise2012.pdf)
Maine Department of Environmental Protection, regulations for chapter 375 (see page 25 and following in ME-096c375.pdf)
Connecticut Siting Council Draft Wind Regulations, Stephen E. Ambrose, INCE and Robert W. Rand, INCE, memo to CSC
dated July 16, 2012 (CT_SITING_COUNCIL_DRAFT_WIND_REGULATIONS_-2012July16-Ambrose-Rand.pdf).
Noise: Windfarms, Daniel Shepherd, Chris Hanning and Bob Thorne. Encyclopedia of Environmental Management, CRC
Press. 2012. (Noise-WindFarms,_Shepherd,_Hanning_and_Thorne_(includes_K-J_criteria).pdf.)
A Proposed Theory to Explain Some Adverse Physiological Effects of the Infrasonic Emissions at Some Wind Farm Sites,
Paul D. Schomer, John Erdreich, James Boyle and Pranav Pamidighantam, 5th International Conference on Wind Turbine
Noise, August 2013 (WTN13_Schomer.pdf).

Please let me know if you have any questions or would like further information. I appreciate this opportunity to submit a request for
changes to Connecticuts Control of Noise regulations and look forward to a reply from the Department of Energy and Environmental
Protection on this important area of public health and safety.

Sincerely,

Joyce Hemingson, Ph.D.
President, FairWindCT
www.fairwindct.com
4
860-379-6425

Wind Energy & Wind Park
Siting and Zoning
Best Practices and
Guidance for States

NARUC Grants & Research

N
A
R
U
C

The National
Association
of Regulatory
Utility
Commissioners
2012
January 2012
A report for the Minnesota Public Utilities
Commission Funded by the U.S. Department of
Energy

The report you are reading was created under the State Electricity Regulators
Capacity Assistance and Training (SERCAT) program, a project of the
National Association of Regulatory Utility Commissioners (NARUC) Grants &
Research Department. This material is based upon work supported by the
Department of Energy under Award Number DE-OE0000123.

The report was authored by Tom Stanton. Throughout the preparation
process, the members of NARUC provided the author(s) with editorial
comments and suggestions. However, the views and opinions expressed
herein are strictly those of the author(s) and may not necessarily agree with
positions of NARUC or those of the U.S. Department of Energy.

Special thanks to the Commissioners and staff at the Minnesota Public
Utilities Commission for guiding this work, and to the Office of Electricity
Delivery and Energy Reliability and the National Energy Technology Lab for
their continued technical assistance to NARUC.

Please direct questions regarding this report to Miles Keogh, NARUCs
Director of Grants & Research, mkeogh@naruc.org; (202) 898-2200.

Disclaimer: This report was prepared as an account of work sponsored by an
agency of the United States Government. Neither the United States
Government nor any agency thereof, nor any of their employees, makes any
warranty, express or implied, or assumes any legal liability or responsibility
for the accuracy, completeness, or usefulness of any information, apparatus,
product, or process disclosed, or represents that its use would not infringe
privately owned rights. Reference herein to any specific commercial product,
process, or service by trade name, trademark, manufacturer, or otherwise
does not necessarily constitute or imply its endorsement, recommendation,
or favoring by the United States Government or any agency thereof. The
views and opinions of authors expressed herein do not necessarily state or
reflect those of the United States Government or any agency thereof.

Put It There!
Wind Energy & Wind-Park Siting and Zoning
Best Practices and Guidance for States

Tom Stanton
Principal for Electricity

January 2012
12-03

2012 National Regulatory Research Institute

This page intentionally blank.
i
Acknowledgments

This material is based upon work supported by the Department of Energy, National Energy Technology
Laboratory under Award Number(s) DE-OE0000123.

This paper results from a National Association of Regulatory Utility Commissioners (NARUC) grant for
State Electricity Regulators Capacity Assistance and Training (SERCAT). Funding for the NARUC
SERCAT program is provided under a cooperative agreement between NARUC and the U.S. Department
of Energy (DOE) and National Energy Technology Laboratory (NETL). NRRI is grateful to NARUC, the
DOE, and NETL for supporting SERCAT and this project.

The author wishes to thank these colleagues from the National Regulatory Research Institute. Without
their assistance, this project would not have been possible.

Deborah Luyo, Research Assistant, assiduously obtained, edited, and verified current
information for the survey of wind siting and zoning practices presented in Appendix A and
helped check the accuracy of the summary of the state surveys reported in Part II.
Leah Goodwin supported this project with her expert editing and desktop-publishing skills.

In addition to those colleagues from NRRI, I wish to thank:

Tricia DeBleeckere, staff at the Minnesota Public Utilities Commission, for her continuing
consultation.
Ben Hoen from Lawrence Berkeley National Laboratory, for his careful reading and helpful
suggestions.
James McElfish of the Environmental Law Institute, whose 2011 report, State Enabling
Legislation for Commercial-Scale Wind Power Siting and the Local Government Role, was
an important resource for understanding practices in the states, and for helping us to correct
several errors in our initial survey work.
Charles McKeown of Michigan State University, Martin (Mike) Pasqualetti of Arizona
State University, and Roopali Phadke of Macalester College, who generously shared
reference materials and provided encouragement for this work.
Victoria Pebbles and the staff and my colleagues who participate in the Great Lakes Wind
Collaborative, whose excellent work in summarizing practices in the Great Lakes states (and
the neighboring Canadian provinces of Ontario and Quebec) and important Best Practices
guidebook helped inform this project.
My colleagues who participate in Michigans State Wind Outreach Team (SWOT), for
their ongoing efforts to provide the best available information and educate the Michigan
public, including me, about wind energy technology, policy, and implementation.
Paul Gipe, keeper of the website www.wind-works.org, for his long-standing diligence in
indexing news items and sharing references about wind energy.

Any inaccuracies, mistakes, or omissions are my responsibility. Comments, corrections, editorial
guidance, and new information to update this report and the survey results are welcome. Comments can
be submitted to:

Tom Stanton, Principal for Electricity
National Regulatory Research Institute
tstanton@nrri.org (517) 775-7764

ii

Online Access

This paper can be accessed online via the National Regulatory Research Institute website at
http://www.nrri.org/pubs/electricity/NRRI_Wind_Siting_Jan12-03.pdf.

Disclaimer

This report was prepared as an account of work sponsored by an agency of the United States Government.
Neither the United States Government nor any agency thereof, nor any of their employees, makes any
warranty, express or implied, or assumes any legal liability or responsibility for the accuracy,
completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents
that its use would not infringe upon privately owned rights. Reference herein to any specific commercial
product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily
constitute or imply its endorsement, recommendation, or favoring by the United States Government or
any agency thereof. The views and opinions of the author expressed herein do not necessarily state or

iii

Table of Contents

Acknowledgments .................................................................................................... i
Online Access ........................................................................................................... ii
Disclaimer ................................................................................................................ ii
Table of Contents ................................................................................................... iii
Table of Figures and Tables .................................................................................... v
Executive Summary .......................................................................................... ES-1
Introduction .............................................................................................................. 1
I. Current Status ................................................................................................ 3
A. Summary information from the survey of state practices ................................................... 5
1. Responsibility for siting and zoning and certificates of necessity:
state, local, or both ............................................................................................... 13
2. A primary rule about local authority: Home Rule versus Dillons Rule.............. 14
3. Mandatory evaluation criteria, voluntary guidelines,
model ordinances, setback and sound standards, and local ordinances ............... 15
4. Supporting policies: clean energy portfolio standards and goals,
promoting in-state wind energy facilities, and renewable energy zones ............. 16
B. The nature of wind-park opposition and list of major concerns ....................................... 17
II. Best Practices for Wind Siting and Zoning Procedures .......................... 22
A. Develop procedures that result in clarity, predictability, and transparency ...................... 23
B. Establish one-stop, pre-submission consultation for applicants ....................................... 23
C. Identify and map constrained and preferred wind energy development zones ................. 23
D. Include preferred development zones in transmission plans............................................. 24
iv

E. Prepare and make readily available guidelines for participants ........................................ 25
F. Prepare and make available for local siting and zoning officials
guidelines, checklists, technical resources, and model ordinances ................................... 25
G. Ensure that the sequence for obtaining permits and approvals
meets requirements to allow development of suitable projects ........................................ 26
III. Guidelines for Implementing Wind-Park Siting and Zoning Criteria
and Setback Distances ................................................................................. 27
A. Avoiding or mitigating public health and safety, nuisance and annoyance issues .......... 28
1. Noise, sound, and infrasound ............................................................................... 29
2. Shadow flicker ..................................................................................................... 31
3. Ice throw .............................................................................................................. 32
4. Pre- and post-construction monitoring
for public health and safety, nuisance, and annoyance issues ............................. 32
B. Preventing harm to flora, fauna, and habitats ................................................................... 33
1. Wildlife and habitat exclusion zones ................................................................... 33
2. Wildlife and habitat pre- and post-construction monitoring ................................ 34
3. Mitigation and operating practices to minimize negative impacts ...................... 34
C. Aesthetics .......................................................................................................................... 35
D. Critical competing land uses and setback distances .......................................................... 36
E. Permit requirements for met towers, construction, and decommissioning ....................... 37
F. Dispute resolution and mitigation ..................................................................................... 38
Summary and Conclusions .................................................................................... 39
References ............................................................................................................... 42
Appendix A: State Survey Reports ...................................................................... 48
v

Table of Figures and Tables

Figure 1: NREL Map of Currently Installed Wind Capacity by State .......................................................... 3
Table ES-1: Summary of State Wind Siting and Zoning Practices ........................................................ ES-3
Table ES-2: Factors Included in State Wind Siting and Zoning Guidelines ........................................... ES-8
Table ES-3: Typology of Anti-Wind-Park Arguments ........................................................................... ES-9
Table ES-4: Best Practices for Procedures ........................................................................................... ES-12
Table ES-5: Wind-Park Siting and Zoning Criteria, Recommended Approaches
and Setback Distances ........................................................................................................... ES-12
Table 1: Summary of State Wind Siting and Zoning Practices ................................................................... 6
Table 2: Summary of State Wind Siting and Zoning Practices (Top Ten States,
Ranked by 2011 Installed Commercial Wind Generating Capacity in MW) .............................. 11
Table 3: Factors Included in State Wind Siting and Zoning Guidelines ..................................................... 15
Table 4: Typology of Anti-Wind-Park-Arguments..................................................................................... 19
Table 5: Best Practices for Procedures ....................................................................................................... 22
Table 6: Wind-Park Siting and Zoning Criteria, Recommended Approaches, and Setback Distances ...... 27

ES-1
Executive Summary

Siting and zoning of new utility-scale wind energy facilities (called wind parks in this report) can be
complicated and is often contentious, due to local opposition. Citizens are frequently worried about the
changes to the landscape that will occur if utility-scale wind turbines are sited nearby. Such wind turbines
are tall, rather imposing structures. Their construction often represents a significant change to what were
previously open rural and agricultural landscapes.

Wind siting and zoning are influenced by preexisting laws and administrative rules, renewable energy
support policies, and public acceptance. But often, planning and zoning officials with no previous
expertise in wind energy systems have to develop the rules and regulations that will ultimately guide local
wind power siting and zoning decisions. Those rules then, for better or worse, directly affect the planning,
design, development, construction, and operations of wind parks.

Development of wind parks in areas with promising wind resources is economically favorable when
compared with other types of renewable energy sources. In part because 37 states have adopted policies
that set either mandates or goals for increasing the use of renewable energy, wind-park development in
the U.S. has been growing steadily. The growth continues, despite controversy in specific jurisdictions.
By late 2011, the U.S. had 42,432 MW of installed wind energy capacity and 14 states had more than
1,000 MW each.

This report summarizes the wind energy siting and zoning practices in all 50 states and the District of
Columbia. Part I briefly reviews the current status of wind energy development in the U.S.

Part I.A reports on a survey conducted of each states wind energy siting and zoning practices. The
completed surveys are presented in Appendix A. Table ES-1 (pp. ES-37) summarizes the survey data.
Specific data reviewed and reported in Part I.A includes:

What agencies have responsibility for wind siting and zoning decisions, and are they state or
local government agencies, or both?

Summary data is shown in Table ES-1, columns 3, 4, and 5. The primary decision-making authority, as
reported in column 3, resides with local governments in 26 states and state governments in 22 states.
Florida and Iowa have shared local and state responsibility. Column 4 includes a (P) to indicate that a
state agency has primary siting authority. Many states have a clearly defined secondary authority, as
indicated by (S) in Column 4. In six states plus the District of Columbia the public utility commission
(generically, the PUC) is responsible for siting and zoning utility-owned wind parks. Altogether, 23 states
and the District of Columbia require a certificate to be issued by the PUC prior to wind park construction.
Eleven other states, indicated with a Y in column 5, have an energy facility siting authority that is
separate from the PUC. Data reported in columns 3 or 4 reports if the state-level jurisdiction is contingent
upon the size of the wind park.

Which overriding rule, established by the states constitution, governs the division between state
and local government jurisdiction in the state? Is it Home Rule, where local governments
retain all decision-making authority except that explicitly granted to the state? Or is it Dillons
Rule, where the state government retains all decision-making authority except that explicitly
granted to the local governments?

That data is reported in Table ES-1, column 6. A general expectation might be that Home Rule states
would tend to have local authority and Dillons Rule states would tend to have state authority for wind
siting and zoning. In practice, though, Home Rule states are evenly split in terms of local versus state
authority, but more Dillons Rule states (20 of 31) have already delegated wind siting and zoning
ES-2

authority to local units of government.

How many and which states have developed mandatory evaluation criteria, voluntary guidelines,
model ordinances, and setback or sound standards for wind parks? How many local governments
in each state have already adopted wind siting and zoning ordinances?

These data are shown in Table ES-1, columns 7 through 12. Slightly more than half the states have
published lists of the criteria that are used to evaluate wind siting and zoning conditions. Ten states have
published voluntary guidelines for wind parks. Table ES-2 (p. ES-8) reports on the major factors
included in each states guidelines.

Five states, labeled Y in Table ES-1, column 9, have published model ordinances intended to guide
local governments. As shown in Table ES-1, columns 10 and 11, a handful of states have published
setback standards, sound standards, or both. Both of these columns differentiate between mandatory
standards, indicated as Y, and recommended or advisory standards for local government consideration,
indicated as Model. Table ES-1, column 12, reports the number of local ordinances that have been
discovered and included in a database being assembled by the National Renewable Energy Laboratory.

How many and which states have supporting policies, such as clean energy portfolio standards
and goals, policies promoting the development of in-state wind energy facilities, and renewable
energy zones?

These data are shown in Table ES-1, columns 13, 14, and 15. As shown in column 13, 29 states and the
District of Columbia have renewable energy portfolio standard (RPS) mandates (M), and eight states have
renewable energy goals (G). Of those 37 states with RPS mandates or goals, 29 have enacted policies that
are specifically intended to promote the development of in-state renewable resources, including wind
parks. Those policies are encoded with one, two, or three letter codes. In column 14: B means a
bonus credit for at least some in-state facilities; D means electricity must be delivered into the state
(or DR means delivered into the region) in order to qualify as eligible to count for RPS compliance;
L means a maximum limit on energy from out-of-state facilities or conversely a minimum limit (often
called a carve-out) on energy from particular kinds of in-state resources; M means a mandate for
in-state generators; R means a mandate for regional generators (usually, in the territory served by a
regional transmission organization, RTO); S means qualifying facilities must be in the service territory
of a utility providing retail service in the state; and U means a mandate for a utility serving the state to
own or contract for the qualifying renewable energy.

Another policy that indirectly supports wind-park siting and zoning is the development of renewable
energy zones. This is reported in Table ES-1, column 15. Typically, a renewable energy zone (REZ) is
identified through a planning process that includes a general review of wind resources and broad-based,
regional land-use compatibility with wind-park development, combined with electric transmission system
modeling and planning. In most REZ processes, once specific zones are identified, transmission will be
built to interconnect the zone to electricity loads, in anticipation that wind-park development will follow.
States with explicit state-level REZ processes include California, Colorado, Michigan, and Texas. These
are indicated with a Y in column 15. Many other states and utilities are participating in REZ-like
transmission modeling and planning under the auspices of regional transmission organizations. These
include the Midwest Independent [Transmission] System Operator Regional Generation Outlet Studies
(RGOS), and the Western Renewable Energy Zone (WREZ) initiative.

ES-3

Table ES-1: Summary of State Wind Siting and Zoning Practices

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Alabama 0 State CPCN from PSC (P) Dillons
Alaska 10 State CPCN from RCA (P) Home 1
Arizona 128 Local Dillons Y W 1 M BD WREZ
Arkansas 0 Local CPCN from PSC (S) Home
California 3,599 Local
California Environmental
Quality Act (S)
Dillons Y 6 M L
Y,
WREZ
Colorado 1,299 Local
CPCN from PUC (>2MW)
(S), PUC consults with
Division of Wildlife (S)
Dillons Y M BL
Y,
WREZ
Connecticut 0
State
(>1 MW)
CECPN from Siting Council
(>1 MW) (P), DEEP checks
congruence with IRP (S)
Y Home Y M LR
Delaware 2 Local Certification from PSC (S) Dillons Y Y Y M B
District of
Columbia
0 PUC Approval from PSC (P) n/a M DL
Florida 0
State
(<75MW)
DOT, FAW (<75MW) (P) Y
12
Y
Georgia 0 Local Dillons YW Y Model Model
Hawaii 93 Local Permit from PUC (S) Dillons M M
Idaho 471 Local Dillons 1 WREZ
Illinois 2,436 Local DNR (S) Home 5 M LR RGOS
Indiana 1,339 Local CON from URC (S) Home 13 G L RGOS
1
See all table notes at the end of the table, on page ES-7. See Appendix A for more detailed information about each states practices.

Table ES-1 (Continued): Summary of State Wind Siting and Zoning Practices
ES-4
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Iowa 3,675
Both
(>25MW)
Certification from Iowa
Utilities Board (>25MW)
Home Y 5 M U RGOS
Kansas 1,074 Local Dillons YW 3 M B
Kentucky 0 State
Siting Board Approval
(>10MW) (P)
Dillons RGOS
Louisiana 0 Local Permit from DEQ (S) Dillons
Maine 266
State
(>20 acres)
13

Permit from DEP (>20
acres) (P), Permit from
LURC (for unorganized
areas)
13
(P)
Dillons Y 8 M BL
Maryland 120
State
(70MW)
CPCN from PSC (70MW)
(P), 7 state agencies notified
(S)
Y Dillons Y W 15 M LR
Massachusetts 38
State
(>100MW)
Permit from Energy
Facilities Siting Board
(>100MW) (P)
Home Y Y Model Model 2 M L
Michigan 164 Local
PSC checks utility-owned
and PPA projects for
compliance with a utilitys
renewable energy plans (S)
Y Home Y Y 11 M BS
Y,
RGOS
Minnesota 2,518
State
(>5MW)
Permit from PUC (>5MW)
(P)
Dillons Y Y Y 2 M RGOS
Mississippi 0 State CPCN from PUC (P) Dillons
Missouri 459 Local Dillons 1 M RGOS
Montana 386 Local Home Y M D
RGOS,
WREZ

ES-5
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Nebraska 294
State
(>80MW)
12

Approval from Nebraska
Power Review Board
(>80MW)
12
(P)
Dillons Y 4
Nevada 0 Local
Permit from PUC
(70MW) (S)
Y Dillons M
Y,
WREZ
New
Hampshire
26
State
(30 MW)
COSF from Site Evaluation
Committee (30MW) (P)
Dillons Y M DR
New Jersey 8 Both
Interconnection authority
falls to PJM RTO (S)
(see New Jersey survey)
Y Home Y 10 M DLR
New Mexico 700
State
(>300MW)
CPCN from PRC (P) Home Y W M WREZ
New York 1,349 Local
(S)
Dillons Y YW Y Model Model 1 M L
North
Carolina
0 Local CPCN from NCUC (S) Dillons Y Y 9 M L
North Dakota 1,424
State
(>0.5MW)
CSC from PSC (P), 21
State Agencies notified (S)
Dillons Y 3 G RGOS
Ohio 67
State
(5MW)
CECPN from Power Siting
Board (5MW) (P)
Home Y M RGOS
Oklahoma 1,482 Local Y Dillons G M
Oregon 2,305
State
(>105MW)
Certification from Energy
Facility Siting Council
(>105MW) (P)
Home Y 1 M BR
GBS,
WREZ
Pennsylvania 751 Local Y Dillons Y Y Model Model 4 M LR
Rhode Island 2
State
(40 MW)
Approval from Energy
Facility Siting Board
(40 MW) (P)
Home Y Y Y Y M

ES-6
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

South
Carolina
0
State
(>75MW)
CPCN from PSC
(>75MW) (P)
Y Dillons
South Dakota 784 Local
Permit from PUC
(>100 MW) (S)
Y Dillons Y Y Y Y

4 G

RGOS
Tennessee 29 Local Dillons
Texas 10,135 Local
Projects must register with
PUC (S)
Dillons Model Model 2 M M Y
Utah 325 Local CCN from PSC (S) Home Y Y Model Model 3 G R
Y,
WREZ
Vermont 6 State COPG from PSB (P) Dillons Y G M
Virginia 0 Local
Permit from
DEQ 100 MW (S),
SCC >100 MW (S)
Dillons Y Y Y 3 G
Washington 2,356
State
(>350MW)
Site Certification
Agreement from Energy
Facility Site Evaluation
Council (>350MW) (P)
Dillons W M DR
GBS,
WREZ
West Virginia 431 State CPCN from PSC (P) Y Dillons G BR
Wisconsin 469 Local
CPCN from PSC
(>100MW) (S)
Dillons Y
10
4 M D RGOS
Wyoming 1,412
State
(30 turbines)
Permit from Industrial
Siting Council (30 turbines)
(P)
Dillons Y Y WREZ

ES-7
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Table Notes: See also the individual survey reports for each state, presented in alphabetical order by state name, in Appendix A.
1
Source data for Column 2 is Figure 1 (p. 3).
2
Column 3 indicates Local when the primary siting authority rests with the local (county or municipal) government or State when primary authority is with the state.
Any Limit means that a wind-park size criterion (number of turbines in Wyoming, acres in Maine, or capacity number of MW in 14 states) determines
jurisdiction. In those circumstances, wind parks larger than the expressed limit trigger state authority. Both applies to Iowa and New Jersey, where siting authority is
held by both the state and local units of government.
3
Column 5: Y for yes indicates there is a state energy facility siting council or board separate from the state public utility commission.
4
Column 6 distinguishes between Home Rule states and Dillons Rule states. See p. 10 for the discussion.
5
Columns 7 and 8: Y means yes, the state does have mandatory evaluation criteria (Column 7) or voluntary guidelines (Column 8). A W in either column means
primarily or exclusively for wildlife. States with both Y and W in either column means multiple documents exist, one focused explicitly on wildlife.
6
Columns 10 and 11: Y indicates that standards are included in evaluation criteria. Model means that criteria are included in a model ordinance.
7
Column 12: The number in Column 12 represents the ordinances included in a database being assembled by the National Renewable Energy Laboratory, available from
http://www.windpoweringamerica.gov/policy/ordinances.asp, retrieved 22 Dec 2011.
8
Column 13: M means the state has a mandatory renewable energy portfolio standard. G means the state has a voluntary goal for renewable energy. See Database of
State Incentives for Renewables & Efficiency, 2011, Portfolio Standards/Set Asides for Renewable Energy [web page] and RPS Policies [map],
http://www.dsireusa.org/incentives/index.cfm?SearchType=RPS&&EE=0&RE=1, retrieved 22 Dec 2011.
9
Column 14: Many state RPS programs include provisions to promote in-state renewable energy facilities, such as wind parks. A recent NRRI Report (Grace, Donovan,
& Melnick, 2011) calls this a tilt policy (intended to tilt the playing field towards certain technologies). In Column 14: B means a bonus credit for at least some
in-state facilities; D means electricity must be delivered into the state (or DR means delivered into the region) in order to qualify; L means a maximum limit on
energy from out-of-state facilities or conversely a minimum limit on energy from particular kinds of in-state resources; M means a mandate for in-state generators;
R means a mandate for regional generators; S means qualifying facilities must be in the service territory of a utility providing retail service in the state; and U
means a mandate for a utility serving the state to own or contract for the qualifying renewable energy. Source: Database of State Incentives for Renewables &
Efficiency, 2011, http://www.dsireusa.org/incentives/index.cfm?SearchType=RPS&&EE=0&RE=1, retrieved 5 Jan 2012.
10
Column 15: REZ means Renewable Energy Zone(s). Coding indicates Y if there is a specific state process for determining zones (in Texas, Colorado, Utah,
Michigan, and Nevada). Other codes include: WREZ for the Western Renewable Energy Zones process for 5 states); RGOS for the Regional Generation Outlet
Study process at the Midwestern Independent [Transmission] System Operator (MISO) for parts or all of 12 states; GBS for the Gorge Bi-State Renewable Energy
Zone, which includes six counties near the Columbia River in both Oregon and Washington.
11
Wisconsins Model Ordinance applies only for small wind systems, <100kW in capacity.
12
Nebraskas >80MW limit applies only if the planned capacity would cause the utilitys total renewable energy production to exceed the companys goal.
13
Maines state authority applies if the proposed wind park involves more than 20 acres of land, or if the wind park will be sited in an unorganized area.

ES-8

Table ES-2: Factors Included in State Wind Siting and Zoning Guidelines

State Wildlife Aesthetics Birds Bats Noise Setbacks Mitigation Decommissioning
Arizona Y
Georgia Y Y Y Y Y
Kansas Y Y Y Y Y
Maryland Y Y Y
Michigan Y Y Y Y Y Y Y Y
New Mexico Y Y Y
New York Y Y Y Y Y Y
Rhode Island Y Y
South Dakota Y Y Y Y
Vermont Y Y Y

Part I.B briefly reviews the nature of wind-park opposition and lists the major concerns that are usually
raised. When engaging in siting and zoning procedures, anti-wind groups and individuals arm themselves
with information obtained from anti-wind web sites. Examples include AWEO (www.aweo.org),
Industrial Wind Action Group (www.windaction.org), and National Wind Watch (www.wind-
watch.org).
1

Ubiquitous internet access among local activists facilitates the dissemination of anti-wind documents and
thereby tends to focus all local anti-wind groups on the same basic issues and concerns. Table ES-3
summarizes many of the objections raised by opposition groups. In Table ES-3, italic font denotes
recommendations for the role that each set of objections ought to play in siting and zoning decisions.

Part II summarizes best practices for the procedures used to manage wind energy siting and zoning. The
report recognizes that best practices are subject to refinement over time, as more knowledge is gained and
as wind generator technologies change and improve. These recommendations are based on data reported
from the survey of state policies and procedures, literature review, and the knowledge and experience of
the author. The recommendations are summarized in Table ES-4.

Part III presents guidelines for wind power development, including recommended approaches to critical
issues: noise; shadow flicker; ice throw; wildlife; aesthetics; competing land uses; permit requirements for
meteorological (met) towers, construction, and facility safety; and decommissioning. Table ES-5
summarizes recommended approaches towards and applying setback distances in response to each of
those major criteria.

1
Website home pages retrieved 12 Dec 2011.

ES-9

Table ES-3: Typology of Anti-Wind Park Arguments

Topics and Subtopics Example of anti-wind characterization. Siting and Zoning Relevance.
Human Health, Nuisance,
and Annoyance Factors
Noise
Infrasound
Shadow flicker
[W]ind farms produce a noise thats hard to comprehend and even more dangerous
to live close to. The beating of the blades have not only their own throbbing sounds,
but beat harmonically together to create a cacophony of audible confusion
(Brougher, 2008).
[B]ased on our knowledge of the harmful effects of noise on childrens health and
the growing body of evidence to suggest the potential harmful effects of industrial
wind turbine noise, it is strongly urged that further studies be conductedbefore
forging ahead in siting industrial wind turbines. (Bronzaft, 2011).
"Dizziness (specifically, vertigo) and anxiety are neurologically linked phenomena.
Hence the anxiety and depression seen in association with other symptoms near
wind installations are not a neurotic response to symptoms, but rather a
neurologically linked response to the balance disturbances people experience from
shadow flicker or low-frequency noise... . Based on these health effects and hazards,
turbines should not be placed within 1700 feet of any road or dwelling. Those living
within 1/2 mile (2640 ft) should be apprised that they are likely to experience very
bothersome levels of noise and flicker, which continue (though to a lesser degree) to
a mile or more from the turbines." (Pierpont, 2005).

Windparks should not be singled out for special noise criteria. Siting and zoning can
apply noise criteria, but noise limits should apply equally to all sources. Separate
consideration should be given to construction noise.
It is a simple matter to calculate the precise locations and maximum annual
duration of shadow-flicker effects. A siting standard can limit shadow flicker.
Both noise and shadow-flicker complaints can be amenable to mitigation, and an
escrow account subject to independent management by an objective, disinterested
arbitrator can be established for this purpose.
Neighbors should have the right to waive noise and shadow-flicker standards.
Safety
Ice-throw
Blade failure
Tower failure
The bottom line is that ice, debris or anything breaking off the wind turbine blades
(including the blades themselves) can impact a point almost 1,700 feet away from the
base of the turbine (Matilsky, 2011).
Especially in the mountainous sites or in the northern areas icing may occur
frequently and any exposed structure also wind turbines will be covered by ice
under special meteorological conditions. This is also true if today's Multi Megawatt
turbines with heights from ground to the top rotor blade tip of more than 150 m can
easily reach lower clouds with supercooled rain in the cold season, causing icing if it
hits the leading edge. (Siefert, Westerhellweg, & Kroning, 2003).
[W]ind turbines are being whipsawed and hammered to pieces constantly, and the
public is not being made aware of this real and present danger, for fear there will be a
grass-roots uprising against it before they are saddled with [wind parks] and dont
have any more say-so in the matter. (Brougher, 2008).

Tower failure for utility-scale turbines is characterized by vertical collapse (like a
beverage can crushing when stepped on), rather than tipping over from the base.
Tower construction standards should guide setback distances, rather than the remote
possibility of tower tip-over.
Ice throw and blade failure resulting in parts hurtling through the air are
increasingly rare. Modern turbines are continuously monitored in real time and will
shut themselves down if ice accumulates on blades. Ice shedding is thus almost
exclusively limited to the zone directly underneath the turbine.

Table ES-3 (Continued): Typology of Anti-Wind Park Arguments

ES-10
Safety (continued)
Ice-throw
Blade failure
Tower failure
Setback distances of 1.5 times turbine height (tower plus blade) should be considered
maximal. Neighbors should have the right to waive setback distances from
participating buildings and property lines. Wind-park owners (and insurers)
should be liable for damages caused by ice throw, blade failure, and tower failure.
An escrow account should cover potential liability and decommissioning costs.
Property Values
Visual amenity
Sense of place,
of community
Industrial appearance
Tourism impacts
The days on market was more than double for those properties inside the
windmill zones. The sold price was on average $48,000 lower inside the windmill
zones than those outside. The number of homes not absorbed (not sold) was 11% vs.
3%. (Luxemburger, n.d.).

There are people who cant sell their homes and are forced to rent other living
accommodation and people who sell their homes to the wind energy companies at
much reduced prices and then are gagged from talking about any of the negative
health effects (Chevalier, n.d.).

The degradation these enormous sprawling industrial complexes bring to our
cultural and visual resources is least understood. Our colleagues describe West
Texas today as an alien landscape where one can drive for miles and miles and miles
(and miles) and see nothing but wind turbines. The nighttime experience is even
more surreal with the blinking red lights. (Industrial Wind Action Group, 2005).

Wildlife and Natural
Features
Avian mortality
(birds and bats)
Habitat destruction,
fragmentation
Whered all the animals go? My guess is as far away from those things as they can
get. (Brougher, 2008).
Save the Eagles International wishes to warn the international community about the
threat that windfarms and their power lines represent for biodiversity. Unlike cars,
buildings, and domestic cats, wind turbine blades and high tension lines often kill
protected or endangered birds like eagles, cranes, storks, etc. Cumulatively and over
the long term, 3.5 million wind turbines to be installed worldwide will cause the
extinction of many bird species, some of them emblematic. (Duchamp, 2011).

Exclusion zones should be identified in concert with state and federal wildlife
agencies based on the best available scientific information and pre- and
post-construction monitoring. Mitigation measures should be identified and included
in siting stipulations. Mitigation funds should be included in escrow accounts as
necessary to ensure compliance.
Energy Policy
Capacity factor
Emissions effects
Integration costs
Reliability
The erratic nature of the wind means that turbines simply cannot supply the base
load that other forms of generation do. Those other generators will continue to be
needed to back up the wildly variable output of wind turbines, with the probability
that in so doing these plants will actually emit more pollution for each kilowatt-hour
they generate than if they were allowed to operate normally. (Roberson, 2004).
[S]ome reliable, dispatchable generating unit(s) must be immediately available at
all times -- and operating at less than peak efficiency and capacity -- to "back up"
the unreliable wind generation. The reliable, backup unit(s) must ramp up and down
to balance the output from the wind turbines. Wind turbines have virtually no
capacity value. Thus, electric customers pay twice: once for the wind energy and
again for reliable capacity. (Schleede, 2005).

Table ES-3 (Continued): Typology of Anti-Wind Park Arguments

ES-11
Energy Policy (continued)
Capacity factor
Emissions effects
Integration costs
Reliability
Peak power during the hottest summer months [is] far more demanding on the
power grid, yet the wind power available in the winter months is on average
greater than in the summer. Thats a huge contradiction . Nor can we store wind
power . So for the most part, winter winds and spring storms must either be
wasted, or they will create surges which blow out the transformers, power
equipment, and burn up their own generators, and set the grid back hundreds of
millions of dollars, as has happened by wind surges in Oregon, and many times in
Denmark, Germany, and other nations . (Brougher, 2008).
In high winds, ironically, the turbines must be stopped because they are easily
damaged. (Brougher, 2008).
A nuclear plant is tens of times cheaper and thousands of times safer per
[terawatt-hour] than gigantic air turbines will ever be even if we learn someday
how to prevent them from burning up, blowing the grid, and folding in half under a
high wind load, and blending our birds with the landscape. (Brougher, 2008).

The only relevance to siting and zoning might be for substations and transmission
facilities, which also need approvals. None of these other issues are siting and
zoning issues, per se.
Economic Development
Subsidies
Employment
Tax avoidance not environmental and energy benefits has become the prime
motivation for building wind farms. Wind farms produce few local economic
benefits and such benefits are overwhelmed by the higher costs imposed on electric
customers through their monthly bills. When the expected contribution of wind
energy toward supplying US energy requirements is taken into account, wind energy
is among the most heavily subsidized of all energy sources. (Schleede, 2005).
[I]nvestment dollars going to "renewable" energy sources would otherwise be
available for other purposes that would produce greater economic benefits. Wind
farms have very high capital costs and relatively low operating costs compared to
generating units using traditional energy sources. They also create far fewer jobs,
particularly long-term jobs, and far fewer local economic benefits. Wind farms are
simply a poor choice if the goals are to create jobs, add local economic benefits, or
hold down electric bills. (Schleede, 2011).
[B]illions of [federal grant] dollars all of it exempt from federal corporate
income taxes is being used to fatten the profits of some of the worlds biggest
companies (Bryce, 2011).

These are not relevant siting and zoning concerns.

ES-12
Table ES-4: Best Practices for Procedures

Recommendation Description
1. Develop procedures that result in clarity,
predictability, and transparency
Jurisdictions with locations suitable for commercial wind
development should anticipate interest and proceed to
develop and publish siting and zoning procedures,
principles, and guidelines.
2. Establish a one-stop, pre-submission
consultation
Provide basic information for applicants in a single
meeting, identifying and explaining the basics of all
necessary permits and approvals.
3. Identify and map constrained and preferred
wind energy development zones
Make available and accessible to the interested public
GIS maps of exclusion, avoidance, and preferred
development zones.
4. Include preferred development zones in
transmission plans
Begin modeling and planning for wind power
interconnections in preferred development zones as soon
as the zones are identified.
5. Prepare and make available guidelines for
participants
Explain procedures and timelines for when, where, and
how to participate in public hearings. Provide
information about decisions already completed through
rulemaking.
6. Prepare and make available for local siting and
zoning officials guidelines, checklists, and
model ordinances
Support local government decision makers by providing
the best available technical resources.
7. Ensure the sequence for obtaining permits and
approvals meets requirements to allow
development of suitable projects
The sequence of events leading to approval or rejection
of an application should entail a logical progression
through the planning and design stages, prior to siting
and zoning approval that allows construction to begin.

Table ES-5: Wind-Park Siting and Zoning Criteria,
Recommended Approaches and Setback Distances

Criterion Recommended approach
Noise, sound, and
infrasound
Noise standards should allow some flexibility.
Noise standards should vary depending on the areas existing and expected land uses,
taking into account the noise sensitivity of different areas (e.g., agricultural, commercial,
industrial, residential).
Determine pre-construction compliance using turbine manufacturers data and best
available sound modeling practices.
Apply a planning guideline of 40 dBA as an ideal design goal and 45 dBA as an
appropriate regulatory limit (following Hesslers proposed approach, 2011).
Allow participating land owners to waive noise limits.
Establish required procedures for complaint handling.
Identify circumstances that will trigger, and techniques to be used for: (a) mandatory
sound monitoring; (b) arbitration; and (c) mitigation.
Do not regulate setback distance; regulate sound.
Shadow flicker Restrict to not more than 30 hours per year or 30 minutes per day at occupied buildings.
Allow participating land owners to waive shadow-flicker limits.
Allow the use of operational practices and mitigation options for compliance.
Do not regulate setback distance; regulate the duration of shadow flicker.

Table ES-5 (Continued): Wind Park Siting and Zoning Criteria,
Recommended Approaches and Setback Distances

ES-13
Ice throw Authorize demonstrated ice control measures.
Require wind-park to provide insurance and escrow funds to ensure compensation for
proven damages resulting from ice throw.
Do not regulate setback distance; regulate ice throw.
Wildlife and habitat
exclusion zones
Responsible wildlife protection agencies should use the best available scientific
knowledge and data to determine exclusion and avoidance zones and appropriate buffers
(that is, setback distances) beyond those zones.
Permits should specify required pre-, during-, and post-construction monitoring.
Permits should specify how mitigation requirements will be determined and what
mitigation techniques will be considered.
Regulate setback distances as required by responsible wildlife protection agencies and do
not authorize siting in exclusion and buffer zones.
Aesthetic
requirements
Require neutral paint color and minimal signage.
Require the minimum of nighttime lighting necessary to achieve FAA compliance.
Require that realistic visual impact assessments, accessible to the public, be included in
wind park planning and applications.
Manage visual impact through setbacks and exclusions from critical competing land uses.
Critical competing
land uses
Map as excluded zones any special cultural, anthropological, sacred lands, and highly
valued scenic vistas.
Apply reasonable setbacks from non-participating property lines, occupied buildings,
scenic vistas, and transportation and utility rights-of-way.
Allow participating properties to at least partially waive setback requirements from
property lines and occupied buildings, in writing.
Permit requirements
for met towers,
construction, and
facility safety
Predetermine requirements and simplify procedures for approving meteorological (met)
towers.
Regulate heavy construction requirements the same as any other heavy construction
project, using the regulatory permitting system (e.g., for stormwater, surface water,
transportation, noise, and wetlands permits).
Check for all required approvals for potential interference with radio and TV reception or
radar. Provide for testing and mitigation of radio and TV interference problems that do
occur.
Regulate structural safety (against, e.g., tower tip-over or blade failure) through
construction codes, combined with minimal setback requirements.
Regulate facility safety (e.g., preventing climbing towers, ensuring electrical safety,
providing fencing around electrical gear).
Decommissioning Set clear requirements for what triggers and what constitutes decommissioning and
restoration or reclamation.
Establish a decommissioning escrow fund, to ensure adequate resources will be available
at the end of a projects useful life or in the event the development fails.
Dispute resolution and
mitigation
Establish procedures for dispute resolution and mitigation.

ES-14
The report ends with a summary and conclusions. This part reviews important literature on wind siting
and zoning and asks: (1) Is there a middle ground that does not require compromises where everyone
loses? and (2) Are there opportunities for improvement in wind-park siting and zoning procedures that are
most likely to lead to a more rapid accumulation of the information and wisdom needed to guide future
decisions?

Among researchers studying wind-park siting, there is at least some optimism regarding finding answers
to these questions. For example: Wolsink (2007a) suggests that better solutions will be found through
collaborative, community-based planning; Upham (2009) proposes that solutions might be found through
focused attention on the field of environmental psychology; Sovacool (2009) advises attention to a
broader research agenda about both social and technical aspects of decision making; and Sengers, Raven,
& Van Venrooij (2010) recommend a concentrated study of news media and the potential role of news
media in public education regarding decisions about our energy future. Any and all of these paths might
prove advantageous.

For the time being, the most sensible recommendation is for communities to work together to make
decisions about future energy systems development, not only wind energy development, in their local
area. There are multiple paths to this goal, insofar as wind energy development is concerned. Some
developers work extensively with host communities, prior to seeking siting and zoning approval, to create
macro- and micro-siting plans that engender little, if any, public opposition. Some land owners form
associations and hire their own developers, so that the owners can directly guide decisions about setback
distances and micro-siting. Some governments simultaneously develop specific plans that identify both
areas where wind parks will be excluded or should be avoided and also those areas where wind parks will
be welcomed. Hindmarsh (2010, p. 560) holds that making good decisions about wind turbine siting
requires collaborative approaches, including the technical mapping of wind resources [and]
community qualifications and boundaries for wind farm location. He argues that community-based
decision making is likely to result in improved problem framing and decision making concerning wind
farm location, and thus development. The goal, as Hindmarsh notes, is a process that will be perceived
as legitimate and fair, and thus sustainable. Reaching that goal might be considered overly optimistic, but
at least some communities have shown a willingness to give it a try. There is at least a good prospect that
these approaches can reduce contentiousness and move towards consensus on how to guide wind-park
siting and zoning.

1
Introduction

Wind-park siting and zoning present serious challenges. Modern utility-scale wind turbines are tall, rather
imposing structures. Their construction often represents a significant change to what were previously
open rural and agricultural landscapes. In many circumstances, modern wind turbine towers, which are
roughly 25 stories tall, are by far the tallest structures being constructed in landscapes that have
previously been rural and agricultural in character, containing no structures taller than silos.

Wind-park siting and zoning is frequently contentious, due to a variety of concerns regarding public
acceptance and opposition. Already, wind siting and zoning cases have been heard in courts of appeals
and supreme courts in multiple states.
2

Often, officials with no previous expertise in wind energy systems have been tasked with developing the
rules and regulations that ultimately guide wind power siting and zoning decisions, which then directly
affect the planning, design, development, construction, and operations of wind parks.

It is axiomatic that all energy sources known today come with some unintended consequences, and
perhaps also unanticipated consequences, and cause some negative side effects. Thus, the siting and
zoning of any new energy facility is likely to raise concerns among potential neighbors. Local opposition
groups form and try to influence siting and zoning for practically all new power plants, transmission lines,
and substations. Thus, public officials who are charged with the task of recommending and making siting
and zoning decisions often face competing, widely divergent views of the benefits and costs, pros and
cons associated with new energy facilities. Wind generators and wind parks are a prominent example,
perhaps the prominent example, of this local opposition phenomenon.

Is the ideal siting and zoning hearing one that has no controversy, where full consensus is reached on the
part of all stakeholders? That goal can be impossible to achieve. The goal of the siting and zoning
decision maker should be fact finding to support objective decision making, in keeping with the enabling
siting and zoning laws and rules.

The purpose for this report is to provide guidelines about how best to manage the siting and zoning
process and apply siting and zoning principles to wind-park decision making. Part II.A covers the siting
and zoning process, and Part III covers recommendations about the specific criteria and principles used in
making wind-park siting and zoning decisions. Applying best practices will enable policymakers to
accelerate as much as practical the time requirements for siting and zoning procedures, while
simultaneously helping to develop the full potential of wind energy and minimizing project risks.

This paper summarizes knowledge about the state of the art in wind-park
3
and wind-turbine siting and
zoning, to support decisionmakers efforts to develop and implement good siting and zoning practices.
It draws on a survey of practices in all 50 states plus some U.S. territories and protectorates to explicate
and report on current practices and principles. The survey results are presented in Appendix A.

2
Wind siting and zoning cases have already appeared in state supreme courts in Kansas, New York, Texas,
Vermont, Washington, and West Virginia, and in state appeals courts in California, Indiana, Maryland, Minnesota
and Wisconsin (Google Scholar, Advanced Scholar Search for legal opinions, retrieved 7 Dec 2011; Minnesota
Appeals Court, Cases Nos. A112228 and A112229, http://macsnc.courts.state.mn.us/ctrack/publicLogin.jsp,
retrieved 5 Jan 2012).
3
In this document, the term wind park is used to refer to installations of multiple utility-scale wind turbines.
Frequently used synonyms are wind development, wind farm, or wind project. Utility-scale does not have
any certain definition. For the purposes of this paper, utility-scale can be understood to mean wind generators that
are typically about 1.5 megawatts (1,500 kilowatts) or larger, mounted on towers that average about 80 meters
(roughly 250 feet) in height or taller.

2

As Ellenbogen et al. (Jan 2012, p. ES-8) explain,

Implicit in the term [best practice] is that the practice is based on the best information available
at the time of its institution. A best practice may be refined as more information and studies
become available.

Though this research has been informed by the survey of states, the goal was not to determine best
practices simply by popularity. As much as possible: (a) best practices for procedures are determined by a
review of literature about public decision-making processes, with particular focus on procedural justice
and public participation; and (b) best practices for the criteria and principles involved are determined by a
review of the literature about siting and zoning law and the best available information about the
relationships between wind parks and siting and zoning.

The focus for this project is almost exclusively on utility-scale wind turbines and wind parks for siting
and zoning on the land. A few of the state survey reports (California, Minnesota, New Hampshire,
Oregon, and Wisconsin) include information specifically about siting and zoning for small wind
turbines.
4
Those states provide detailed information about siting and zoning standards and procedures
exclusively for small wind. Off-shore wind energy development is not included in this study either,
though it is a topic of interest in Atlantic, Gulf Coast, Pacific, and Great Lakes states.

Part I of this paper reports on the current status of wind siting and zoning, based on a survey of states and
other jurisdictions and information gleaned from a review of published literature about wind siting and
zoning. Part II reviews and identifies best practices for the procedures used in wind energy siting and
zoning. Part III presents guidelines for addressing the specific criteria used to determine wind-park siting
and zoning. That part of the report identifies the criteria commonly used and includes the best available
information about applying those criteria to determine siting and zoning practices. That discussion is
followed by a brief summary and conclusions.

4
Small wind does not have a certain definition. Generally, small wind systems are those that might be installed in
a residential or commercial area to produce electricity for on-site use by a single residence, farm, or commercial
facility. Typical small-scale wind generators produce less than a few hundred kilowatts, sometimes as few as one to
ten kW, and they are mounted on towers no taller than about 150 feet. For more information see
http://www.windpoweringamerica.gov/small_wind.asp, retrieved 7 Jan 2012.

3

I. Current Status

Taken as a whole, the experience with wind-park development has been quite positive. Given the large
numbers of turbines installed and operating, and experience in some locations totaling 20 years and more,
there have been relatively few complaints. As shown in Figure 1, 42,432 MW of wind generation had
already been installed in the U.S. by late 2011.
5

Figure 1: NREL Map of Currently Installed Wind Capacity by State

Source: http://www.windpoweringamerica.gov/images/windmaps/installed_capacity_current.jpg.
See also http://www.windpoweringamerica.gov/wind_installed_capacity.asp.

By September 2011, 14 U.S. states had more than 1,000 MW of installed wind capacity (California,
Colorado, Iowa, Illinois, Indiana, Kansas, Minnesota, North Dakota, New York, Oklahoma, Oregon,
Texas, Washington, and Wyoming). Survey data from these states is summarized in Table 1, with the
states ranked installed capacity (as reported in Figure 1). Among the 14 states with over 1,000 MW of
installed capacity, only Wyoming has neither a mandatory renewable portfolio standard nor a voluntary

5
Data sources used to generate Figure 1 focus almost exclusively on commercial, utility-scale wind
generators. Small-scale (residential or small commercial) wind generators are typically not included. This
maps data for each state is copied into Table 1, Column 2.

4

renewable portfolio goal. Indiana, North Dakota, and Oklahoma have voluntary goals. The other ten states
that are leaders in installed capacity have mandatory standards. Eleven of these 14 states have RPS
policies that promote in-state facility development.

Another 14 states had between 100 and 1,000 MW (Arizona, Idaho, Maine, Maryland, Michigan,
Missouri, Montana, Nebraska, New Mexico, Pennsylvania, South Dakota, Utah, Wisconsin, and West
Virginia). Five states had between 20 and 100 MW (Hawaii, Massachusetts, New Hampshire, Ohio, and
Tennessee). Five states had between one and 20 MW (Alaska, Delaware, New Jersey, Rhode Island, and
Vermont). A dozen states, notably many in the Southeast, had no commercial wind development at the
time (Alabama, Arkansas, Connecticut, District of Columbia, Florida, Georgia, Kentucky, Louisiana,
Mississippi, North Carolina, Nevada, South Carolina, and Virginia).

In many areas, wind parks have been developed with little controversy, resulting in few if any reported
problems. Where problems have occurred, though, they have attracted significant news media and public
attention, sometimes followed by litigation. In particular places, wind parks have been responsible for
bird and bat kills that concern wildlife conservation agencies. In others, relatively small numbers of wind-
park neighbors report persistent, acute, and chronic problems and concerns.

Because of the reported problems, in many jurisdictions siting and zoning hearings become a major focal
point for opposition groups, who are intent on protecting themselves and their communities from what
they believe is a land-use intrusion that will result in irreversible negative effects. Although typically
relatively small numbers or percentages of the population come out against wind-park development,
public opposition, when it does arise, tends to be vocal and intense. It is also common that citizens who
generally favor wind-park development represent what could be called a silent majority of people who
are less motivated to participate in siting and zoning hearings.

Wind energy siting and permitting practices in the U.S. are mainly influenced by three factors in each
state: (1) preexisting siting and permitting practices for other kinds of energy facilities; (2) renewable-
energy support policies, especially renewable portfolio standard (RPS) or broader clean energy standard
(CES) policies; and (3) public acceptance.

State-level wind siting and zoning responsibility is more likely where preexisting policies have already
vested energy facility siting responsibility with a state agency. In those circumstances, state authorities are
most likely to be charged with weighing applications for wind parks larger than some particular,
legislated minimum capacity.

State renewable-energy support policies have focused some attention on wind-park development,
especially in the 37 states that have adopted policies setting either mandates or goals for increasing the
use of renewable energy.
6
Most U.S. states renewable energy support policies use quota systems that rely
on auctions to select renewable energy projects to receive power purchase agreement (PPA) contracts for
the sale of electricity. Those auctions tend to favor wind parks, because the price of energy from wind
parks in locations with commercially viable wind resources is generally lower than that for other
renewable energy options.

Also, many state renewable energy support policies favor in-state electricity generation, one way or
another.
7
These policies, especially those that focus on in-state renewable resources, have encouraged

6
See RPS Policies at Database of State Incentives for Renewables & Efficiency, Dec 2011, Summary maps [web
page], http://www.dsireusa.org/summarymaps/index.cfm?ee=1&RE=1, retrieved 8 Dec 2011.
7
Various policies promote in-state renewable energy production and use. These are briefly summarized in Table 1.
For details, see: Database of State Incentives for Renewables & Efficiency, http://www.dsireusa.org/rpsdata and
http://www.dsireusa.org/incentives/index.cfm?SearchType=RPS&&EE=0&RE=1, retrieved 22 Dec 2011. See also
the discussion about tilt policies in Grace, Donovan, and Melnick, 2011, especially pp. iii, 10-12.

5

wind prospectors to investigate opportunities in practically all of the windiest areas in the country, even
areas with more potential siting and zoning obstacles.

Public acceptance, broadly speaking, depends on features of the landscapes where wind developments are
proposed, such as housing density or the lack thereof, the perceived existence and importance of scenic
beauty, and whether the areas are considered to be natural or already disturbed by human activity. The
current status of public acceptance varies widely in different regions of the country and even in different
jurisdictions within states. In states where local authorities have responsibility for wind-park siting and
zoning, it is not at all unusual to find some townships or counties adopting ordinances intended to restrict
or prevent development, while others are adopting development-friendly ordinances.

Unsurprisingly, wind-park developers have generally focused first on those areas with fewer obstacles to
siting and zoning. The tendency is for wind parks to be built first in the windiest areas (where the
economics are most favorable) and in landscapes with the fewest environmental and political obstacles to
development. Barriers to development are varied, though, depending on factors such as population density
and suburbanization, as well as concerns about potential negative effects on wildlife and special habitats.
Barriers can also include cumbersome or uncertain and unpredictable state and local siting and zoning
procedures and practices.

Part I.A of this report briefly summarizes state wind-park siting and zoning procedures and principles,
based on information gleaned from the state survey data that is presented in Appendix A. Part I.B
summarizes the nature of wind-park opposition, and lists the major concerns raised by opposition groups.

A. Summary information from the survey of state practices

This part of the report summarizes information gleaned from the survey of state wind energy siting and
zoning practices and principles. The surveys were completed beginning in the summer of 2011. NRRI
student interns and staff searched the Internet to find references about practices in each state. Once that
data was compiled, preliminary surveys were circulated to in-state contacts deemed as most likely to be
knowledgeable about the states practices. The in-state contacts were asked to review and help edit the
survey data and the contacts were always invited to forward the survey data to others who were likely to
be familiar with the states practices. Surveys are considered complete only after they have been reviewed
and accepted as accurate by one or more in-state experts.
8

The completed surveys are attached in Appendix A. Findings from the surveys are summarized in Table 1
(pages 6-10). The rest of Part I.A (pages 11-14) reports on the data presented in Table 1 and presents
some additional summary information gathered from the survey reports. Table 2 (pages 11-12) shows a
copy of the same data as Table 1, but only for those 14 states identified in Figure 1 as having more than
1,000 installed MW of wind capacity. In Table 2, the 14 states are ranked in descending order, based on
installed wind capacity.

8
Names of the individuals responsible for the original data collection and in state reviewers are shown at the end of
each states survey record. As of this publication date, reviews are yet to be completed for 12 states. The authors
intend to continue efforts to update the survey reports, as needed, to keep them up to date. The most current survey
data will be published on the NRRI website, in the area devoted to wind energy information.

6

Table 1: Summary of State Wind Siting and Zoning Practices

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Alabama 0 State CPCN from PSC (P) Dillons
Alaska 10 State CPCN from RCA (P) Home 1
Arizona 128 Local Dillons Y W 1 M BD WREZ
Arkansas 0 Local CPCN from PSC (S) Home
Quality Act (S)
Dillons Y 6 M L
Y,
WREZ
Dillons Y M BL
Y,
WREZ
Connecticut 0
State
(>1 MW)
CECPN from Siting Council
(>1 MW) (P), DEEP checks
congruence with IRP (S)
Y Home Y M LR
Delaware 2 Local Certification from PSC (S) Dillons Y Y Y M B
District of
Columbia
0 PUC Approval from PSC (P) n/a M DL
Florida 0
State
(<75MW)
DOT, FAW (<75MW) (P) Y
12
Y
Georgia 0 Local Dillons YW Y Model Model
Hawaii 93 Local Permit from PUC (S) Dillons M M
Idaho 471 Local Dillons 1 WREZ
1
See all table notes at the end of the table, on page 10. See Appendix A for more detailed information about each states practices.

Table 1 (Continued): Summary of State Wind Siting and Zoning Practices
7
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Iowa 3,675
Both
(>25MW)
Home Y 5 M U RGOS
Kentucky 0 State
Siting Board Approval
(>10MW) (P)
Dillons RGOS
Louisiana 0 Local Permit from DEQ (S) Dillons
Maine 266
State
(>20 acres)
13

Permit from DEP (>20
acres) (P), Permit from
LURC (for unorganized
areas)
13
(P)
Dillons Y 8 M BL
Maryland 120
State
(70MW)
CPCN from PSC (70MW)
(P), 7 state agencies notified
(S)
Y Dillons Y W 15 M LR
Massachusetts 38
State
(>100MW)
Permit from Energy
Facilities Siting Board
(>100MW) (P)
Home Y Y Model Model 2 M L
Michigan 164 Local
PSC checks utility-owned
and PPA projects for
compliance with a utilitys
renewable energy plans (S)
Y Home Y Y 11 M BS
Y,
RGOS
Minnesota 2,518
State
(>5MW)
(P)
Mississippi 0 State CPCN from PUC (P) Dillons
Missouri 459 Local Dillons 1 M RGOS
Montana 386 Local Home Y M D
RGOS,
WREZ

8
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Nebraska 294
State
(>80MW)
12

Approval from Nebraska
Power Review Board
(>80MW)
12
(P)
Dillons Y 4
Nevada 0 Local
Permit from PUC
(70MW) (S)
Y Dillons M
Y,
WREZ
New
Hampshire
26
State
(30 MW)
COSF from Site Evaluation
Committee (30MW) (P)
Dillons Y M DR
New Jersey 8 Both
Interconnection authority
falls to PJM RTO (S)
(see New Jersey survey)
Y Home Y 10 M DLR
New Mexico 700
State
(>300MW)
CPCN from PRC (P) Home Y W M WREZ
(S)
Dillons Y YW Y Model Model 1 M L
North
Carolina
0 Local CPCN from NCUC (S) Dillons Y Y 9 M L
North Dakota 1,424
State
(>0.5MW)
CSC from PSC (P), 21
State Agencies notified (S)
Dillons Y 3 G RGOS
Ohio 67
State
(5MW)
CECPN from Power Siting
Board (5MW) (P)
Home Y M RGOS
Oklahoma 1,482 Local Y Dillons G M
Oregon 2,305
State
(>105MW)
(>105MW) (P)
Home Y 1 M BR
GBS,
WREZ
Pennsylvania 751 Local Y Dillons Y Y Model Model 4 M LR
Rhode Island 2
State
(40 MW)
Approval from Energy
Facility Siting Board
(40 MW) (P)
Home Y Y Y Y M

9
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

South
Carolina
0
State
(>75MW)
CPCN from PSC
(>75MW) (P)
Y Dillons
South Dakota 784 Local
Permit from PUC
(>100 MW) (S)
Y Dillons Y Y Y Y

4 G

RGOS
Tennessee 29 Local Dillons
Texas 10,135 Local
PUC (S)
Utah 325 Local CCN from PSC (S) Home Y Y Model Model 3 G R
Y,
WREZ
Vermont 6 State COPG from PSB (P) Dillons Y G M
Virginia 0 Local
Permit from
DEQ 100 MW (S),
SCC >100 MW (S)
Dillons Y Y Y 3 G
Washington 2,356
State
(>350MW)
Site Certification
Dillons W M DR
GBS,
WREZ
West Virginia 431 State CPCN from PSC (P) Y Dillons G BR
Wisconsin 469 Local
CPCN from PSC
(>100MW) (S)
Dillons Y
10
4 M D RGOS
Wyoming 1,412
State
(30 turbines)
(P)
Dillons Y Y WREZ

10
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Table Notes: See also the individual survey reports for each state, presented in alphabetical order by state name, in Appendix A.
1
Source data for Column 2 is Figure 1 (p. 3).
2
Column 3 indicates Local when the primary siting authority rests with the local (county or municipal) government or State when primary authority is with the state.
Any Limit means that a wind-park size criterion (number of turbines in Wyoming, acres in Maine, or capacity number of MW in 14 states) determines
jurisdiction. In those circumstances, wind parks larger than the expressed limit trigger state authority. Both applies to Iowa and New Jersey, where siting authority is
held by both the state and local units of government.
3
Column 5: Y for yes indicates there is a state energy facility siting council or board separate from the state public utility commission.
4
Column 6 distinguishes between Home Rule states and Dillons Rule states. See p. 10 for the discussion.
5
Columns 7 and 8: Y means yes, the state does have mandatory evaluation criteria (Column 7) or voluntary guidelines (Column 8). A W in either column means
primarily or exclusively for wildlife. States with both Y and W in either column means multiple documents exist, one focused explicitly on wildlife.
6
Columns 10 and 11: Y indicates that standards are included in evaluation criteria. Model means that criteria are included in a model ordinance.
7
Column 12: The number in Column 12 represents the ordinances included in a database being assembled by the National Renewable Energy Laboratory, available from
http://www.windpoweringamerica.gov/policy/ordinances.asp, retrieved 22 Dec 2011.
8
Column 13: M means the state has a mandatory renewable energy portfolio standard. G means the state has a voluntary goal for renewable energy. See Database of
State Incentives for Renewables & Efficiency, 2011, Portfolio Standards/Set Asides for Renewable Energy [web page] and RPS Policies [map],
http://www.dsireusa.org/incentives/index.cfm?SearchType=RPS&&EE=0&RE=1, retrieved 22 Dec 2011.
9
Column 14: Many state RPS programs include provisions to promote in-state renewable energy facilities, such as wind parks. A recent NRRI Report (Grace, Donovan,
& Melnick, 2011) calls this a tilt policy (intended to tilt the playing field towards certain technologies). In Column 14: B means a bonus credit for at least some
in-state facilities; D means electricity must be delivered into the state (or DR means delivered into the region) in order to qualify; L means a maximum limit on
energy from out-of-state facilities or conversely a minimum limit on energy from particular kinds of in-state resources; M means a mandate for in-state generators;
R means a mandate for regional generators; S means qualifying facilities must be in the service territory of a utility providing retail service in the state; and U
means a mandate for a utility serving the state to own or contract for the qualifying renewable energy. Source: Database of State Incentives for Renewables &
Efficiency, 2011, http://www.dsireusa.org/incentives/index.cfm?SearchType=RPS&&EE=0&RE=1, retrieved 5 Jan 2012.
10
Column 15: REZ means Renewable Energy Zone(s). Coding indicates Y if there is a specific state process for determining zones (in Texas, Colorado, Utah,
Michigan, and Nevada). Other codes include: WREZ for the Western Renewable Energy Zones process for 5 states); RGOS for the Regional Generation Outlet
Study process at the Midwestern Independent [Transmission] System Operator (MISO) for parts or all of 12 states; GBS for the Gorge Bi-State Renewable Energy
Zone, which includes six counties near the Columbia River in both Oregon and Washington.
11
Wisconsins Model Ordinance applies only for small wind systems, <100kW in capacity.
12
Nebraskas >80MW limit applies only if the planned capacity would cause the utilitys total renewable energy production to exceed the companys goal.
13
Maines state authority applies if the proposed wind-park involves greater than 20 acres of land, or if the wind-park will be sited in an unorganized area.

11

Table 2: Summary of State Wind Siting and Zoning Practices
(Top Ten States, Ranked by 2011 Installed Commercial Wind Generating Capacity in MW)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

P
r
i
m
a
r
y

R
u
l
e
3

E
v
a
l
u
a
t
i
o
n

C
r
i
t
e
r
i
a
5

V
o
l
u
n
t
a
r
y

G
u
i
d
e
l
i
n
e
s
5

M
o
d
e
l

O
r
d
i
n
a
n
c
e

S
e
t
b
a
c
k

S
t
a
n
d
a
r
d
6

S
o
u
n
d

S
t
a
n
d
a
r
d
6

L
o
c
a
l

O
r
d
i
n
a
n
c
e
s
7

R
P
S
8

R
P
S

I
n
-
S
t
a
t
e

T
i
l
t
9

R
E
Z
1
0

Texas 10,135 Local
PUC (S)
Quality Act (S)
Dillons Y 6 M L
Y,
WREZ
Iowa 3,675
Both
(>25MW)
Y Home Y 5 M U RGOS
Minnesota 2,518
State
(>5MW)
(P)
Washington 2,356
State
(>350MW)
Site Certification
Y Dillons W M DR
GBS,
WREZ
Oregon 2,305
State
(>105MW)
(>105MW) (P)
Y Home Y 1 M BR
GBS,
WREZ
Oklahoma 1,482 Local Dillons G M
North Dakota 1,424
State
(>0.5MW)
21 State Agencies notified
(S)
Dillons Y 3 G RGOS
Wyoming 1,412
State
(30 turbines)
(P)
Y Dillons Y Y WREZ
1
See all table notes at the end of Table 1, on page 10. See Appendix A for more detailed information about each states practices.

(Top Ten States, Ranked by 2011 Installed Commercial Wind Generating Capacity in MW)

12
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
State
M
W

I
n
s
t
a
l
l
e
d
1

P
r
i
m
a
r
y

A
u
t
h
o
r
i
t
y

(
L
i
m
i
t
)
2

P
r
i
m
a
r
y

(
P
)

o
r

S
e
c
o
n
d
a
r
y

(
S
)

S
t
a
t
e

A
u
t
h
o
r
i
t
y

S
t
a
t
e

E
n
e
r
g
y

S
i
t
i
n
g
4

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13

1. Responsibility for siting and zoning and certificates of necessity:
state, local, or both

The factors summarized here are entered in Table 1, columns 3, 4, and 5. Column 3 indicates whether the
primary wind siting and zoning authority in the state rests with the local government, state government, or
both. The primary decision-making authority resides with local governments in 26 states and state
governments in 22 states. Florida and Iowa have shared local and state responsibility. Column 4 includes
a (P) to indicate a state agency has primary siting authority. Many states have a clearly defined
secondary authority, as indicated by (S) in column 4. Often the secondary authority is responsible for
determining whether a proposed wind-park meets the standards necessary to be granted a certificate of
public convenience and necessity, or the equivalent. Secondary authority is frequently not explicitly for
siting or zoning, but approvals from a primary siting and zoning authority can be one criterion needed to
obtain approval from a secondary authority. If there is a state agency responsible for energy facility siting
other than the states public utility commission (PUC),
9
column 5 includes a Y.

In six states plus the District of Columbia the PUC is responsible for siting and zoning utility-owned wind
parks. The states include Kentucky, Minnesota, New Mexico (for facilities >300MW in capacity), North
Dakota, Virginia (for facilities >100MW), and West Virginia.

Twenty-three states and the District of Columbia require a certificate from the PUC. This is typically
called a certificate of public convenience and necessity (CPCN). It represents a determination by the
PUC that the public good will be served by the construction and operation of a particular facility. CPCN
hearings can include information about siting and zoning, and siting and zoning approval can be a
prerequisite to a CPCN, but in many cases the CPCN approval is separate from siting and zoning
approval. In those circumstances, a developer must obtain both siting and zoning approval from one
agency and a CPCN from another. States requiring a CPCN from the PUC include: Alabama, Alaska,
Arkansas, Colorado, Delaware, Hawaii, Indiana, Maryland, Minnesota, Mississippi, Nevada, New
Mexico, New York, North Carolina, North Dakota, South Carolina, South Dakota, Texas, Utah, Vermont,
Virginia, West Virginia, and Wisconsin. CPCN requirements are sometimes triggered only when a facility
will be owned by a public utility, or when a facility is larger than some specific size (as indicated in Table
1, columns 3 and 4).

Eleven other states, indicated with a Y in column 5, have an energy facility siting authority that is
separate from the PUC. These include: Connecticut, Florida, Maine, Massachusetts, Nebraska, New
Hampshire, Ohio, Oregon, Rhode Island, Washington, and Wyoming. It is common for state energy
facility siting to apply only to larger-capacity projects, but the limits triggering state authority range from
as small as 1 MW in Connecticut and 5 MW in Ohio to as large as 300 MW in New Mexico and 350 MW
in Washington. The limits are listed in columns 3 and 4. Commercial wind parks are most likely to be
much larger than those smallest limits, but are often smaller than the largest limits.

No matter what criteria determine the dividing line between state and local authority, developers are
prone to selecting the state or local government venue that they believe offers the greatest chance of siting
and zoning success. Development plans for project size and location are quite likely to be adjusted to
meet particular criteria. This issue has been addressed in a few states already, with policymakers reducing
the project size limit that will trigger state review for wind projects (in Appendix A, see the History of
siting authority reported for North Dakota and Ohio).

9
Different states use different names for the state agency that is the public utility regulatory authority. The most
common names used are public service(s) commission (PSC) and public utility commission (PUC), but several
states use other names. In this paper, the generic term, PUC, is used to represent the relevant commission or board.

14
Whether or not it is stated explicitly in the state summaries in Appendix A, all relevant federal laws apply
to wind siting and zoning decisions. Various federal agencies will have some authority, depending on the
specific locations being considered. These include the following: Army Corps of Engineers (COE),
Bureau of Land Management (BLM), Federal Aviation Administration (FAA), Federal Communications
Commission (FCC), Environmental Protection Agency (USEPA), Fish and Wildlife Service (USFWS),
and U.S. Military. In many circumstances, USEPA requirements are delegated to state (or sometimes
local government) agencies. Illinois publishes this list of federal agency requirements, which is a good
example for all the states:

(1) Federal Aviation Administration (FAA): (a) Determination of No Hazard to Air Navigation;
(b) Notice of proposed construction (form FAA 7460-1); (c) Lighting plan; (d) Post-
construction form (form FAA 7460-2).
(2) U.S. Fish and Wildlife Services (USFWS): Threatened and Endangered Species Act, Section
7 Consultation and Migratory Bird Act.
(3) U.S. Army Corps of Engineers (COE): (a) Clean Water Act: Section 404 - Discharge of Fill
Materials; (b) Rivers and Harbors Act: Section 10.
(4) Federal Communications Commission (FCC): Microwave Studies.
(5) U.S. Environmental Protection Agency (USEPA): Spill Prevention, Control and
Countermeasures Plan (SPCC Plan, 40 CFR112).
(6) U.S. Military: Determination of non-interference with flight operations and radar.

It is also common for state and county departments of transportation to have some oversight regarding
wind-park construction, including plans for the delivery of components to the construction site, road use
during construction, and the disposition of temporary roads after construction is completed.

2. A primary rule about local authority: Home Rule versus Dillons Rule

In Table 1, Column 6 differentiates states into one of two types, according to the primary rule that
governs state versus local authority: Home Rule and Dillons Rule. The original difference would be
found in the state constitution.

Home Rule states grant broad authority and autonomy to local governments. The essence of home rule is
that local governments hold all authority that has not been ceded explicitly to the state or federal
governments, through either the federal or state constitutions or by legislation. Alternatively, Dillons rule
generally holds that all authority not explicitly residing in the federal government is held by the state
government, unless explicitly delegated to local governments through the state constitution or through
state legislation. Therefore, Dillons rule reinforces that some powers should be reserved by states in
order to ensure equality for all.

In practice, though, Dillons rule and home rule are not mutually exclusive. Legislatures in some Dillons
Rule states have explicitly authorized limited home rule for some local governments, usually counties but
sometimes municipalities. Those states include Colorado, Illinois, Kansas, North Dakota, and
Washington.
10
A general expectation might be that Home Rule states would tend to have local authority
and Dillons Rule states would tend to have state authority for wind siting and zoning. In practice, though,

10
Richardson, undated; Sellers, 2010; USLEGAL.COM, Dillons rule law & legal definition and Home rule law &
legal definition, retrieved 22 Dec 2011 from http://definitions.uslegal.com/d/dillons-rule/ and
http://definitions.uslegal.com/h/home-rule/.

15
Home Rule states are evenly split in terms of local versus state authority, but more Dillons Rule states
(20 of 31) have already delegated wind siting and zoning authority to local units of government.

3. Mandatory evaluation criteria, voluntary guidelines,
model ordinances, setback and sound standards, and local ordinances

Data on these factors is included in Table 1, Columns 7 through 12. As shown in Column 7, 27 of the 50
states have published lists of the criteria that are used to evaluate wind siting and zoning decisions.
Washingtons criteria cover only wildlife protection concerns. For the other 23 states and District of
Columbia, the survey did not discover any clear list of evaluation criteria.

Ten states have published voluntary guidelines for wind siting and zoning. Those states are indicated with
a Y in Table 1, column 8, meaning general guidelines, a W meaning guidelines explicitly for
addressing wildlife concerns, or both letters. The ten states include Arizona (explicitly for wildlife),
Georgia, Kansas (including both a general guidelines and wildlife guidelines), Maryland (explicitly for
wildlife), Michigan, New Mexico (explicitly for wildlife), New York (including both a general guidelines
and wildlife guidelines), Rhode Island, South Dakota (including natural and biological resources), and
Vermont. Table 3 indicates with a Y the major factors included in each states guidelines. Michigan is
the only state with guidelines for all the identified topics, but some (e.g., mitigation) are bare mentions,
with no details about how the guideline might be implemented.

Table 3: Factors Included in State Wind Siting and Zoning Guidelines

State Wildlife Aesthetics Birds Bats Noise Setbacks Mitigation Decommissioning
Arizona Y
Georgia Y Y Y Y Y
Kansas Y Y Y Y Y
Maryland Y Y Y
Michigan Y Y Y Y Y Y Y Y
New Mexico Y Y Y
New York Y Y Y Y Y Y
Rhode Island Y Y
South Dakota Y Y Y Y
Vermont Y Y Y

Five states, labeled Y in Table 1, Column 9, have published model ordinances intended to guide local
governments. They include Massachusetts, Minnesota, New York, Pennsylvania, Utah, and Virginia.

As shown in Table 1, columns 10 and 11, a handful of states have published setback standards, sound
standards, or both. Both of these columns differentiate between mandatory standards, indicated Y, and
recommended or advisory standards for local government consideration, indicated Model. As shown in
Table 1, with the exceptions of Minnesota (mandatory sound standard only) and Wyoming (mandatory
setback standard only), all of the other states identified in Table 1, columns 10 and 11, have either both
mandatory or both model setback and sound criteria. Mandatory setback and sound standards are found in
Delaware, Rhode Island, and Virginia. It is interesting to note that these are three states with little
commercial wind energy activity. Model setback and sound standards exist for Georgia, Massachusetts,
New York, Pennsylvania, Texas, and Utah.

16
Table 1, column 12, reports the number of local ordinances that have been discovered and included in a
database being assembled by the National Renewable Energy Laboratory.

In addition to that information that is tabulated in Table 1, the survey reports in Appendix A identify two
states that have published clear procedural steps for wind siting and zoning (Maine and North Dakota)
and two that have published explicit standards for determining wind siting and zoning (Maine and
Minnesota). The Maine and Minnesota standards are more than just lists of the criteria to be considered;
they list both the criteria and how compliance with the criteria will be determined.

Also, six states report that efforts to better define wind siting and zoning practices are presently underway
but incomplete. Connecticut is developing new regulations and presently prohibits acting on pending
wind siting requests until the new regulations are adopted. Iowa and New York are developing new
regulations based on each states respective June 2011 legislation. Maryland has drafted but not yet
implemented new voluntary guidelines that will cover more than the existing guidelines for wildlife only.
Rhode Island is updating its guidelines and reports it might develop a model ordinance as a part of that
effort. Texas, which presently has none, is developing guidelines.

4. Supporting policies: clean energy portfolio standards and goals,
promoting in-state wind energy facilities, and renewable energy zones

As shown in Table 1, Column 13, 29 states and the District of Columbia have renewable energy portfolio
standard (RPS) mandates (M), and eight states have renewable energy goals (G).
11

Column 14 summarizes how 29 of the 37 states with RPS mandates or goals have policies intended to
promote the development of in-state renewable resources, including wind parks.
12
Those policies are
encoded with one, two, or three letter codes. In Column 14: B means a bonus credit for at least some
in-state facilities; D means electricity must be delivered into the state (or DR means delivered into the
region) in order to qualify as eligible to count for RPS compliance; L means a maximum limit on
energy from out-of-state facilities or conversely a minimum limit (often called a carve-out) on energy
from particular kinds of in-state resources; M means a mandate for in-state generators; R means a
mandate for regional generators (usually, in the territory served by a regional transmission organization,
RTO); S means qualifying facilities must be in the service territory of a utility providing retail service
in the state; and U means a mandate for a utility serving the state to own or contract for the qualifying
renewable energy.

Only two states, Connecticut and Michigan, explicitly require utilities to demonstrate that their renewable
energy procurement plans conform with their approved integrated resource plan (IRP) or renewable
energy plan.

Another policy that indirectly supports wind-park siting and zoning is the development of renewable
energy zones. This is reported in Table 1, column 15. Typically, a renewable energy zone (REZ) is
identified through a planning process that includes a general review of wind resources and broad-based,
regional land-use compatibility with wind-park development, combined with electric transmission system

11
The distinctions between mandatory and voluntary RPSs are not always completely black and white. Many
so-called mandatory programs include legislated circuit breakers or off ramps. See the details for each program at
http://www.dsireusa.org/summarymaps/index.cfm?ee=1&RE=1, http://www.dsireusa.org/rpsdata/index.cfm, and
http://www.dsireusa.org/summarytables/rrpre.cfm.
12
RPS tilt policies are not the only means that states use to promote in-state renewable energy facility development.
In addition to specific RPS rules or standards, all states offer at least some financial incentives for renewable energy.
See: Database of State Incentives for Renewables & Efficiency, 2011, Financial Incentives for Renewable Energy
[web page], http://www.dsireusa.org/summarytables/finre.cfm, retrieved 5 Jan 2012; and Hempling, Stanton, and
Porter, 2011.

17
modeling and planning. In most REZ processes, once specific zones are identified, transmission will be
built to interconnect the zone to electricity loads, in anticipation that wind-park development will follow.

States with explicit state-level REZ processes include California, Colorado, Michigan, and Texas. These
are indicated with a Y in column 15. Many other states and utilities are participating in REZ-like
transmission modeling and planning under the auspices of regional transmission organizations. The
Midwest Independent [Transmission] System Operator (MISO) Regional Generation Outlet Studies
(RGOS) have included Indiana, Illinois, Iowa, Michigan, Minnesota, North Dakota, Ohio, South Dakota,
and Wisconsin, plus the Canadian province of Manitoba (MISO, 2011). The Western Renewable Energy
Zone (WREZ) initiative includes Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico,
Oregon, Utah, Washington, and Wyoming, the part of Texas near El Paso, the Canadian provinces of
Alberta and British Columbia, and a small portion of northern Mexico in Baja California (Western
Governors Association, 2009). In addition, the Gorge Bi-State Renewable Energy Zone is an initiative for
six counties near the Columbia River in both Oregon and Washington (www.cgbrez.org/). The U.S.
Eastern Interconnection States Planning Council also includes a workgroup presently working on state
energy zones modeling, for all of the states and Canadian provinces east of the Rocky Mountains (see
http://communities.nrri.org/web/eispc/share-and-view-files-members/-/document_library/view/195538).

B. The nature of wind-park opposition and list of major concerns

But for public opposition, there would be little controversy about wind-park siting and zoning; technical
best practices would determine siting and zoning decisions, and that would be that. Because of strongly
held local concerns, though, public input frequently becomes an important or perhaps the most important
factor in siting and zoning decisions. This is true for both macro- and micro-siting.
13

It should be noted that when decisions are made by local siting and zoning authorities, the decisionmakers
are most likely the neighbors of those who might be opposed. Those local decisionmakers are often
elected officials, too, and there have already been experiences in some jurisdictions where voting for local
officials turns on public sentiment about wind-park siting and zoning decisions. Therefore, the democratic
process, with public input influencing the outcome, is of serious importance.

Wind-park siting opposition is sometimes characterized by pro-wind advocates and developers as a not
in my backyard (NIMBY) attitude held by a small number of area residents who are most likely
aggrieved because they are not going to benefit financially from land-lease payments. Although there can
be a kernel of truth in this observation, academic researchers fault the NIMBY label for multiple reasons
and find that anti-wind sentiments are more nuanced and complex (Devine-Wright, 2004, 2009; Devine-
Wright & Howes, 2010; Eltham, Harrison, & Allen, 2008; Jegen & Audet, 2011; Jones & Eiser, 2009;
Musall & Kuik, 2011; Hindmarsh, 2010; Mooney, 2010; and Wolsink, 2007a, 2007b).

Critiques of the NIMBY label are that it is overly simplistic and pejorative (Musall & Kuik, 2011, p.
3252). A precise definition of NIMBY refer[s] to a situation in which someone has a positive attitude
towards something in general but accompanies this with a motivation to oppose its installation locally,
due to reasons of self-interest (Wolsink, 2007, cited in Jones and Eiser, 2009, p. 4605). As Jones and
Eiser (2011, p. 4605) explain, though,

Many researchers have found that when defined strictly in these terms, NIMBYism is relatively
rare and certainly is too simplistic to be used as a sole explanation for all local opposition to

13
Macro-siting means the general location of a wind park. A macro-site can be thought of as the boundary that
defines the overall areas that are inside and outside an area considered for wind-park construction. Micro-siting
involves the detailed decisions about the placement of each wind turbine, the required access roads, and the
necessary interconnections to the transmission or distribution grid. Micro-siting depends on many factors, including
prevailing winds, technical features of the selected wind turbines, and the precise locations of homes and other
buildings, property lines, exclusion zones, and setbacks around avoidance zones.

18
proposed development [emphasis in original; references omitted]. [A]n often incorrect and
indiscriminate usage of the term has infused NIMBY with derogatory connotation and left it
outdated and lacking explanatory value.

In the context of decisions about wind parks, such NIMBY self-interests most notably could include
concerns about effects on property values, negative perceptions of visual impacts, and fears about noise
and shadow flicker. Countervailing hypotheses about public opposition, however, identify a more
complex set of influential factors [that] include [the] national political environment, local perception
of economic impacts, social influences such as trust and institutional factors such as fairness and
inclusiveness of the planning and execution of the project (Musall & Kuik, 2011, p. 3253). In a public
survey in Cardiff, Wales, Demski (2001, pp. 3-4) found that opinions around wind farms were more
complex and diverse compared to other technologies [and] the majority of people should not be
classified as either strong supporters or strong resisters (of wind farms) and instead can be found
somewhere in between these two positions. As Pasqualetti (2000, p. 385) explains, all kinds of energy
facility developments can encounter public resistance, especially where land is sacred, protected, scenic,
or otherwise sensitive. In particular, he notes, siting a modern wind park changes the out of sight, out of
mind relationship between people and energy production. Thus, researchers are finding that citizen
concerns and opposition is guided by deep-seated issues involving competing land uses and attachment to
place. These issues are most acute in circumstances where wind parks are proposed for areas with
sufficient housing density that potential neighbors concerns are heightened by the prospect of fairly close
proximity among wind turbines and houses. These concepts and the associated lessons for public
engagement and consultation are briefly explored in Part II.E of this report and revisited in the Summary
and Conclusions.

When engaging in siting and zoning procedures, anti-wind groups and individuals arm themselves with
information obtained from anti-wind web sites. Examples include AWEO (www.aweo.org), Industrial
Wind Action Group (www.windaction.org), and National Wind Watch (www.wind-watch.org).
14

Ubiquitous internet access among local activists facilitates the dissemination of anti-wind documents and
thereby tends to focus all local anti-wind groups on the same basic issues and concerns. Table 4
summarizes many of the objections raised by opposition groups. In Table 4, italic font denotes
recommendations for the role that each set of objections ought to play in siting and zoning decisions.
Some of the concerns are not directly relevant to siting and zoning procedures, but experience with
groups opposed to all kinds of locally unwanted land uses (LULUs) demonstrates that opposition groups
typically raise every possible objection (Cockerill, Groothuis, & Groothuis, 2011, p. 10).

14
Website home pages retrieved 12 Dec 2011.

19

Table 4: Typology of Anti-Wind-Park Arguments

Human Health, Nuisance,
and Annoyance Factors
Noise
Infrasound
Shadow flicker
[W]ind farms produce a noise thats hard to comprehend and even more dangerous
to live close to. The beating of the blades have not only their own throbbing sounds,
but beat harmonically together to create a cacophony of audible confusion
(Brougher, 2008).
[B]ased on our knowledge of the harmful effects of noise on childrens health and
the growing body of evidence to suggest the potential harmful effects of industrial
wind turbine noise, it is strongly urged that further studies be conductedbefore
forging ahead in siting industrial wind turbines. (Bronzaft, 2011).
"Dizziness (specifically, vertigo) and anxiety are neurologically linked phenomena.
Hence the anxiety and depression seen in association with other symptoms near
wind installations are not a neurotic response to symptoms, but rather a
neurologically linked response to the balance disturbances people experience from
shadow flicker or low-frequency noise... . Based on these health effects and hazards,
turbines should not be placed within 1700 feet of any road or dwelling. Those living
within 1/2 mile (2640 ft) should be apprised that they are likely to experience very
bothersome levels of noise and flicker, which continue (though to a lesser degree) to
a mile or more from the turbines." (Pierpont, 2005).

Wind parks should not be singled out for special noise criteria. Siting and zoning
can apply noise criteria, but noise limits should apply equally to all sources.
Separate consideration should be given to construction noise.
It is a simple matter to calculate the precise locations and maximum annual
duration of shadow-flicker effects. A siting standard can limit shadow flicker.
Both noise and shadow-flicker complaints can be amenable to mitigation, and an
escrow account subject to independent management by an objective, disinterested
arbitrator can be established for this purpose.
Neighbors should have the right to waive noise and shadow-flicker standards.
Safety
Ice-throw
Blade failure
Tower failure
The bottom line is that ice, debris or anything breaking off the wind turbine blades
(including the blades themselves) can impact a point almost 1,700 feet away from the
base of the turbine (Matilsky, 2011).
Especially in the mountainous sites or in the northern areas icing may occur
frequently and any exposed structure also wind turbines will be covered by ice
under special meteorological conditions. This is also true if today's Multi Megawatt
turbines with heights from ground to the top rotor blade tip of more than 150 m can
easily reach lower clouds with supercooled rain in the cold season, causing icing if it
hits the leading edge. (Siefert, Westerhellweg, & Kroning, 2003).
[W]ind turbines are being whipsawed and hammered to pieces constantly, and the
public is not being made aware of this real and present danger, for fear there will be a
grass-roots uprising against it before they are saddled with [wind parks] and dont
have any more say-so in the matter. (Brougher, 2008).

Tower failure for utility-scale turbines is characterized by vertical collapse (like a
beverage can crushing when stepped on), rather than tipping over from the base.
Tower construction standards should guide setback distances, rather than the remote
possibility of tower tip-over.
Ice throw and blade failure resulting in parts hurtling through the air are
increasingly rare. Modern turbines are continuously monitored in real time and will
shut themselves down if ice accumulates on blades. Ice shedding is thus almost
exclusively limited to the zone directly underneath the turbine.

Table 4 (Continued): Typology of Anti-Wind Park Arguments

20
Safety (continued)
Ice-throw
Blade failure
Tower failure
Setback distances of 1.5 times turbine height (tower plus blade) should be considered
maximal. Neighbors should have the right to waive setback distances from
participating buildings and property lines. Wind-park owners (and insurers)
should be liable for damages caused by ice throw, blade failure, and tower failure.
Property Values
Visual amenity
Sense of place,
of community
Industrial appearance
Tourism impacts
The days on market was more than double for those properties inside the
windmill zones. The sold price was on average $48,000 lower inside the windmill
zones than those outside. The number of homes not absorbed (not sold) was 11% vs.
3%. (Luxemburger, n.d.).

There are people who cant sell their homes and are forced to rent other living
accommodation and people who sell their homes to the wind energy companies at
much reduced prices and then are gagged from talking about any of the negative
health effects (Chevalier, n.d.).

The degradation these enormous sprawling industrial complexes bring to our
cultural and visual resources is least understood. Our colleagues describe West
Texas today as an alien landscape where one can drive for miles and miles and miles
(and miles) and see nothing but wind turbines. The nighttime experience is even
more surreal with the blinking red lights. (Industrial Wind Action Group, 2005).

Wildlife and Natural
Features
Avian mortality
(birds and bats)
Habitat destruction,
fragmentation
Whered all the animals go? My guess is as far away from those things as they can
get. (Brougher, 2008).
Save the Eagles International wishes to warn the international community about the
threat that windfarms and their power lines represent for biodiversity. Unlike cars,
buildings, and domestic cats, wind turbine blades and high tension lines often kill
protected or endangered birds like eagles, cranes, storks, etc. Cumulatively and over
the long term, 3.5 million wind turbines to be installed worldwide will cause the
extinction of many bird species, some of them emblematic. (Duchamp, 2011).

Exclusion zones should be identified in concert with state and federal wildlife
agencies based on the best available scientific information and pre- and
post-construction monitoring. Mitigation measures should be identified and included
in siting stipulations. Mitigation funds should be included in escrow accounts as
necessary to ensure compliance.
Energy Policy
Capacity factor
Emissions effects
Integration costs
Reliability
The erratic nature of the wind means that turbines simply cannot supply the base
load that other forms of generation do. Those other generators will continue to be
needed to back up the wildly variable output of wind turbines, with the probability
that in so doing these plants will actually emit more pollution for each kilowatt-hour
they generate than if they were allowed to operate normally. (Roberson, 2004).
[S]ome reliable, dispatchable generating unit(s) must be immediately available at
all times -- and operating at less than peak efficiency and capacity -- to "back up"
the unreliable wind generation. The reliable, backup unit(s) must ramp up and down
to balance the output from the wind turbines. Wind turbines have virtually no
capacity value. Thus, electric customers pay twice: once for the wind energy and
again for reliable capacity. (Schleede, 2005).

Table 4 (Continued): Typology of Anti-Wind Park Arguments

21
Energy Policy (continued)
Capacity factor
Emissions effects
Integration costs
Reliability
Peak power during the hottest summer months [is] far more demanding on the
power grid, yet the wind power available in the winter months is on average
greater than in the summer. Thats a huge contradiction . Nor can we store wind
power . So for the most part, winter winds and spring storms must either be
wasted, or they will create surges which blow out the transformers, power
equipment, and burn up their own generators, and set the grid back hundreds of
millions of dollars, as has happened by wind surges in Oregon, and many times in
Denmark, Germany, and other nations . (Brougher, 2008).
In high winds, ironically, the turbines must be stopped because they are easily
damaged. (Brougher, 2008).
A nuclear plant is tens of times cheaper and thousands of times safer per
[terawatt-hour] than gigantic air turbines will ever be even if we learn someday
how to prevent them from burning up, blowing the grid, and folding in half under a
high wind load, and blending our birds with the landscape. (Brougher, 2008).

The only relevance to siting and zoning might be for substations and transmission
facilities, which also need approvals. None of these other issues are siting and
zoning issues, per se.
Economic Development
Subsidies
Employment
Tax avoidance not environmental and energy benefits has become the prime
motivation for building wind farms. Wind farms produce few local economic
benefits and such benefits are overwhelmed by the higher costs imposed on electric
customers through their monthly bills. When the expected contribution of wind
energy toward supplying US energy requirements is taken into account, wind energy
is among the most heavily subsidized of all energy sources. (Schleede, 2005).
[I]nvestment dollars going to "renewable" energy sources would otherwise be
available for other purposes that would produce greater economic benefits. Wind
farms have very high capital costs and relatively low operating costs compared to
generating units using traditional energy sources. They also create far fewer jobs,
particularly long-term jobs, and far fewer local economic benefits. Wind farms are
simply a poor choice if the goals are to create jobs, add local economic benefits, or
hold down electric bills. (Schleede, 2011).
[B]illions of [federal grant] dollars all of it exempt from federal corporate
income taxes is being used to fatten the profits of some of the worlds biggest
companies (Bryce, 2011).

These are not relevant siting and zoning concerns.

II. Best Practices for Wind Siting and Zoning Procedures

Table 5 briefly summarizes the best practices for wind siting and zoning procedures. The
recommendations are influenced by practices in those states and several foreign countries where wind
energy resources have been developed with what appears to be a minimum of regrets.

Of course to some extent, progress in wind energy development can reflect simply an abundance of
wide-open spaces where turbines can be placed without affecting many citizens at all. As shown in
Table 2, many of the states that are leading in installed wind energy capacity are in the Great Plains and
West and have an abundance of rangeland and farmland, large land parcels, and sparse population
density. Prominent examples include Iowa, North Dakota, Oklahoma, Texas, and Wyoming. On the other
hand, there are several states that do have greater population density and more urban and suburban lands
where wind development is also already substantial and growing. Prominent examples of those include
Illinois, Indiana, Minnesota, and New York.

In any case, the recommendations presented here and in Part III reflect what has been gleaned from the
survey of the states, a review of the literature, and the authors experience and best judgment.

Table 5: Best Practices for Procedures

Recommendation Description
1. Develop procedures that result in clarity,
predictability, and transparency
Jurisdictions with locations suitable for commercial
wind development should anticipate interest and
proceed to develop and publish siting and zoning
procedures, principles, and guidelines.
2. Establish a one-stop, pre-submission
consultation
Provide basic information for applicants in a single
meeting, identifying and explaining the basics of all
necessary permits and approvals.
3. Identify and map constrained and
preferred wind energy development zones
Make available and accessible to the interested
public GIS maps of exclusion, avoidance, and
preferred development zones
4. Include preferred development zones in
transmission plans
Begin modeling and planning for wind power
interconnections in preferred development zones as
soon as the zones are identified.
5. Prepare and make available guidelines for
participants
Explain procedures and timelines for when, where,
and how to participate in public hearings. Provide
information about decisions already completed
through rulemaking.
6. Prepare and make available for local
siting and zoning officials guidelines,
checklists, and model ordinances
Support local government decision makers by
providing the best available technical resources.
7. Ensure the sequence for obtaining permits
and approvals meets requirements to
allow development of suitable projects
The sequence of events leading to approval or
rejection of an application should entail a logical
progression through the planning and design stages,
prior to siting and zoning approval that allows
construction to begin.

23
A. Develop procedures that result in clarity, predictability, and transparency

All involved parties benefit from procedures that are clear and predictable and lead to transparency in
decision making. Procedures need to be spelled out in ample detail so that all participants can understand
how to participate, and when and where participation is expected. Applicants should understand their
responsibilities. This all sounds obvious, but experience shows that in too many circumstances procedures
are not spelled out. Applicants and other participants often find it difficult to learn what is expected, the
sequence of events and venues, and time frames needed to progress through the siting and zoning process.

At the outset, a lack of clarity can be blamed on the novelty of siting and zoning for a wind park.
However, all siting and zoning officials can quickly learn about the general attractiveness of their
jurisdiction for commercial wind energy development. Wind resource maps are readily available that are
accurate enough for making general determinations about good, better, and best areas for commercial
development (Wind Powering America, 2011). Jurisdictions with locations suitable for commercial wind
development should anticipate interest and proceed to develop and publish siting and zoning procedures,
principles, and guidelines.

B. Establish one-stop, pre-submission consultation for applicants

A best practice for siting and zoning is to establish a one-stop procedure for applicants, in the form of a
pre-submission consultation (Rosenberg, 2008, p. 681). This means applicants will have an opportunity to
meet once, with one or more of the responsible agencies. The goal is for the applicant to come away from
the one meeting with a clear understanding of all the necessary permits and approvals needed. One-stop
procedures can be difficult when coordination involves multiple levels of government, but good
communications can still work towards this goal. If nothing else, at least the organization with lead
responsibility for wind-park siting and zoning can have available for applicants a list of all permits and
approvals, which specifies the criteria that trigger each requirement. For each permit or approval, the
one-stop agency should be able to communicate all the basic information about each requirement,
including the contact persons, procedures, sequence of approvals required, timelines, and where and how
to obtain complete, detailed information.

Delaware, Florida, and Oregon have provisions for one-stop meetings with applicants. Florida and
Oregon both have state level siting (although Floridas applies to other kinds of power plants, not wind
parks). Delaware has primarily local siting and zoning for wind parks, but a one-stop state agency helps
applicants understand all required permits.

C. Identify and map constrained and preferred wind energy development zones

Siting and zoning authorities should identify and communicate about constrained and preferred
development zones; in preferred areas development would be encouraged, and in constrained areas, the
opposite. Information about these zones should be available in geographic information system (GIS)
format. Examples of constrained zones include areas already identified as important to the life-cycle of
endangered species, areas of particular historical or archeological importance, and wetlands, and can take
two forms: exclusion zones and avoidance zones. Exclusion zones are known to be off limits, and
avoidance zones are places where development deserves extra caution. Many government agencies that
have what is effectively veto power over siting and zoning already have maps in GIS format, showing
areas that are either exclusion or avoidance zones. Basic mapping information should be available,
identifying constrained zones and the relevant buffers around the constraints (Great Lakes Wind
Collaborative, 2011, Best Practice #11).

Such maps will not be a complete substitute for ground-truth assessments of specific locations, but they
can go a long way towards helping all parties to avoid wasting time and resources on the evaluation of
locations that will ultimately prove to be unavailable for development. Where jurisdictions have made

24
determinations about setback (i.e., buffer) distances, those can also be clearly communicated. All
interested parties should be able to use the available maps to understand both macro- and micro-siting.
As Rosenberg (2008, p. 681) explains, such maps serve to highlight actual and potential conflicts
between wind power projects and listed sensitive lands. Hopefully, he notes, projects could be
planned to avoid these areas and if [wind power projects] were proposed for sites in the vicinity of such
areas, potential adverse impacts could be mitigated through careful project planning.

Preliminary examples of this type of mapping capability are available from the Great Lakes Wind
Collaborative (GLWC, http://erie.glin.net/wind/, retrieved 9 Jan 2012) and Vermont Energy Atlas
(www.vtenergyatlas.org, retrieved 20 Jan 2012). The GLWC GIS system for eight states and two
Canadian provinces assembles many different GIS map layers already available from various sources. It
demonstrates a system that can facilitate identifying areas of concern. The Vermont atlas system does not
yet include information about constrained zones, but it does demonstrate excellent ease of use and
presents much practical information.

Similarly, if state or local jurisdictions have identified preferred development zones, information about
those areas can be made available in map form. For example, several states are engaged in identifying
renewable energy zones to receive special treatment for transmission expansion (see Table 1, Column 15).
Also, some states have identified renewable energy resource development as a priority use for brownfield
redevelopment (for example, New Jersey Statute 40:55D-66.11, 31 Mar 2009, Wind and solar facilities
permitted in industrial zones, www.dsireusa.org/documents/Incentives/NJ17R.htm). Colorado enabling
legislation encourages county master plans to consider both methods for assuring access to appropriate
conditions for solar, wind, or other alternative energy sources [and avoiding] areas containing
endangered or threatened species (Colorado Revised Statutes 30-28-106(3)(a)(VI)(XI),
www.michie.com/colorado). Similarly, Denmark directs its county governments to identify wind
development zones (Danish Energy Agency, 2009, pp. 12-14).

Procedures for identifying areas for preferred development should ensure meaningful public participation
and input, but once preferred development areas are selected, then information about those zones should
be readily available to help guide developers.

D. Include preferred development zones in transmission plans

As discussed above, mapping preferred (and constrained) zones is recommended. With preferred zones,
the mapping should, ideally, go one step further. Depending on the estimated wind power production
from preferred development zones, the areas should be linked to and coordinated with transmission
development plans (see Great Lakes Wind Collaborative, 2011, Best Practices #4 and #5). If the
estimated production in a preferred development zone is substantial, wind parks will need to be
interconnected to the electric transmission, rather than distribution, system. The determination of what
capacity level is too big for the local distribution system needs to be done on a case-by-case basis: It
depends on the design and operation of the existing distribution and transmission systems, and on nearby
loads and generation.

Whatever interconnections will be required, whether to the distribution or transmission system or both,
modeling and planning for interconnections in the preferred development zones should begin as soon as
the zones are identified. The reason is that the entire process for transmission planning, design, and
construction including the transmission siting and zoning process will often take much more time than
the process for planning, designing, obtaining approvals, and constructing a wind park. As shown in
Table 1, Column 15, 23 states are already engaged in procedures to identify wind energy resource zones,
with those procedures linked to transmission planning. That includes 9 of the top 10, 16 of the top 20, and
21 of the top 30 states, in terms of wind capacity development.

25
E. Prepare and make readily available guidelines for participants

All participants need clearly understandable guidelines, so they can know ahead of time when to expect
public hearings, what will be the substance of those hearings, and how to participate. Many participants
will not be frequent participants in planning and zoning hearings. It certainly helps if they learn what is
expected.

As shown in Table 4, wind-park opponents frequently raise issues that are not germane to siting and
zoning hearings. It is best for everyone concerned if clear, complete information is provided, prior to
public hearings, to explain which venues will be addressing which subjects. Where guidance or
regulations exist, those should be made clear. For example, California legislation establishes restrictions
for tower height, parcel size, setbacks, and noise level, and prescribes practices for public notice of
applications and hearings (Assembly Bill 45 of 2009; see Database of State Incentives for Renewables &
Efficiency, California County Wind Ordinance Standards, retrieved 22 Dec 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=CA61R&re=1&ee=1).

Maine has spelled out the sequence of procedures that apply to wind siting and zoning but does not
include the expected timelines.

Ohio mandates public information meetings prior to filing an application to build a new facility. These
are not formal public hearings, which take place after an application is filed. The purpose for a public
information meeting is to inform stakeholders about plans to file an application [and] as an
opportunity to gather public input and hear the publics concerns, which the company considers in
developing its application. (Ohio Power Siting Board, 2010,
http://www.puco.ohio.gov/emplibrary/files/OPSB/Presentations_Manuals/OPSBbrochure2010.pdf).

There is no conclusive evidence that educational meetings will reduce public concerns or opposition. On
the other hand, there is reason to believe that public opposition increases and festers if people feel, rightly
or wrongly, that procedures do not provide adequate opportunities for public concerns to be aired and
addressed. (See, for example, English, pp. 307-08, and Huber & Horbaty, 2010, pp. 50-51.) In fact, there
is extensive literature about public engagement and participation in all kinds of land use and technology
decisions, and explicitly about wind parks (see, for example: Agterbosch, Meertens, & Vermeulen, 2009;
Hindmarsh, 2010; Koebel, 2011; Jones & Eiser, 2009; Mazur, 2007; Sovacool, 2009; Toke, Breukers, &
Wolsink, 2008; and Wilson & Grubler, 2011).

F. Prepare and make available for local siting and zoning officials
guidelines, checklists, technical resources, and model ordinances

States should consider providing technical documents to help support local government decision makers.
This is important for states that have a shared or exclusive local government responsibility for wind siting
and zoning, and wherever state rules do not supersede or at least constrain local authority.

It is important to recognize that local authorities might not be familiar with wind siting and zoning. It is
certainly not likely that any particular local authority will come to their job with a background in wind
siting and zoning. As with many issues facing local governments, specialized education is often needed to
arm local governments with the tools necessary to guide decisionmaking.

As Rosenberg (2008, pp. 674-75) notes, there is a concern that [l]ocal zoning decisions can be little more
than project popularity contests driven by the prevalent popular sentiment. And, he points out, the
generally rural local governments that are most likely to receive proposals often have limited resources
and can be lacking the extensive planning resources or personnel to evaluate wind power siting
proposals. Therefore, Rosenberg (2008, pp. 675-76) prescribes an attitude of shared responsibility
between state and local governments. He recommends provid[ing] local governments, planners and

26
citizens with expert state-level guidance . This approach can include voluntary guidelines, checklists,
and technical resources to aid [local governments] in their evaluation of siting wind projects.

As shown in Table 1, columns 7 through 11 report on the kinds of information discussed here. Twenty-
seven states have published evaluation criteria that support wind siting and zoning. Those are frequently
environmental protection criteria, though, rather than explicit wind siting and zoning criteria, and apply to
all construction projects. Ten states have published voluntary guidelines for wind parks, but three of those
are exclusively guidelines for wildlife and habitat protection. Ten states have model ordinances and six
states have model standards for setback and sound. Although many states have one or more of these
documents available, only Georgia, Michigan, and New York have provided both voluntary guidelines
and model ordinances. Only three states (Delaware, Rhode Island, and Virginia) have published
mandatory rules about both setback and sound. Minnesota has a sound standard and Wyoming has a
setback standard.

G. Ensure that the sequence for obtaining permits and approvals
meets requirements to allow development of suitable projects

Procedures should allow for suitable projects to obtain all required approvals. The sequence of events
leading to approval or rejection of an application should entail a logical progression through the planning
and design stages, prior to siting and zoning approval that allows construction to begin.

For example, at least one state agency requires a project application to include certification that the
project complies with all applicable land-use ordinances and a copy of a final interconnection agreement.
At least some developers might hesitate to spend as much as sometimes can be required to obtain a final
interconnection agreement, unless and until they are certain the project is approved.

Also, power purchase agreements (PPAs) could require developers to demonstrate that a project has the
requisite control over the property planned for development (that is, land leases), siting and zoning
approval, sufficient progress towards obtaining an interconnection agreement, and the financial
wherewithal to complete construction and enter into commercial operation in a reasonable time period. If
those are requirements for the sale of wind-generated electricity, then the siting and zoning approval
cannot be contingent upon obtaining the PPA.

27
III. Guidelines for Implementing Wind-Park Siting and Zoning
Criteria and Setback Distances

This part of the report reviews the many criteria that are addressed in wind-park siting and zoning, and
provides guidelines based on the best available information about each criterion. As already mentioned
(see p. 2), best practices are subject to refinement over time, as more knowledge is gained and as wind
generator technologies change and improve. Table 6 summarizes the recommendations included in
Part III.

Table 6: Wind-Park Siting and Zoning Criteria, Recommended Approaches and Setback Distances

Noise, sound, and
infrasound
Noise standards should allow some flexibility.
Noise standards should vary depending on the areas existing and expected land
uses, taking into account the noise sensitivity of different areas (e.g., agricultural,
commercial, industrial, residential).
Determine pre-construction compliance using turbine manufacturers data and best
available sound modeling practices.
Apply a planning guideline of 40 dBA as an ideal design goal and 45 dBA as an
appropriate regulatory limit (following Hesslers proposed approach, 2011).
Allow participating land owners to waive noise limits.
Establish required procedures for complaint handling.
Identify circumstances that will trigger, and techniques to be used for:
(a) mandatory sound monitoring; (b) arbitration; and (c) mitigation.
Do not regulate setback distance; regulate sound.
Shadow flicker Restrict to not more than 30 hours per year or 30 minutes per day at occupied
buildings.
Allow participating land owners to waive shadow-flicker limits.
Allow the use of operational practices and mitigation options for compliance.
Do not regulate setback distance; regulate the duration of shadow flicker.
Ice throw Authorize demonstrated ice control measures.
Require wind park to provide insurance and escrow funds to ensure compensation
for proven damages resulting from ice throw.
Do not regulate setback distance; regulate ice throw.
Wildlife and habitat
exclusion zones
Responsible wildlife protection agencies should use the best available scientific
knowledge and data to determine exclusion and avoidance zones and appropriate
buffers (that is, setback distances) beyond those zones.
Permits should specify required pre-, during-, and post-construction monitoring.
Permits should specify how mitigation requirements will be determined and what
mitigation techniques will be considered.
Regulate setback distances as required by responsible wildlife protection agencies
and do not authorize siting in exclusion and buffer zones.
Aesthetic
requirements
Require neutral paint color and minimal signage.
Require the minimum of nighttime lighting necessary to achieve FAA compliance.
Require that realistic visual impact assessments, accessible to the public, be
included in wind park planning and applications.
Manage visual impact through setbacks and exclusions from critical competing
land uses.

Table 6 (Continued): Wind Park Siting and Zoning Criteria, Recommended Approaches
and Setback Distances

28
Critical competing
land uses
Map as excluded zones any special cultural, anthropological, sacred lands, and
highly valued scenic vistas.
Apply reasonable setbacks from non-participating property lines, occupied
buildings, scenic vistas, and transportation and utility rights of way.
Allow participating properties to at least partially waive setback requirements
from property lines and occupied buildings, in writing.
Permit requirements
for met towers,
construction, and
facility safety
Predetermine requirements and simplify procedures for approving meteorological
(met) towers.
Regulate heavy construction requirements the same as any other heavy
construction project, using the regulatory permitting system (e.g., for stormwater,
surface water, transportation, noise, and wetlands permits).
Check for all required approvals for potential interference with radio and TV
reception or radar. Provide for testing and mitigation of radio and TV interference
problems that do occur.
Regulate structural safety (against, e.g., tower tip-over or blade failure) through
construction codes, combined with minimal setback requirements.
Regulate facility safety (e.g., preventing climbing towers, ensuring electrical
safety, providing fencing around electrical gear).
Decommissioning Set clear requirements for what triggers and what constitutes decommissioning
and restoration or reclamation.
Establish a decommissioning escrow fund, to ensure adequate resources will be
available at the end of a projects useful life or in the event the development fails.
Dispute resolution
and mitigation
Establish procedures for dispute resolution and mitigation.

A. Avoiding or mitigating public health and safety,
nuisance and annoyance issues

Ellenbogen et al. (Jan 2012, p. ES-5) report, based on their independent review of the best available
literature, that a self-reported annoyance response appears to be a function of some combination of the
sound itself, the sight of the turbine, and attitude towards the wind turbine project.

The Ellenbogen et al. study (Jan 2012, p. ES-7) concludes:

There is no evidence for a set of health effects, from exposure to wind turbines that could be
characterized as a Wind Turbine Syndrome. [T]he weight of the evidence suggests no
association between noise from wind turbines and measures of psychological distress or mental
health problems. None of the limited epidemiological evidence reviewed suggests an
association between noise from wind turbines and pain and stiffness, diabetes, high blood
pressure, tinnitus, hearing impairment, cardiovascular disease, and headache/migraine.

But the same researchers (Jan 2012, p. ES-11) recommend an ongoing program of monitoring and
evaluating the sound produced by wind turbines [including] more comprehensive assessment of wind
turbine noise in populated areas. Such assessments, they report, would be useful for refining siting
guidelines and for developing best practices .

29

In any case, some people really do get upset by the idea of, or the actual fact of, wind turbines being built
nearby. As opponents in a siting and zoning process, they have a tendency to raise every argument they
can think of to help dissuade officials from approving projects. (See Table 4).

The following materials address the significant concerns that are raised about public health, safety,
nuisance, and annoyance issues. Not included in this list are electromagnetic field (EMF) effects and stray
voltage. Those subjects should be regulated by other agencies, typically the PUC, and are not germane to
siting and zoning decisions.

Some research suggests that wind-park opponents are affected by a nocebo effect, which is essentially
the opposite of a placebo effect (see the Skeptics Dictionary, http://skepdic.com/nocebo.html, retrieved
27 Dec 2011). One widely cited study (Pedersen, Bouma, Bakker, & van den Berg, 2008) finds evidence
of a nocebo reaction, among neighbors with no financial interest and an anti-wind-park predisposition.
Ellenbogen et al. (Jan 2012, p. ES-8) state somewhat the reverse of this assessment. They find:

Effective public participation in and direct benefits from wind energy projects (such as receiving
electricity from the neighboring wind turbines) have been shown to result in less annoyance in
general and better public acceptance overall.

The next few sections of this report: (1) address noise, sound, and infrasound; (2) shadow flicker; (3) ice
throw; and (4) pre- and post-construction monitoring of noise, sound, and infrasound.

1. Noise, sound, and infrasound

As can be inferred from dictionary definitions: (a) noise means sound that humans perceive as generally
loud, unpleasant, unexpected, or undesired; noise means sounds that are disturbing; (b) sound means
simply the sensations that can be perceived by the sense of hearing; and (c) infrasound means a wave
phenomenon of the same physical nature as sound but with the frequencies below the range of human
hearing (Merriam-Webster Dictionary, retrieved 24 Jan 2012 from http://www.m-w.com/dictionary/).
Sound pressure is measured in decibels (dB), using a device called a sound level meter. Decibels are
measured using either an A-weighted scale (dBA, sometimes written dB(A)) or C-weighted scale
(dBC, or dB(C)). The A-weighted scale is intended to measure the sounds as they are subjectively
perceived by the human ear. The C-weighted scale is highly sensitive to low-frequency sound and is
therefore normally used to evaluate sources where the low-frequency content of the sound is prominent or
dominant. The C-weighted scale was developed to assess sound levels more commonly associated with
occupational exposures. Environmental noise limits are commonly expressed solely in terms of
A-weighted decibels.

Ellenbogen et al. (Jan 2012, p. ES-6) reviewed the best available reports on noise, sound, and infrasound.
They conclude:

[I]t is possible that noise from some wind turbines can cause sleep disruption. A very loud
wind turbine could cause disrupted sleep, particularly in vulnerable populations, at a certain
distance, while a very quiet wind turbine would not likely disrupt even the lightest of sleepers at
that same distance. But there is not enough evidence to provide particular sound-pressure
thresholds at which wind turbines cause sleep disruption. Further study would provide these
levels. Claims that infrasound from wind turbines directly impacts the vestibular system have
not been demonstrated scientifically. Available evidence shows that the infrasound levels near
wind turbines cannot impact the vestibular system.

Hessler (2011, pp. 11-12) reports:

30
[A]ny noise limit on a new project must try to strike a balance that reasonably protects the public
from exposure to a legitimate noise nuisance while not completely standing in the way of
economic development and project viability. It is important to realize that regulatory limits for
other power generation and industrial facilities never seek or demand inaudibility but rather they
endeavor to limit noise from the source to a reasonably acceptable level either in terms of an
absolute limit (commonly 45 dBA at night) or a relative increase over the pre-existing
environmental sound level (typically 5 dBA19). [T]he rate of adverse reaction comes down to
a handful of individuals or very roughly about 4 to 6% when residences are exposed to project
sound levels in the 40 to 45 dBA range. [T]he vast majority of residents living within or close
to a wind farm have no substantial objections to project noise, particularly if the mean sound level
is below 40 dBA. While the possibility of annoyance, if not serious disturbance, can almost
never be completely ruled out, it appears that the total number of complaints would be fairly
small as long as the mean project level does not exceed 40 dBA.

The inconsistency in reactions to wind turbine and wind-park noise makes it difficult to establish any
absolute criteria that siting and zoning officials could use in all circumstances. Hessler (2011, p. 21)
explains:

[T]he exact reaction to any project can never be predicted with certainty because project noise is
often audible to some extent, at least intermittently, far from the project. However, the studies of
response to wind turbine noise suggest that the threshold between a mild or acceptable impact
and a fairly significant adverse reaction is a gray area centered at 40 dBA.

However, observations of neighbors reactions to newly operational wind farms suggest that it is not
necessary to rigidly impose a maximum noise level of 40 dBA in order to avoid complaints. Hessler
(2011, p. 12) recommends 40 dBA as an ideal design goal, if it can reasonably be achieved, but 45 dBA
as an appropriate regulatory limit. Adverse reactions to wind turbine noise between 40 and 45 dBA are
still quite low, at roughly 2 percent of wind-park neighbors, even in rural environments with low
background levels.

As with siting and zoning for other activities, the social good produced from the activity needs to be
weighed against any local disturbances, including annoyances and nuisances. As with the siting and
zoning of any other legal activity, the appearance of complaints, even more so the potential for
complaints, is not reason enough for denial. From a legal standpoint, the preponderance of available
evidence leads to the conclusion that noise requirements for wind turbines should be the same as those
applied to any other legal activity that could be sited or zoned in the same jurisdiction.

Noise standards should also allow some flexibility because of the highly variable nature of both
background noise and wind turbine noise. No single incursion beyond the noise standard should force
abandonment of a wind park. The wide variability in wind turbine sound propagation makes it impractical
to require absolute compliance with this kind of limit. Hessler (2011, pp. 35-63) provides detailed
guidance for post-construction testing procedures.

The noise standard should allow micro-siting and construction based on the best available data on noise
generated by the turbines planned for installation and modeling of the local conditions. It is also important
to allow participating property owners to waive noise limits, in writing.

In approving wind-park construction, the siting and zoning permit should establish clear procedures to be
invoked if there are complaints about noise. The wind-park owners and operators should have the
opportunity to mitigate any confirmed problems, using any combination of operational and technical
changes. For example, Leung & Yang (2012, p. 1037) identify opportunities to significantly reduce
wind turbine noise by putting obstacles in the [sound] propagation path. These researchers also report a
promising experiment where an optimized or serrated blade noticeably reduced wind turbine noise.

31
As Ellenbogen et al. (2012, p. ES-11) propose, If noise control measures are to be considered, the wind
turbine manufacturer must be able to demonstrate that such control is possible.

Ellenbogen et al. (2012, p. ES-11) also recommend an ongoing program of monitoring and evaluating
the sound produced by wind turbines [including] more comprehensive assessment of wind turbine
noise in populated areas . They elaborate:

These assessments should be done with reference to the broader ongoing research in wind turbine
noise production and its effects, which is taking place internationally. Such assessments would be
useful for refining siting guidelines and for developing best practices .

North Dakota Department of Transportation (NDDOT, 2011, pp. 1, 6-7), as the states policy for
implementation of the requirements of the Federal Highway Administration (FWHA) Noise Standard at
23 Code of Federal Regulations (CFR) Part 772, identifies and categorizes lists of specific, noise
sensitive land uses. These cover everything from areas where serenity and quiet are of extraordinary
significance and serve an important public need to cemeteries, day-care centers, hospitals, libraries
to areas where noise is expected and land uses are presumed to be not sensitive to highway traffic noise
such as agriculture, airports, industrial, logging, manufacturing, [and] mining . Similar
guidelines could be produced for wind parks, or perhaps the guidelines for transportation projects could
be adapted for application to wind-park siting and zoning.

2. Shadow flicker

Shadow flicker is defined as alternating changes in light intensity that can occur at times when the
rotating blades of wind turbines cast moving shadows on the ground or on structures (Priestley, 2011,
p. 2). The International Energy Agency (2010, p. 42) identifies shadow flicker as a nuisance.

The existence of shadow flicker depends on turbine micro-siting, with respect to the distance from the
turbine and compass direction between the turbine and any surfaces of concern. Wind-park designers can
model where shadows might fall on each day of the year (see, for example, Zephyr North, 2009).

Shadow flicker will affect any particular location only during either sunrise or sunset. The specific
location is a function of the potential alignment between the sun, a wind turbine, and a receiving surface,
Given the geometry of the potential alignment, and then depending on the latitude and tilt of the earth on
its axis, the effect can happen for only a small number of days per year as the point in the horizon where
sunrise or sunset appears changes, moving north or south by a small compass angle each day. Plus, on
those several days and during the times when shadows could occur, the sky needs to be clear enough for
the effect to be noticeable.

In their study, Ellenbogen et al. (2012, p. ES-78) determine:

Scientific evidence suggests that shadow flicker does not pose a risk for eliciting seizures as a
result of photic stimulation. There is limited scientific evidence of an association between
annoyance from prolonged shadow flicker (exceeding 30 minutes per day) and potential
transitory cognitive and physical health effects.

Shadow flicker should be determined as a pre-construction activity. Reports can be provided so that the
possible shadow effects on properties, buildings, and roadways can be understood. A reasonable standard
can rely on micro-siting modeling to ensure that shadow flicker will not exceed 30 hours per year or 30
minutes per day at any occupied building. These are the most commonly used guidelines (Lampeter,
2011, pp. 5-14). However, the standard should also allow for property owners to waive the shadow-flicker
maximum and for mitigation options, which could include changes in landscaping or window treatments
to minimize concerns. It is even conceivable that a contract between a wind-park operator and property
owner would provide for shadow-flicker limits through operational control, simply curtailing a particular

32
turbine during those times when shadow flicker would otherwise constitute a nuisance in excess of the
local standard or some other agreed limit.

3. Ice throw

Ellenbogen et al. (2012, p. ES-8) report:

In most cases, ice falls within a distance from the turbine equal to the tower height, and in any
case, very seldom does the distance exceed twice the total height of the turbine (tower height plus
blade length). There is sufficient evidence that falling ice is physically harmful and measures
should be taken to ensure that the public is not likely to encounter such ice.

These researchers (Ellenbogen et al. 2012, p. ES-12) also advise that any ice-control measures used to
comply with permit requirements should be demonstrated by the wind turbine manufacturer.
Modern wind turbines that are planned for installation in climates where icing can be expected will have
both physical characteristics and operational controls designed to minimize any concern about ice throw.
Turbines are designed to stop rotating if ice builds up on blades, and some designs include blade heaters
to shed ice. For siting and zoning purposes, it should be sufficient to review the plans for managing
operations to minimize ice throw, and to require the wind-park owners to maintain liability insurance
against the unlikely event that ice throw causes any damage or injury. Explicit setback requirements for
ice throw should not be necessary.

4. Pre- and post-construction monitoring
for public health and safety, nuisance, and annoyance issues

Since noise is one of the most common concerns for wind-park development, both pre- and post-
construction monitoring should be considered for at least some facilities. Together, developers,
communities, and siting and zoning authorities can determine which areas deserve special attention for
pre-construction monitoring. Post-construction monitoring could be established only as a requirement for
addressing noise complaints.

Hessler (2011, p. 25) proposes the pre-construction background-sound testing protocol:

[A] long-term, continuous monitoring approach is needed in which multiple instruments are set
up at key locations and programmed to run day and night for a period of about two weeks or
more. In essence, it is necessary to cast a wide net in order to capture sound levels during a
variety of wind and atmospheric conditions and provide sufficient data so that the relationship
between background noise and wind speed can be quantitatively evaluated. [I]t is highly
preferable to conduct this type of survey during cool season, or wintertime, conditions to
eliminate or at least minimize possible contaminating noise from summertime insects, frogs and
birds. In addition, it is best for deciduous trees to be leafless at sites where they are present in
quantity to avoid elevated sound levels that might not be representative of the minimum annual
level. Human activity, such as from farm machinery or lawn care, is also normally lower during
the winter. While summertime surveys can be successful they should, as a general rule, be
avoided wherever possible because nocturnal insect noise, for instance, can easily contaminate
the data and make it impossible to quantify the relationship between sound levels and wind speed.

As already mentioned, Hessler (2011, pp. 35-63) provides detailed guidance for post-construction testing
procedures.

All interested parties should recognize the potential role of post-construction monitoring for at least some
wind parks, to produce the information necessary to inform best practices. But it is not necessary for
every wind park to be monitored. Modeling and testing are reliable enough to deduce the likely noise
effects from studies of similar turbines, wind conditions, terrain, and setback distances.

33

B. Preventing harm to flora, fauna, and habitats

Operating wind turbines in particular locations can harm ecosystems. Of special concern has been the
killing of birds and bats. Thus, siting and zoning standards typically include provisions designed to
protect wildlife and wildlife habitat.

The role in siting and zoning is to require the appropriate reviews before approval is granted and before
construction begins. Specific wildlife and habitat concerns will require some locations to be excluded
from development. Examples include habitats known to be used by threatened or endangered species or
migratory birds, and wetlands. Such exclusions or related restrictions are governed by federal and state
environmental protection laws and regulatory agencies. Siting and zoning authorities should also require
applicants to demonstrate compliance with and approvals granted by the relevant environmental
regulatory agencies, before a siting and zoning application is considered complete.

Wildlife and environmental studies are routine but critically important components of due diligence for
wind-park planning. Developers know these studies are integral to obtaining the approvals that will allow
construction and operation, and lenders check the studies prior to approving wind-park financing. The last
thing a developer wants is to find out, post construction, that there are problems that threaten long-term
operations. In fact, a developer wants to find out about such problems as early as possible, before
dedicating resources to prospecting and planning for an area that can later prove to be undevelopable.

The wind industry has taken many steps to understand wind and wildlife interactions and has already
changed tower and turbine designs, operating practices, and macro- and micro-siting to avoid, prevent, or
mitigate problems. The American Wind Wildlife Institute (AWWI) was formed in 2008-09, as a forum
for wind developers and manufacturers to work with environmental and wildlife preservation
organizations and experts to provid[e] and shar[e] scientific information and tools to advance wind
energy with respect for the environment (www.awwi.org/about/ and www.awwi.org/about/founders.aspx
[web pages], retrieved 7 Jan 2012). The National Renewable Energy Laboratory (n.d.) also maintains an
on-line database of literature about wind and wildlife impacts.

Efforts to understand the nature and extent of interactions between wind turbines, wind parks, and
wildlife and habitat are continuing (see Wind Powering America, 2011b). But, as Ewert, Cole, & Grman
(2011, p.1) report, much remains unknown and there are interactions that are presently inadequately
understood. Thus, wildlife and environmental experts recommend a precautionary approach, combined
with pre- and post- construction monitoring efforts, to provide the best available information that can be
used to establish guidelines and perhaps translate to regulatory determinations. The U.S. Department of
Interior, Fish and Wildlife Service is presently developing guidelines (www.fws.gov/windenergy and
www.fws.gov/habitatconservation/wind.html [web pages], retrieved 7 Jan 2012).

These concerns are best managed by a combination of three practices: (1) identifying exclusion and
avoidance zones based on the best currently available information about endangered and protected species
and critical habitat; (2) requiring wildlife and habitat pre- and post-construction monitoring; and
(3) mitigation requirements for circumstances where disturbance of important habitats cannot be avoided.

1. Wildlife and habitat exclusion zones

Exclusion and avoidance zones for wildlife and habitat should be determined by the states responsible
wildlife protection agency. As already mentioned, to the extent practical those zones should be identified
and mapped ahead of time. In addition to any areas pre-identified, wind energy developers should consult
with the appropriate wildlife protection agencies to determine whether areas targeted for development
include any environmentally or culturally sensitive areas that should be avoided or buffered.

34
It is not important for the maps to publicly specify why each area has been identified. Exclusion and
avoidance zones can be identified for a wide variety of reasons, including for example environmental,
cultural, and historic sites, which may include wildlife refuges, feeding areas of protected species, and
sensitive federal, state, and private lands (Michigan Wind Energy Resource Zone Board, 2009, p. 75).
It is sufficient just to identify zones being excluded and indicate they are sensitive.

2. Wildlife and habitat pre- and post-construction monitoring

When a wildlife protection agency determines that wind-park construction will encroach on or border
sensitive areas, the agency should have the ability to require pre-construction monitoring and reporting.
Depending on the results of pre-construction monitoring, the agency should consider its ability to enforce
any conditions on construction and operation. Among reasonable conditions, depending on the concerns
identified, can be monitoring and reporting during and after construction.

For example, Kansas Department of Wildlife and Parks Wind Power Position Statement (quoted in
www.fishwildlife.org/files/Kansas.pdf, retrieved 11 Nov 2011) declares:

To support the study of and establishment of standards for adequate inventory of plant and animal
communities before wind development sites are selected, during construction, and after develop-
ment is completed. The resultant improvement in available knowledge of wind power and
wildlife interactions obtained through research and monitoring should be used to periodically
update guidelines regarding the siting of wind power facilities.

3. Mitigation and operating practices to minimize negative impacts

Kansas Renewable Energy Working Group guidelines (quoted in www.fishwildlife.org/files/Kansas.pdf,
retrieved 11 Nov 2011) state:

When it is impossible to avoid significant ecological damage in the siting of a wind power
facility, mitigation for habitat loss should be considered. Appropriate actions may include
ecological restoration, long-term management agreements, and conservation easements to
enhance or protect sites with similar or higher ecological quality to that of the developed site.

Davis, Weis, Halsey, & Patrick (2009, p. 9) advise:

For wind projects, as with any land development, the reality is that not all impacts can be
avoided. Even with full efforts at avoidance and minimization, impacts often remain including
bird and bat mortality and habitat loss and fragmentation. For this reason, it is essential to
understand and evaluate impacts as well as assess the need for offsets and compensatory
mitigation.

Parameters for these practices are determined by the relevant wildlife protection, environmental, and
natural resources authorities, and will depend on the species impacted and the potential or actual problems
identified. If problems are identified after construction, then it is appropriate to consider operational
changes.

For example, some operational techniques presently being tested show promise for identifying the
presence of birds or bats, or even the insects that birds or bats might feed on, thus allowing operators to
control wind turbines to reduce bird or bat injuries and fatalities (see: Davis, Weis, Halsey, & Patrick,
2009; Deign, 2011; and Leung & Yang, 2012).

35
C. Aesthetics

Siting and zoning authorities frequently include aesthetic requirements in wind-park permits. These
include factors such as the appearance of the turbines themselves, nighttime lighting, and other
requirements to limit visual impact. From a siting and zoning standpoint, these requirements are not very
different from those authorities impose on all kinds of decisions about signage, lighting, and setbacks for
commercial properties.

An apparent consensus on best practices has been achieved on paint color and nighttime lighting.
Although there could be continuing progress on both issues, the gist of the consensus is that paint colors
should be neutral, so that the turbines blend into the landscape to a significant extent. FAA (Patterson,
2009, p. 9) has determined that towers painted white do not need any daytime strobe lighting to warn
pilots. It is most common for permits to limit any signage or advertising. For example, Delaware (Chapter
80, Title 29, 8060, http://delcode.delaware.gov/sessionlaws/ga145/chp147.shtml) requires:

Wind systems shall be free from signage, advertising, flags, streamers, any decorative items or
any item not related to the operation of the wind turbine. Electric wiring for the turbines shall be
placed underground for non-building integrated systems.

Nighttime lighting can be minimized as much as practical while still meeting FAA requirements.
Patterson (2009) explains the FAA requirements and how the FAA has worked to adjust its requirements
for wind turbine lighting. Since nighttime lighting can be a nuisance for neighbors and an attractant for
birds, bats, and the insects birds and bats might feed on, there has been interest on the part of wind turbine
manufacturers, wind park developers, and the FAA to find the best means available to reduce negative
impacts while keeping sufficient lighting to alert pilots of areas to avoid. The basic results are to limit
turbine lights to the machines on the perimeter of a wind park and allow spacing of up to one-half mile
between lighted turbines. Since 2009, in some circumstances and on a case-by-case basis, the FAA has
even been able to approve a new obstacle collision avoidance system (OCAS) that reduces the need for
lighting even further (Patterson, 2009, p. 13; PRNewswire, 2009).

Although many people might think of nighttime lighting as a minor issue, the FAAs responsiveness is a
positive example of the way the wind energy industry and government regulators can work together to
reduce negative impacts. As Patterson (2009, pp. 1-3) reports, FAAs goal has been to make obstructions
visible to airborne aircraft, while being as sensitive as possible to the surrounding environment. He
reports that the FAA worked cooperatively with DOE to [d]etermine the most effective and efficient
technique for obstruction lighting of wind turbine farms focused on Aviation Safety, with consideration
for wildlife, surrounding communities, and industry... consistent [and] easy to implement.

Molnarova et al. (2012) surveyed residents in Central Bohemia, Czech Republic and reviewed 18 earlier
studies to better understand public attitudes towards the visual impacts of wind turbines. They identify
special concerns for landscapes of high aesthetic quality. But they also note, similar to findings from
other research on public responses to wind turbines, The most important characteristic of the respondents
that influenced their evaluation was their attitude to wind power (Molnarova et al., 2012, p. 269). Their
conclusion is that their survey research provides a further argument for considerate planning of
renewable energy and for the use of public participation, factors known to improve public attitudes
toward wind power (Molnarova et al., 2012, p. 277, footnotes omitted).

State guidelines often include provisions designed to ensure that realistic visual impact assessments,
accessible to the public, will be included in wind park planning and applications. Examples include
Kansas guidelines (Kansas Energy Council, 2005, pp. 7-8) and those of Maine, New York, Vermont, and
West Virginia (Vissering, Sinclair, & Margolis, 2011, p. 6). Completing visual impact assessments and
making them accessible to the public should be considered a best practice. The required level of detail can
be adjustable, though, to reflect the particular landscape, population density, and proximity to especially

36
valued scenic vistas. To some extent, the retention of high-concern scenic vistas will be managed by
exclusion zones and setback criteria (discussed in Part III.D, which follows).

D. Critical competing land uses and setback distances

As previously mentioned, some areas should be excluded from consideration for wind turbine placement.
Some important land uses could be so difficult or even impossible to maintain in close proximity to wind
turbines or wind parks, that they should be considered off-limits. As already discussed, primary examples
include important anthropological and cultural resources, significant wildlife habitats and natural resource
areas, and areas with preexisting land uses that are especially noise-sensitive. Mapping such areas and
making that data available to developers and the public is recommended (in Part II.C).

To some degree, impacts on residential property values can serve as a proxy for the determination of the
appropriateness of a wind-parks siting, because perceived adverse impacts will likely emerge in
proximate home sales prices. Wind-park opponents have claimed and frequently predict that home
property values have been and will be negatively affected in the area of wind parks. Therefore, they
sometimes argue, any areas near homes deserve to be excluded from wind-park development.
15

Analyzing the possible effects of wind-park proximity on home values has been difficult due to the
relatively small number of transactions near the turbines (e.g., within one mile). The most thorough
available studies, however (see, e.g., Hoen, Wiser, Cappers, Thayer, & Sethi, 2011, which collected 125
transactions within one mile of existing turbines), have found no evidence of an impact on selling prices
due to proximity to turbines in the period after wind-parks have been constructed and begin operation.
That notwithstanding, there is some emerging evidence that the period after announcement but prior to
operation might coincide with significant impacts to proximate property values (see, for example: Eltham,
Harrison, & Allen, 2008, p. 29; Hinman, 2010; Hoen, Wiser, Cappers, Thayer, & Sethi, 2011, pp. 280-81;
Koebel, 2011, p. 9). During this period, risks to proximate property values are highest because actual
impacts are difficult to ascertain, and, therefore, to the degree that home buyers and sellers take a
risk-averse stance, impacts might be present.

Moreover, as with other large industrial installations, public fears can be exacerbated by perceptions of
secrecy in development plans. In an effort to reduce those fears and decrease the perceived risks, a
number of steps can be taken in the development process. Those include open and transparent public
planning and decision-making processes that include serious attention to public sentiments and concerns,
effectively engaging all interested parties in collaborative, community-based planning, and expanded
efforts to accurately explain the changes to the community due to the wind-park (see Part II.E).

Setbacks from turbines for homes and property lines are a corollary to the property value impact
discussion. In part because of the nascent state of research on property value impacts, reaching consensus
on setback distances has been difficult across the U.S. This has been exasperated by the myriad different
land uses surrounding U.S wind parks. That notwithstanding, guidelines or mandatory requirements from
a handful of states do converge on 1 to 1.5 times the turbine height (that is, tower plus blade length, or
more accurately tower plus rotor and blade radius) from, for example, property lines belonging to non-
participating land-owners, roads, power lines, and other rights-of-way. It is also not unusual for states to
require further setbacks from residences. Examples include Delaware, Massachusetts, New York,
Pennsylvania, Utah and Wyoming (see survey data for these states in Appendix A).

Pennsylvanias Model Ordinance recommends setbacks of 1.1 times turbine height from the nearest

15
In many areas of the country in the recent past, it could have been difficult for casual observers to isolate the
possible effects of wind-park proximity because of the pervasive backdrop of major declines in home values
resulting from the so-called mortgage crisis: There could have been real, observable declines in housing values that
had nothing to do with wind-park proximity.

37
occupied building, but adds,

For non-participating landowners, Wind Turbines shall be set back from the nearest Occupied
Building located on a Non-participating Landowners property a distance of not less than five (5)
times the Hub Height.

Wyomings law (Article 5 Wind Energy Facilities, Statute 18-5-504) requires:

A turbine must be sited at least 110% of its height from any property line contiguous or
adjacent to the proposed facility, unless the property owner waives the setback distance, in
writing.
A turbine must be sited at least 110% of its height from public roads.
A turbine must be 550% of its height and no less than 1000 feet away from platted
subdivisions.
A turbine must be 550% of its height and no less than 1000 feet away from a residential
dwelling.
A turbine must be at least half a mile from city limits.

Two versions of setback criteria are reported as being common in Nova Scotia and Ontario, one for
on-site and one for off-site (that is, for participating and non-participating) residences (Watson, Betts,
& Rapaport, 2011, p. 2).

As previously mentioned, appropriate wind siting and zoning requirements, exclusion zones, and
avoidance areas should depend on many factors. Setback distances tend to be used by siting and zoning
authorities as an administratively simple means of addressing many concerns, including, for example,
noise, shadow flicker, ice throw, wildlife and habitat, and aesthetic requirements.

Setback distances are also used to address two additional concerns, tower collapse or tip-over and blade
failure. Both of these are rare occurrences, at least with respect to modern utility scale wind machines,
and present evidence suggests that setbacks roughly equivalent to or modestly in excess of the turbine
height offer sufficient protection against such risks. As with all other kinds of buildings and towers, to
some extent construction codes and standards protect the public, which makes setback provisions for
these purposes somewhat redundant.

Regulating setback distances is more convenient, in many ways, compared to directly handling the
underlying issues through explicit decisions on a category by category basis. One virtue of setback
distances is that once they are set they are easy to measure. But wind-park opponents frequently seek
excessive setback distances, which they expect will prevent developers from trying to build a project in
the area. If setback distances are based on arbitrary criteria, though, they are not likely to stand up to the
scrutiny of a court challenge. It is better to establish minimal setback distances based on the few criteria
where setback does appear to be justified, such as ice throw, and regulate all other determinations of
distances by regulating the specific concerns as mentioned earlier, such as sound, shadow flicker,
exclusion and avoidance zones for wildlife and habitat, and exclusion and avoidance zones for critical
competing land uses. Given all of those restrictions, developers should be encouraged to work with host
communities to establish a plan for macro- and micro-siting that will respect community desires and
reduce the likelihood of post-construction problems.

E. Permit requirements for met towers, construction, and decommissioning

Siting and zoning authorities are also asked to approve requests to install temporary meteorological (met)
towers. It is also common and appropriate for wind-park permits to be conditioned on meeting specific
terms and conditions for construction and decommissioning.

38

For temporary met towers, jurisdictions with commercial-quality wind resources should predetermine the
requirements and simply procedures for obtaining approvals. Criteria might include, for example, the
maximum height for temporary met towers, a reasonable maximum duration (such as two years for data
collection, plus reasonable set-up and take-down time), setbacks of at least tip-over distance from non-
waived property lines and occupied buildings, and provisions for removal or replacement after initial data
collection.

For construction, developers should enter into binding agreements with the appropriate authorities,
ensuring that they will meet all requirements for minimizing negative impacts during construction. That is
the same as for any other major construction project, with terms covering, for example, natural resource
protection (e.g., wetlands, surface and storm water), noise, dust, and traffic.

Provisions for future site decommissioning and the restoration or reclamation of the land should also be
included in permit requirements, and the decommissioning plan should be adopted as a binding contract
between the developer and the relevant government authorities. The plan should describe what
circumstances will trigger decommissioning, and the plan should be secured by an appropriate financial
instrument (e.g., performance bonds, letters of credit or other corporate guarantees).

Rosenberg (2008, p. 684) relates:

Of particular importance in the permitting process is the closure or decommissioning phase of the
project's life cycle. At the conclusion of their useful life, wind power facilities must be
disassembled and the site restored to its pre-construction conditions or other conditions specified
in the permit. Wind project applicants must provide financial assurance to the state that these
steps are properly funded... Having this financial assurance will prevent the unfortunate situation
of localities having abandoned facilities in their midst without available resources to carry out
proper decommissioning.

F. Dispute resolution and mitigation

Finally, in the interest of clarity, predictability, and transparency, a wind-park siting and zoning permit
should include provisions for dispute resolution and mitigation. This is no different from any other major
contract, which includes fair and foreseeable provisions for complaint or dispute resolution. It is helpful
for all concerned to understand their responsibilities and the procedures to be followed in the event that
disputes arise.

39
Summary and Conclusions

The beginning of this report observes that wind-park developers have a propensity to focus their efforts
first on those areas with ample wind resources and few barriers to siting and zoning. The reverse is also
true; developers will avoid areas with uneconomical or marginal wind resources and where siting and
zoning barriers are difficult to overcome.

Prospective wind-park neighbors who are opposed to development are likely to cheer siting and zoning
ordinances that have the effect of blocking construction in their environs. But siting and zoning author-
ities should recognize their responsibilities both to create ordinances that meet all legal requirements, and
to consider how the costs and benefits of siting decisions will affect everyone in their jurisdiction, not
only those who are most vocal. And, as Ellenbogen et al. (2012, pp. ES-1112) observe,

The considerations should take into account trade-offs between environmental and health impacts
of different energy sources, national and state goals for energy independence, potential extent of
impacts, etc.

Of course there are some areas that should be excluded and reasonable setback distances should be
maintained for a variety of land use types, including occupied buildings, roadways, utility rights of way,
and special wildlife habitats. Leung & Yang (2012, p. 1032) report:

Though wind power has performed well in recent years, it also creates a strong environmental
impact, such as noise, visual and climatic impact. Although these impacts seem minor when
compared with fossil fuels, its effect on humans should not be overlooked, due to its potential
great development in usage. It is necessary to figure these potential drawbacks out, especially
their potential long-term effects, and to find solutions to them in order to retain the long-term
sustainability of wind energy.

Rosenberg (2008, p. 665) acknowledges:

Although there are many advantages to wind power, disadvantages exist as well. Every energy-
producing technology contains pros and cons which must be evaluated by government
policymakers, the public and private investors. With regard to wind energy, some of the
associated adverse effects or disadvantages are inherent in the nature of wind power itself while
others relate to the use of this technology at particular sites. In the end, judgments must be made
balancing and comparing the positive features with the negative ones.

Rosenberg (2008, p. 669) also points out:

As research and experience with wind power technology become increasingly available, it is
possible to separate verifiable claims of harm from those without basis in fact.

The associated hope is that increased experience, and the wisdom derived from it, will help guide future
siting and zoning decisions. In the meantime, however, siting and zoning authorities, government energy
policy decision makers at every level, and competitive markets that help shape energy supply and demand
all have roles to play in making decisions based on the best available information.

In any case, the energy policy issues of concern to wind energy proponents also deserve some
consideration in siting and zoning decisions. Those issues include, for example: diversifying energy
supply; reducing reliance on fossil fuels; conserving water; and reducing or eliminating air pollutants and
greenhouse gas emissions. Some weight should also be given to the prospective economic benefits for
rural landowners and rural areas and from wind energy manufacturing, construction, operations and
maintenance (Rosenberg, 2008, pp. 659-665).

40

The precautionary principle can be a useful guide to decision makers, but wind energy opponents propose
siting and zoning precautions based on one set of concerns, while proponents propose another set.
Sunstein (2005, p. 93) observes:

Much of the time what is available and salient to some is not available and salient to all. For
example, many of those who endorse the Precautionary Principle focus on cases in which the
government failed to regulate some environmental harm, demanding irrefutable proof, with the
consequence being widespread illness and death. To such people, the available incidents require
strong precautions in the face of uncertainty. But many other people, skeptical of the
Precautionary Principle, focus on cases in which the government overreacted to weak science,
causing large expenditures for little gain in terms of health or safety. To such people, the
available incidents justify a measure of restraint in the face of uncertainty. Which cases will be
available and to whom?

As Sunstein explains, applying the precautionary principle requires decisionmakers to consider margins
of safety and both the probability and magnitude of harm that might result from their decisions. Sunstein
(2005, pp. 117-118) reasons:

Let us suppose, too, that we will learn over time. If so, we might elect to take certain steps
now, on the basis of a principle of Act, then learn. The steps we now take would not be the
same as those that we would take if the worst outcomes were more probable, but they should be
designed so as to permit us to protect against the worst outcomes if we eventually learn that they
are actually likely. On this view, an understanding of what we do not know means not that
regulators should do little, but that they should act in stages over time, adopting precautions that
amount to a kind of insurance against the chance that the harm will be higher than we currently
project in light of our current knowledge of both probability and magnitude. (footnote omitted).

Everyone needs to recognize that each wind energy macro- and micro-siting decision has fairly long-term
ramifications. Once a turbine location is pinpointed, that decision has the effect of preventing another
turbine from being placed any closer than a few rotor diameters away. Specific distances between turbines
in a wind park will be determined based on exclusion and avoidance zones, siting and zoning setback
requirements, and data regarding prevailing winds and technical aspects of the particular turbine and its
blades. This does mean that siting decisions will have long-lasting effects in the landscape.

By the same token, everyone also needs to realize that wind turbine technology and operating practices
continue to improve, so that the potential negative impacts and concerns raised by future machines could
be fewer and smaller than those of today. This implies, at least to some extent, that there could be
multiple paths to mitigation for decisions made today that result in significant concerns or complaints.
Future mitigation could include, for example, replacing various important wind turbine components (such
as blades, gearboxes, controls), or even whole turbines, with machines that are some combination of more
reliable, quieter, and safer.

The important questions decisionmakers and policymakers can ask are: (1) Is there a middle ground that
does not require compromises where everyone loses? and (2) Are there opportunities for improvement in
wind-park siting and zoning procedures that are most likely to lead to a more rapid accumulation of the
information and wisdom needed to guide future decisions?

Among researchers studying wind-park siting, there is at least some optimism regarding finding answers
to these questions. For example: Wolsink (2007a) suggests that better solutions will be found through
collaborative, community-based planning; Upham (2009) proposes that solutions might be found through
focused attention on the field of environmental psychology; Sovacool (2009) advises attention to a
broader research agenda about both social and technical aspects of decision making; and Sengers, Raven,
& Van Venrooij (2010) recommend a concentrated study of news media and the potential role of news

41
media in public education regarding decisions about our energy future. Any and all of these paths might
prove advantageous.

For the time being, the most sensible recommendation is for communities to work together to make
decisions about future energy systems development, not only wind energy development, in their own
local area. There are multiple paths to this goal, insofar as wind energy development is concerned. Some
developers work extensively with host communities, prior to seeking siting and zoning approval, to create
macro- and micro-siting plans that engender little, if any, public opposition. Some land owners associate
and hire their own developers, so that the owners can directly guide decisions about setback distances and
micro-siting. Some governments simultaneously develop specific plans that identify both areas where
wind parks will be excluded or should be avoided, and also those areas where wind parks will be
welcomed. Hindmarsh (2010, p. 560) holds that making good decisions about wind turbine siting requires
collaborative approaches, including the technical mapping of wind resources [and identifying]
community qualifications and boundaries for wind farm location. He argues that community-based
decision making is likely to result in improved problem framing and decision making concerning wind
farm location, and thus development. The goal, as Hindmarsh notes, is a process that will be perceived
as legitimate and fair, and thus sustainable. Reaching that goal might be considered overly optimistic, but
at least some communities have shown a willingness to give it a try. There is at least a good prospect that
these approaches can reduce contentiousness and move towards consensus on how to guide wind-park
siting and zoning.

At the outset, this report noted that wind-park siting and zoning presents serious challenges and that
proposals frequently attract public opposition and are therefore contentious. History does show that public
attitudes about any new technology are subject to change over time, as experience is gained. History
reminds us of a similar controversy, where over 300 people vigorously protested construction of a local
project which they called useless and a grotesque monster. It was said that building it would be a
threat to public health, safety, and well-being. Such was part of the initial reaction to constructing the
Eiffel Tower. (Gipe, 1995, pp. 252-55). Only time will tell how apt that comparison might be.

42
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48
Appendix A:
State Survey Reports

The Appendix is bound separately and is available as a PDF file at the following URL:

http://www.nrri.org/pubs/electricity/NRRI_Wind_Siting_Survey_Jan12-03A.pdf

Put It There!
Wind Energy & Wind-Park Siting and Zoning
Best Practices and Guidance for States

Appendix A:
State Wind Siting and Zoning Survey

Tom Stanton
Principal for Electricity

Deborah Luyo
Research Assistant

January 2012
12-03

Acknowledgements

This material is based upon work supported by the Department of Energy, National Energy Technology
Laboratory under Award Number(s) DE-OE0000123.

This paper results from a National Association of Regulatory Utility Commissioners (NARUC) grant for
State Electricity Regulators Capacity Assistance and Training (SERCAT). Funding for the NARUC
SERCAT program is provided under a cooperative agreement between NARUC and the U.S. Department
of Energy (DOE) and National Energy Technology Laboratory (NETL). NRRI is grateful to NARUC, the
DOE, and NETL for supporting SERCAT and this project.

The authors wish to thank these colleagues from the National Regulatory Research Institute. Without their
assistance, this project would not have been possible. Four NRRI student interns worked many hours
during their summer break from classes in 2011. These students completed initial surveys of the states:

Kai Goldynia, from Okemos, Michigan, a sophomore studying History and Environmental
Studies at Amherst College in Amherst, Massachusetts;
Francis Motycka, from East Lansing, Michigan, a junior at The College of William and
Mary, planning to double major in Economics and Government;
Lauren Teixeira, from Silver Spring, Maryland, a sophomore at Grinnell College in
Grinnell, Iowa; and
Marley Ward, from St. Clair Shores, Michigan, a sophomore at the University of Michigan
Dearborn.

In addition, more than 100 individuals from all over the U.S. helped us check our survey work, including
all those who helped identify the most appropriate in-state contact persons and especially those
individuals listed as reviewers on the state survey reports.

The authors alone are responsible for any errors and omissions that remain.

Online Access

These survey reports can be accessed online via the National Regulatory Research Institute website at
http://www.nrri.org/pubs/electricity/NRRI_Wind_Siting_Survey_Jan12-03A.pdf

Disclaimer

This report was prepared as an account of work sponsored by an agency of the United States Government.
Neither the United States Government nor any agency thereof, nor any of their employees, makes any
warranty, express or implied, or assumes any legal liability or responsibility for the accuracy,
completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents
that its use would not infringe upon privately owned rights. Reference herein to any specific commercial
product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily
constitute or imply its endorsement, recommendation, or favoring by the United States Government or
any agency thereof. The views and opinions of the author expressed herein do not necessarily state or

A-1
Table A-1: State Wind Siting and Zoning Survey Summary Table
(26 Jan 2012)

State
NRRI
Review
Completed
Sent to
State
Contact(s)
Response
from
Contact(s)
Followup
Additional
Edits
Complete
No. of Jurisdictions: 51 51 39 6 5 39
No. of Contacts: 106 47 6 5 44
Alabama x x x x
Alaska x x x x
Arizona x x x x x x
Arkansas x x x x
California x x
Colorado x x
Connecticut x x x x
Delaware x x x x
District of Columbia x x x x
Florida x x x x
Georgia x x x x
Hawaii x x
Idaho x x x x
Illinois x x x x
Indiana x x x x
Iowa x x x x
Kansas x x x x
Kentucky x x x x
Louisiana x x x x
Maine x x x x x x
Maryland x x x x
Massachusetts x x x x
Michigan x x x x
Minnesota x x x x
Mississippi x x
Missouri x x
Montana x x x x
Nebraska x x x x x
Nevada x x x x
New Hampshire x x x x x x
New J ersey x x x x
New Mexico x x x x
New York x x x x
North Carolina x x
North Dakota x x x x
Ohio x x x x
Oklahoma x x x x
Oregon x x
Pennsylvania x x x x

Table A-1: State Wind Siting and Zoning Survey Summary Table
(26 Jan 2012)

A-2
State
NRRI
Review
Completed
Sent to
State
Contact(s)
Response
from
Contact(s)
Followup
Additional
Edits
Complete
Rhode Island x x
South Carolina x x x x
South Dakota x x x x
Tennessee x x
Texas x x x x x x
Utah x x
Vermont x x x x
Virginia x x x x x x
Washington x x x x
West Virginia x x x x
Wisconsin x x
Wyoming x x

The authors intend to continue efforts to update the survey reports, as needed, to keep them up to date.
New information to update the survey results are welcome. Comments can be submitted to:

Tom Stanton, Principal for Electricity
National Regulatory Research Institute
tstanton@nrri.org (517) 775-7764

A-3 Alabama

State: Alabama

Wind siting basics: Investor-owned utilities providing retail electric service to the public must obtain a
Certificate of Public Convenience and Necessity (CPCN) from the Alabama Public Service Commission
(PSC) for construction of power generation facilities intended to serve the public. During its review, the
Commission considers, among other things, the proposed facility location. However, the PSC has no
specific siting authority over wind generation or generation facilities proposed by a non-regulated utility.

Other state entities that may have authority include: Alabama Department of Environmental Management;
Alabama Department of Conservation and Natural Resources; local zoning authorities such as counties
and cities; and circuit courts of the counties.

History of siting authority: The PSC does not have any history regarding the siting of wind turbines for
the generation of power.

Approvals needed: Investor-owned utilities providing retail service to the public must obtain a
Certificate of Public Convenience and Necessity (CPCN) from the Alabama Public Service Commission
for construction of power generation facilities (Stemler, 2007).

Evaluation criteria: As part of its consideration of a regulated utilitys request for a CPCN to construct a
power generation facility intended to serve the public, the PSC reviews data rom the company, including:
the type, location and cost of the proposed generation facility and related transmission facilities and
upgrades; the companys existing and planned resources; the companys existing and forecasted reserve
levels; and various demand and cost data germane to the request.

Public input: CPCN hearings are open to the public. In addition, any person or entity granted intervenor
status may participate in the proceedings.

Relationships to other important energy policies or siting and zoning decisions: Alabama is a fully
regulated market for retail electric service. Utilities under the jurisdiction of the PSC have a legal duty to
maintain their facilities and proper reserve levels in order to render adequate service to the public and as
necessary to meet the growth and demand of the service territory.

Contacts:

J ohn Free, Director
Electricity Policy Division
Alabama Public Service Commission
100 N Union Street, RSA Union
Montgomery, AL 36104
john.free@psc.alabama.gov

Pam Thomas
Wildlife Section
Alabama Division of Wildlife and Freshwater Fisheries
64 North Union Street, Suite 584
Montgomery, AL 301457
Pam.Thomas@dcnr.alabama.gov

Alabama A-4

Citations and links:

Edison Electric Institute. (2004). State Generation & Transmission Directory: Agencies, Contacts,
and Regulations.
www.eei.org/ourissues/ElectricityTransmission/Documents/State_Generation_Transmission_Siti
ng_Directory.pdf.

Stemler, J odi. (Apr 2007). Wind Power Siting Regulations and Wildlife Guidelines in the United
States. U.S. Fish & Wildlife Service.
www.fws.gov/midwest/wind/guidance/AFWASitingSummaries.pdf.

Data gathered by Deborah Luyo, 3 Nov 2011
Reviewed by John Free, 25 J an 2012.
A-5 Alaska

State: Alaska

Wind siting basics: The Regulatory Commission of Alaska (RCA) issues a Certificate of Public
Convenience and Necessity to any utilities and independent power producers in the state. The RCA is not
involved in siting activities. Depending on site land ownership and environmental impacts, permits for
turbine sites are handled through the Alaska Department of Natural Resources and Division of Wildlife,
the U.S. Army Corp of Engineers, Federal Aviation Administration (FAA), and Fish and Wildlife
Service, and local governments.

History of siting authority: RCA does not provide a siting review; however, generating facilities serving
ten or more persons are required to receive a CPCN. (See:
www.fws.gov/midwest/wind/guidance/AFWASitingSummaries.pdf.)

Approvals needed: No state-level approval is needed. Some cities and municipalities have specific wind
generator siting and zoning procedures.

General permitting guidelines can be found at
www.akenergyauthority.org/Reports%20and%20Presentations/2009WindBestPracticesGuide.pdf.

Evaluation criteria: No state-level criteria.

Public input: No specific procedures identified.

Relationships to other important energy policies or siting and zoning decisions: Alaskas Coastal
Zone Management Program, run by the State Department of Natural Resources, used to serve as a one-
stop shop for permitting issues involving the states coastal zones. The program was discontinued by the
Alaska legislature this year, though, and restarting it could take as long as two to three years.
1

Contacts:

Rich Stromberg, Wind Program Manager
Alaska Energy Authority
813 West Northern Lights Boulevard
Anchorage, AK 99503
(907) 771-3053
rstromberg@aidea.org


Alaska Energy Authority. (Sep 2009). Alaska Wind Energy Development: Best Practices Guide to
Environmental Permitting and Consultation.
www.akenergyauthority.org/Reports%20and%20Presentations/2009WindBestPracticesGuide.pdf.

Alaska Energy Authority. (30 J un 2011). Wind Programs [web page]. Retrieved 7 Aug 2011 from
www.akenergyauthority.org/programwindenergybasics.html.

1
Rich Stromberg, 15 Aug 2011, personal communication. See
www.alaskajournal.com/stories/060311/loc_sczm.shtml, www.adn.com/2011/06/20/1927031/alaska-
house-rejects-special-session.html, and www.alaskapublic.org/2011/06/08/senators-warn-against-letting-
coastal-zone-management-program-die/.

Alaska A-6

Database of State Incentives for Renewables & Efficiency. (J un 2011). Alaska Incentives/Policies for
Renewables & Efficiency [web page]. Retrieved 7 Aug 2011 from
www.dsireusa.org/incentives/index.cfm?re=1&ee=1&spv=0&st=0&srp=1&state=AK.

Stemler, J odi. (Oct 2007). Wind Power Siting, Incentives, and Wildlife Guidelines in the United
States, Alaska. U.S. Fish & Wildlife Service.

U.S. Department of Energy. (J ul 2011). State of Alaska 50-Meter Wind Resource Map.
www.windpoweringamerica.gov/maps_template.asp?stateab=ak.

Data gathered by Kai Goldynia, 7 Aug 2011.
Reviewed by Rich Stromberg, 15 Aug 2011.

A-7 Arizona

State: Arizona

Wind siting basics: The state has no specific wind siting authority, codes, or regulations. Wind facilities
must obtain siting and zoning approvals at the county level.

History of siting authority: The state has no specific wind siting authority.

Approvals needed: No state-level approval is needed for wind facilities. The Arizona Game & Fish
Department provides voluntary guidelines for reducing wildlife endangerment during wind facility
construction and operation.

The Arizona Power Plant and Transmission Line Siting Committee has the authority to approve a
Certificate of Environmental Compatibility (CEC) for transmission lines 115kV or higher. The Arizona
Corporation Commission (ACC) must either confirm, deny or modify the certificate granted by the
Committee or if the Committee refused to grant a certificate, the Commission may issue a certificate
(Arizona Corporation Commission).

Evaluation criteria: Voluntary guidelines issued by the AZ Game & Fish Department include:

(1) Place turbines, roads, power lines, and other infrastructure appropriately, avoiding high-quality
wildlife habitats.
(2) Close, obliterate, and re-vegetate any roads constructed for the project that are not necessary for
facility maintenance after tower construction.
(3) Control or prevent erosion, siltation, and air pollution by vegetating or otherwise stabilizing all
exposed surfaces.
(4) Control or prevent damage to fish, wildlife, or their habitats.
(5) Prevent or control damage to public and/or private property.

Public input: ACC decisions are made during public meetings, with opportunities for public comment.

Relationships to other important energy policies or siting and zoning decisions: The Arizona
Renewable Energy Standard (15% by 2025) includes wind as an eligible technology. Arizona electric
utilities must file with the ACC biennial integrated resource plans, including analysis and discussion of
how the utility will meet the states renewable energy standard.

Pending issues: Major areas of concern are environmental and wildlife criteria, coupled with the
development of a permitting process. Debate continues with regard to establishing comprehensive wind
generator siting procedures. Currently, Arizona lacks any state regulation of wind facilities; however,
with more facilities proposed, environmental groups worry about the increased impact on the physical and
natural environment and habitats of vital plant and animal species. The Arizona Game & Fish Department
is working with counties and the State Land Department to address wildlife concerns.

Contacts:

Ginger Ritter
Arizona Game and Fish Dept.-WMHB
(623)-236-7606
GRitter@azgfd.gov

Arizona A-8

Ray Williamson
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
(602) 542-0828
www.cc.state.az.us/
RWilliamson@azcc.gov


Arizona Corporation Commission. Arizona Power Plant and Transmission Line Siting Committee
[web page]. Retrieved 18 Oct 2011 from www.azcc.gov/divisions/utilities/electric/linesiting-faqs.asp.

Arizona Corporation Commission. Integrated Resource Planning [web page]. Retrieved 29 J ul 2011
from www.cc.state.az.us/divisions/administration/integratedresource.asp.

Arizona Game and Fish Department. (Nov 2009). Guidelines for Reducing Impacts to Wildlife from
Wind Energy Development in Arizona.
www.azgfd.gov/hgis/pdfs/WindEnergyGuidelines.pdf.

Database of State Incentives for Renewables & Efficiency. Arizona Incentives/Policies for
Renewables & Efficiency [web page]. Retrieved 17 J ul 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=AZ03R&re=1&ee=1.

www.fws.gov/habitatconservation/windpower/AFWA%20Wind%20Power%20Final%20Report. pdf.


U.S. Department of Energy. (J ul 2011). State of Arizona 50-Meter Wind Resource Map.
www.windpoweringamerica.gov/maps_template.asp?stateab=az.

Data gathered by Kai Goldynia, 17, 19 J ul 2011.
Reviewed by Ray Williamson, 10 Aug 2011, Ginger Ritter, 3 Nov 2011.

A-9 Arkansas

State: Arkansas

Wind siting basics: Wind siting is done at the local level of government.

History of siting authority: Arkansas Code A.C.A. 23-3-201 (1935)
(www.offthemarble.com/arkcode/Title23/). Arkansas is a Home Rule State.

Approvals needed: All electricity generating facilities that provide a public service are required to
obtain a Certificate of Public Convenience and Necessity (CPCN) from the Arkansas Public Service
Commission.

Evaluation Criteria: None identified.


Relationships to other important energy policies or siting and zoning decisions: None identified.

Contacts:

Diana Brenske, Director
Electric Section
Arkansas Public Service Commission
900 W Capitol Ave
Little Rock, AR 72201
(501) 682-5656
diana_brenske@psc.state.ar.us

J .D. Lowery, Renewable Energy Programs Manager
Arkansas Energy Office
Arkansas Economic Development Commission
(501) 682-7678
jlowery@arkansasedc.com


The Arkansas Code. A.C.A. 23.
http://web.lexisnexis.com/research/xlink?app=00075&view=full&interface=1&docinfo=off&sear
chtype=get&search=A.C.A.+%25A7+23-3-201.

Manthey, Toby. (25 Mar 2011). Wind-Power Talked Up, but Bill Fades, Arkansas Democrat-
Gazette. www.wind-watch.org/news/2011/03/25/wind-power-talked-up-but-bill-fades/.

Data collected by Francis Motycka, 6, 11 J ul, 3 August 2011.
Reviewed by J .D. Lowery, 18 Nov 2011.

California A-10

State: California

Wind siting basics: Siting authority is delegated to municipalities. Every county is required to adopt a
General Plan for wind development. However, they are subject to the California Environmental Quality
Act (CEQA), which requires Environmental Impact Reports (EIRs) and imposes mitigation measures to
reduce significant adverse impacts.

History of siting authority: The California Planning and Zoning Law was modified in 1980 to delegate
land-use decisions to municipalities
(http://leginfo.ca.gov/pub/09-10/bill/sen/sb_0001-0050/sbx8_34_bill_20100322_chaptered.pdf).

The California Environmental Quality Act (CEQA), passed in 1970, requires local governments
permitting facilities to analyze wind generator environmental impacts (www.leginfo.ca.gov/cgi-
bin/displaycode?section=prc&group=20001-21000&file=21000-21006).

Approvals needed: Approvals vary by municipality. It could come from the planning department, one or
more planning commissions, administrative boards or hearing officers, the legislative body itself, or any
combination thereof. Under CEQA, applicants are required to consult with the California Department of
Fish and Game (CDFG) to meet fish and game statutes and wildlife protection laws; however, the CDFG
cannot approve or disapprove of the application. If the project will occupy U.S. Bureau of Land
Management (BLM) land, BLM approval is needed (www.blm.gov/ca/st/en/prog/energy/wind.html).

The applicant should first conduct an initial study of the environmental impacts of the project and prepare
a document meeting the requirements of both the CEQA and the National Environmental Policy Act
(NEPA). If in the initial study the county or the BLM finds potentially significant environmental impacts,
the county and the BLM will hire an environmental consultant to conduct the more comprehensive
Environmental Impact Report (EIR). Once this report is completed, the County Planning Commission
will hold a public hearing to determine whether or not the EIR should be approved. EIR approval
facilitates obtaining other necessary permits, such as a permit pursuant to the Endangered Species Act and
a Conditional Use Permit (CUP), if the applicant is trying to build on certain types of land, like
agricultural land. Once the applicant has acquired all the necessary permits (others include a stormwater
discharge permit and a right-of-way from the BLM if the project involves BLM property), the applicant
can file its application with the county.

Evaluation criteria: Required CEQA environmental impact analysis includes:
-aesthetics
-agricultural resources
-air quality
-biological resources
-geology and soils
-greenhouse gases
-hazards and hazardous materials
-hydrology and water quality
-land use and planning
-mineral resources
-noise
-population and housing
-public services
-recreation
-transportation and traffic
-utilities (meaning any required ancillary facilities, such as for wastewater or waste disposal)

A-11 California

For small wind generators (50kW or smaller), Assembly Bill 45 of 2009 authorizes counties to adopt
siting ordinances. The Bill establishes maximum restrictions for tower height, parcel size, setbacks, public
notice, and noise level
(www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=CA61R&re=1&ee=1).



Pending issues: Proposed legislation, AB 13 (www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0001-
0050/abx1_13_bill_20110707_amended_sen_v95.pdf), seeks to expedite the wind siting process by
expanding the SB 34 (http://leginfo.ca.gov/pub/09-10/bill/sen/sb_0001-
0050/sbx8_34_bill_20100322_chaptered.pdf) process, originally conceived to facilitate solar facility
siting within the states Desert Renewable Energy Conservation Plan (DRECP). This bill would allow
wind project applicants within the DRECP to pay fees to the CA Energy Commission to expedite project
review and pay an in-lieu-of-mitigation fee to the state to ensure adequate wildlife and habitat protections
when the project is sited.

Contacts:

Cheryl Lee
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
www.cpuc.ca.gov/renewables
cheryl.lee@cpuc.ca.gov

Dr. C.P. (Case) van Dam
Department of Mechanical and Aeronautical Engineering
University of California, Davis
One Shields Avenue
Davis, CA 95616
cpvandam@ucdavis.edu

Dr. Bruce R. White
Department of Mechanical and Aeronautical Engineering
University of California, Davis
One Shields Avenue
Davis, CA 95616
brwhite@ucdavis.edu

Kate Zocchetti
California Energy Commission
Renewable Energy Program
1516 Ninth Street, MS-45
Sacramento, CA 95814-5512
(916) 654-3945
www.energy.ca.gov
Kzocchet@energy.state.ca.us


California A-12


California Department of Fish and Game [web page]. Retrieved 22 J un 2011 from www.dfg.ca.gov/.

California Energy Commission. California Guidelines for Reducing Impacts to Birds and Bats from
Wind Energy Development [web page]. Retrieved 22 J un 2011 from
www.energy.ca.gov/windguidelines/index.html.

CEQA Checklist, www.dot.ca.gov/ser/downloads/ceqa/CEQAchecklist.doc. CEQA Guidelines,
http://ceres.ca.gov/ceqa/docs/Adopted_and_Transmitted_Text_of_SB97_CEQA_Guidelines_Amendments.pdf.

Desert Renewable Energy Conservation Plan [web page]. Retrieved 22 J un 2011 from
www.drecp.org/.

Environmental Law Institute. (2011). State Enabling Legislation for Commercial-Scale Wind Power
Siting and the Local Government Role, www.elistore.org/reports_detail.asp?ID=11410.

_________. (March 7, 2011). Renewable energy permitting and siting bill passes California
assembly, Imperial Valley News.
http://imperialvalleynews.com/index.php?option=com_content&task=view&id=9694&Itemid=2.

States. U.S. Fish & Wildlife Service

Stoel Rives. (2011). Case Study: Development of a Wind Prospect in the State of California.
www.stoel.com/files/SRCaseStudy_DevelopmentofWindProjectinCA_2011.PDF.

U.S. Bureau of Land Management [web page]. Retrieved 22 J un 2011 from
www.blm.gov/ca/st/en/prog/energy/wind.html.

Data gathered by Lauren Teixeira, 22 Jun 2011.
A-13 Colorado

State: Colorado

Wind siting basics: Wind facilities must be permitted by both the local and state governments. The
Colorado PUC regulates: (1) eligible renewable energy resources; (2) facilities larger than 2 MW
capacity; and (3) facilities exceeding 50 feet in height. By state law, each county must have a Master
Plan, which includes information on how to make land-use decisions with respect to siting (Stemler,
2007). State enabling legislation encourages counties to consider methods for assuring access to
appropriate conditions for solar, wind, or other alternative energy sources and areas containing
endangered or threatened species in their plans.

History of siting authority: Colorado Statute 40-5-101 (1963, amended 2005, 2007),
www.michie.com/colorado. The Local Government Land Use Control Enabling Act (General Assembly
of Colorado, 1974) delegates broad land-use decision-making authority to the municipalities.

Approvals needed: In general, applicants need one of these county government permits if the proposed
facilitys capacity exceeds a certain threshold established by the county: a 1041 (a.k.a. Areas and
Activities of State Interest) permit, special use permit, or conditional use permit. 1041 permits are
generally required for the site selection and construction of transmission lines, power plants (renewable
and non-renewable), and substations with capacities exceeding the county-specified limit.

The process generally includes a pre-application meeting, public notice, submittal of the permit
application, public hearing, approval of the permit, and post-approval requirements, if applicable.

For more information on these permits, see Colorado Governors Energy Office report (p. 52;
www.dora.state.co.us/puc/projects/TransmissionSiting/EnvironmentSitingLanduse_REDIProject_GEO07-20-2009.pdf).

Projects also need a Certificate of Public Convenience and Necessity (CPCN) from the PUC. The PUC is
required to consult with the Colorado Division of Wildlife and the U.S. Fish and Wildlife Service. Those
agencies usually determine requirements for wildlife impact studies. If the project is to be on federal land
or triggers the National Environmental Policy Act (NEPA) in some way, studies must be conducted
according to NEPA. The applicant must provide written documentation that consultation occurred with
appropriate governmental agencies. In addition, if the project receives federal funding, involves federal
land, or connects to a transmission line belonging to a federal power authority, the applicant must comply
with the federal Endangered Species Act (ESA). Colorado is home to 10 endangered bird species.

The PSC checks to make sure the applicant has the consent of the relevant municipalities and will comply
with the applicable zoning ordinances. An applicant can appeal a county zoning decision to the
Commission and request a hearing. The PSC has the right to amend the CPCN.

Evaluation criteria: The County will either require or encourage the applicant to conduct an
Environmental Impact Assessment (EIA). The Colorado Division of Wildlife requires avian and bat
studies. Typically required permits include:

County Conditional or Special use Permits
County Building Permit
County Septic System Permit
State of Colorado Storm Water Permit (construction)
State of Colorado Dust Controls Permit (construction)
State of Colorado Highway Access and Enroachment Permit (tower and blade transportation)
State of Colorado Water Well Permit


Colorado A-14


Relationships to other important energy policies or siting and zoning decisions: Colorado has a
renewable portfolio standard of 30% by 2020. Transmission projects are being developed to support wind
(www.eei.org/ourissues/ElectricityTransmission/Documents/Trans_Project_V-X.pdf). However, a recent
report by the Governors Energy Office found that CO might not be able to meet its RPS goal unless even
more transmission lines are built (www.denverpost.com/business/ci_13913735).

Colorado Senate Bill 11-45 (J une 2011) established a task force on statewide transmission siting and
permitting, which will report to the governor on its recommendations for improving the states statutory
and regulatory framework (www.dora.state.co.us/puc/projects/TransmissionSiting/SB11-45/SB11-
45.htm). A report by the task force, submitted on 1 Dec 2011, recommended (Colorado Public Utilities
Commission, 2011):
(1) ...increased cooperation and collaboration among local governments that review transmission
applications in Colorado.
(2) When local government land-use decisions on utility projects are appealed to the PUC, and the
PUC's decision is subsequently appealed, cases should go directly to the Colorado Court of
Appeals, rather than to a district court in order to achieve more efficient and timely review.
(3) ...establishment of processes and provision of resources to resolve transmission siting and
permitting disputes between local governments and transmission operators.

Contacts:

Tom Blickensderfer
CO Department of Natural Resources
(303)866-3157
t.blick@state.co.us

Richard Mignogna
Colorado Public Utilities Commission
1560 Broadway, Suite 250
Denver, CO 80202
(303) 894-2871
www.dora.state.co.us/PUC
richard.mignogna@dora.state.co.us

Tom Plant
Governor's Energy Office
1580 Logan Street
Suite 100
Denver, CO 80203
(303) 866-2100
www.colorado.gov/energy
geo@state.co.us


Colorado Governors Energy Office. (20 J uly 2009). Renewable Energy Development Infrastructure
Project: Environmental, Siting, and Land Use Decisions.
www.dora.state.co.us/puc/projects/TransmissionSiting/EnvironmentSitingLanduse_REDIProject_GEO07-20-2009.pdf.

A-15 Colorado

Colorado Public Utilities Commission. (1 Dec 2011). Report of the Task Force on Statewide
Transmission Siting and Permitting. Department of Regulatory Agencies.
www.dora.state.co.us/puc/projects/TransmissionSiting/SB11-45/Report/SB11- 45TF_RptToGA_12-01-2011.pdf.

Edison Electric Institute. (May 2011). Transmission Projects: At a Glance.
www.eei.org/ourissues/ElectricityTransmission/Documents/Trans_Project_V-X.pdf.
Environmental Law Institute. (10 May 2011). State Enabling Legislation for Commercial-Scale Wind
Power Siting and the Local Government Role. www.eli.org/pressdetail.cfm?ID=224.

Freeman, Roger L., & Kass, Ben. (May 2010). Siting Wind Energy Facilities on Private Lands in
Colorado: Common Legal Issues The Colorado Lawyer 39, 5.
www.dgslaw.com/attorneys/ReferenceDesk/Freeman-Kass_ColoLaw_SitingWindEnergy.pdf.

General Assembly of Colorado. (1974). Chapter 23, House Bill 03-1077 Local Government Land
Use Control Enabling Act. www.state.co.us/gov_dir/leg_dir/olls/sl2003a/sl_123.pdf.

J affe, Mark. (3 Dec 2009). Colorado Study Doubts Green Goals, denverpost.com.
www.denverpost.com/business/ci_13913735.

States. U.S. Fish and Wildlife Service.

Data collected by Lauren Teixeira, 7 J ul 2011; Deborah Luyo, 20 Oct 2011.

Connecticut A-16

State: Connecticut

Wind siting basics: The Connecticut Siting Council has sole jurisdiction over electric generating
facilities using renewable energy sources with more than 1 MW of capacity and of PURPA non-
qualifying facilities under 1 MW.

History of siting authority: Connecticut statutes Sections 16-50g, 16-50k and 16-50x(d) (1971, as
amended) grant authority to the Connecticut Siting Council
(www.cga.ct.gov/2011/pub/chap277a.htm#Sec16-50j.html). A new law, Connecticut Public Act 11-245
(PA 11-245), effective 1 J ul 2011, requires the Connecticut Siting Council by 1 J ul 2012, in consultation
with the departments of Public Utility Control and Environmental Protection, to adopt regulations
concerning the siting of wind turbines. (See Pending Issues.)

Approvals needed: Electric generation facilities using renewable energy sources with more than 65 MW
of capacity could have a significant adverse environmental effect and require a certificate from the
Connecticut Siting Council. Electric generation facilities using renewable energy sources with fewer than
65 MW of capacity could have a significant adverse environmental effect and require a declaratory
ruling from the Connecticut Siting Council.

The applicant for a certificate must consult the municipality in which it wishes to build at least 60 days
prior to filing the application. Within 60 days of that consultation, the municipality must issue its
recommendation to the applicant. The applicant must also consult the municipal zoning and inland
wetland agencies. The agencies have 65 days after the time the application is filed to issue an order
restricting or regulating the proposed site. Concerned parties have 30 days after the order is issued to
appeal it to the Council. The Council can affirm, revoke, or modify the zoning or wetlands order. If the
Council accepts the application, it must hold a public hearing in which all parties to the proceeding may
offer testimony and file evidence. The Council can reject an application if it fails to comply with certain
data requirements. The Council must render a decision within 180 days of receipt of the application. The
suggested form and content of the application can be found here:
www.ct.gov/csc/lib/csc/guides/guidesonwebsite042010/renewableenergyfacilityapplicationguide.pdf#51365.

Only two wind facilities have been approved in the state of Connecticut: BNE filed its petition to build its
Colebrook South facility on 6 Dec 2010 and its petition to build its Colebrook North facility on 13
December 2010. Their petitions were approved on 2 June 2011 and 9 J une 2011, a time frame of about six
months; however, including the municipal consultation beforehand, the total time was probably a few
months more.

Evaluation criteria: Prior to passage of PA 11-245, criteria included:

consultation with state agencies and municipal commissions
Applications including reviews of:
o hazards to air traffic;
o health and safety;
o justification of selection of the proposed site, including a comparison with alternative sites
that are environmentally, technically, and economically practicable;
o explanation of why this project is necessary for the reliability of electric power supply of the
state or is necessary for a competitive market for electricity;
o description of the projects proximity to certain areas
(www.ct.gov/csc/lib/csc/guides/guidesonwebsite042010/renewableenergyfacilityapplicationguide.pdf#51365.)

A-17 Connecticut

The applicant must include assessment of the historic and expected availability of necessary
electric transmission infrastructure. This includes [t]he construction type of the transmission
interconnection (overhead, underground, single circuit, double circuit) and the existing and
expected transmission line loadings, substation interconnection plan, and the anticipated range of
dispatch based on transmission grid constraints. In addition, provide a final copy of, or a status
report on, the independent system operator transmission grid interconnection study.

Public input: A public hearing will be required under Connecticut Public Act 11-245. (See Pending
issues.)

Relationships to other important energy policies or siting and zoning decisions:

The applicant must show how its proposed facility is consistent with the approved Integrated Resource
Plan. The agency in charge of IRP is the Department of Energy and Environmental Protection (DEEP).

Pending issues: Regulations promulgated under PA 11-245 must at least consider (1) setbacks, including
tower height and distance from neighboring properties; (2) flicker; (3) a requirement for the developer to
decommission the facility at the end of its useful life; (4) different requirements for different size projects;
(5) ice throw; (6) blade shear; (7) noise; and (8) impact on natural resources. The regulations must also
require a public hearing for wind turbine projects.

PA 11-245, effective date 1 J ul 2011, bars the CT Siting Council from acting on any application or
petition for siting a wind turbine until the new regulations are adopted
(www.cga.ct.gov/2011/SUM/2011SUM00245-R03HB-06249-SUM.htm).

Contacts:

Linda Roberts, Executive Director
Connecticut Siting Council
(860) 827-2935
www.ct.gov/csc/site/default.asp
linda.roberts@ct.gov


Connecticut Siting Council . (Apr 2010). Application Guide for a Renewable Energy Facility.
www.ct.gov/csc/lib/csc/guides/guidesonwebsite042010/renewableenergyfacilityapplicationguide.pdf.


Podsada, J anice. (9 J un 2011). Connecticut Siting Council approves Colebrook wind farm today
despite protests, Hartford Courant, http://articles.courant.com/2011-06-09/business/hc-ct-future-
wind-farm-20110609_1_fairwindct-gregory-zupkus-wind-farm.

Siedzik, J ason. (18 Apr 2011). Legislative Push Continues for Moratorium on Wind Turbines,
Litchfield County Times.
http://countytimes.com/articles/2011/04/18/news/doc4da6fb6809a44285141426.txt.

Data collected by Lauren Teixeira, 21 Jun 2011; Tom Stanton, 18 Oct 2011.
Reviewed by Melanie Bachman, 24 Oct 2011.

Delaware A-18

State: Delaware

Wind siting basics: Wind siting authority is at the local level.

History of siting authority: None identified.

Approvals needed: For an Eligible Energy Resource, which includes wind generators, the generation
unit must be certified by the Delaware Public Service Commission. The Eligible Energy Resource can
then register with PJ Ms Environmental Information Services (EIS) Generation Attribute Tracking
System (GATS; www.pjm-eis.com/getting-started/about-GATS.aspx), which tracks renewable energy
credits (RECs) for compliance with state renewable portfolio standards (RPSs).

Developers should contact the Delaware Department of Natural Resources & Environmental Control,
Regulatory Advisory Service (www.dnrec.delaware.gov/SBA/Pages/RegulatoryAdvisoryService.aspx).
This Service will help identify all required state (and federal) permits, depending on the location of a
proposed wind development. Examples include state-regulated wetlands, sediment and storm-water
requirements for land disturbances, and federal coastal zone requirements.

Evaluation criteria: The following are criteria for wind siting on private property that may be used by
county and municipal governments, as stated in Title 29, Chapter 80 of the Delaware Code:

(1) Historical: Any wind energy system shall be buffered from any properties or structures included
on the Historic Register.
(2) Property Setback: Wind turbines shall be setback 1.0 times the turbine height from [the]
adjoining property line. Turbine height means the height of the tower plus the length of 1 blade.
(3) Noise: The aggregate noise or audible sound of a wind system shall not exceed 5 decibels above
the existing average noise level of the surrounding area and shall be restricted to a maximum of
60 decibels measured at any location along the property line to the parcel where the wind system
is located.
(4) Visual: Wind systems shall be free from signage, advertising, flags, streamers, any decorative
items or any item not related to the operation of the wind turbine. Electric wiring for the turbines
shall be placed underground for non-building integrated systems.


Relationships to other important energy policies or siting and zoning decisions: Delaware has a
renewable portfolio standard (RPS) requiring 25% of electricity sold by utilities to come from renewable
energy sources by 2025 and imposing interim annual portfolio requirements.

Research Issues: The only current commercial wind turbine is on the University of Delaware-Lewes
campus. The 2 MW wind turbine was constructed without any environmental permits. The University is
completing a two-year research project to measure the impact of the schools wind turbine on bird and bat
mortality. The study is expected to be completed by December 2013.

Contacts:

Kimberly Chesser
Delaware Department of Natural Resources & Environmental Control (DNREC)
Kimberly.Chesser@state.de.us

A-19 Delaware

Courtney Stewart
Delaware Public Service Commission
861 Silver Lake Blvd.
Cannon Bldg., Suite 100
Dover, DE 19904
(302) 736-7500
www.state.de.us/delpsc/default.shtml
courtney.stewart@state.de.us


Boyle, Elizabeth. (7 Mar 2011). Study to Quantify Turbine Impact on Birds and Bats, Udaily.
www.udel.edu/udaily/2011/mar/wind-turbine-study-030711.html.

Database of State Incentives for Renewables & Efficiency. Delaware Incentives/Policies for
Renewables & Efficiency [web page]. Retrieved 11 J uly 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=DE06R&re=1&ee=1.

The Delaware Code. 26 Del. C., 202a . 29 Del. C., 80-8060.
http://delcode.delaware.gov/title26/c001/sc02/index.shtml,
http://delcode.delaware.gov/title29/c080/sc02/index.shtml.

Delaware Department of Natural Resources and Environmental
Control (DNREC), Environmental Permits [web page]. Retrieved 11 J ul 2011 from
www.dnrec.delaware.gov/Pages/default.aspx.

Delaware Municipal Electric Corporation. Delaware Municipal Utilities History [web page].
Retrieved 14 Aug 2011 from www.demecinc.net/History/.

Delaware Public Service Commission [web page]. Retrieved 11 J ul 2011 from
http://depsc.delaware.gov/.

Delawares Sustainability Energy Utility Task Force and Board. Sustainable Energy Utilities
[web page]. Retrieved 11 J ul 2011 from www.seu-de.org/.

Murray, Molly. (27 Apr 2011). Lewes Group Question University of Delaware Wind Turbine, The
News Journal.
http://pqasb.pqarchiver.com/delawareonline/access/2330517921.html?FMT=ABS&date=Apr+27%2C+2011.

Data gathered by Francis Motycka, 6, 11, 12, J ul, 4 Aug 2011; Tom Stanton, 30 Aug 2011.
Reviewed by Courtney Stewart and Kimberly Chesser, 30 Aug 2011.

District of Columbia A-20

Jurisdiction: District of Columbia

Wind siting basics: None identified.


Approvals needed: None identified.

Evaluation criteria: None identified.


Relationships to other important energy policies or siting and zoning decisions: Washington, DC has
a renewable energy portfolio standard of 20% by 2020 (Database of State Incentives for Renewables &
Efficiency, 2011).

Contacts:

Roger Fujihara
DC Public Service Commission
1333 H Street, NW, Suite 200
Washington, DC 20005
(202) 625-0558
www.dcpsc.org
rfujihara@psc.dc.gov

Emil King
Energy Division
District Department of the Environment
2000 14
th
Street, NW, 300 East
Washington, DC 20009
(202) 673-6700
http://ddoe.dc.gov/ddoe
emil.king@dc.gov


Database of State Incentives for Renewables & Efficiency. (29 Aug 2011). District of Columbia
Incentives/Policies for Renewables & Efficiency [web page].
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=DC04R&re=1&ee=1.

Data collected by Deborah Luyo, 21 Nov 2011.
Reviewed by Roger Fujihara, 29 Nov 2011.

A-21 Florida

State: Florida

Wind siting basics: Currently, all applicants proposing to build a wind farm must obtain a variety of
permits from various federal and state agencies. There is one-stop permitting for power plants 75 MW
and over; however, Florida has yet to extend this process to wind. If the farm is to be on state land, the
applicant needs approval from the state Siting Board (the governor and the cabinet).

History of siting authority: Since Floridas Power Plant Siting Act
(www.dep.state.fl.us/siting/power_plants.htm) does not apply to wind farms, applicants must obtain all of
the necessary permits one by one. The necessary permits are laid out on the Florida Department of
Environmental Protection (DEP) website: www.dep.state.fl.us/siting/files/renew_resource_permitting.pdf

Approvals needed: The applicant must obtain approval, either through a permit or authorization, from a
variety of federal and state agencies, including: the Federal Aviation Administration, the U.S. Fish and
Wildlife Service, the Florida Department of Transportation, the Florida Fish and Wildlife Conservation
Commission, the Florida Department of Business and Profession Regulation, the Florida Department of
Environmental Protection (sub-agencies: Bureau of Beaches; Stormwater Program; State Lands; District
offices), and the Florida Office of Historic Preservation

Evaluation criteria: On the federal level, the applicant must issue a Notice of Proposed Construction
concerning height restrictions to the Federal Aviation Administration. A wildlife permit from the U.S.
Fish and Wildlife Service is also required.

On the state level, the following authorizations and permits are required:

Access and roadway (Florida Department of Transportation)
Migratory Bird Nest Removal and Relocation Permit (Florida Fish and Wildlife)
Business incorporation (Florida Department of State)
Business license (Florida Department of Business and Profession Regulation)
Coastal Construction Control Line (Florida DEP Bureau of Beaches)
Environmental resources permit (Florida DEP District Office)
National Historical Preservation Act Compliance (Florida Office of Historic Preservation)
National Pollutant Discharge Elimination System (NPDES) Stormwater Permit for Construction
(Florida DEP Stormwater Program)
State Lands Determination Waterways (Florida DEP State Lands)

On the county level, the following authorizations and permits are required:

Building
Business license
County wetlands
Land-use determination
Local fire marshal
Noise ordinance
Zoning

Palm Beach County, which is in the process of approving Floridas first wind farm, has Alternative
Energy Development Guidelines, which the County Council voted to amend in order to accommodate
the height of the proposed turbines.

Public input: Some counties include public hearings in the zoning process.

Florida A-22


Pending issues: Florida is currently in the process of siting what might be its first wind farm. A few years
ago, Florida Power and Light attempted to site a 20 MW wind farm on Hutchinson Island in St. Lucie
County, but the initiative failed because of widespread public opposition and because three of the turbines
were to be on public land. Right now, Wind Capital Group, St. Louis, Missouri, has applied to build an
80-turbine, 150 MW wind farm in the Everglades agricultural area in Palm Beach County. The project has
come into question in light of a recent U.S. Fish and Wildlife analysis that identifies concerns for avian
mortality. The Fish and Wildlife Service has recommended a more comprehensive study.

Contacts:

Cindy Mulkey
DEP Siting Coordination Office Program Manager
850-245-2175
cindy.mulkey@dep.state.fl.us


Cogan, J esse. (21 J ul 2008). Big Florida Wind Provider Offers Long-Winded Excuse to Floridians
for Windless Policy. The Cutting Edge.
www.thecuttingedgenews.com/index.php?article=651&pageid=21&pagename=Energy.


King, Bob. (1 J une 2011). Dustup over Florida wind farm, Politico.
www.politico.com/news/stories/0511/55947.html.
.
Florida Department of Environment Protection [web page]. Retrieved 26 J ul 2011 from
www.dep.state.fl.us/.

Florida Department of Transportation [web page]. Retrieved 26 J ul 2011 from
www.dot.state.fl.us/onestoppermitting/access_type.shtm.

Florida Fish and Wildlife Conservation Commission [web page]. Retrieved 26 J ul 2011 from
http://myfwc.com/.

Florida Office of Historic Preservation [web page]. Retrieved 26 J ul 2011 from
www.flheritage.com/preservation/compliance/index.cfm.

Reid, Andy. (28 J ul 2011). Palm Beach County wind turbines get initial go-ahead, despite threat to
birds, Sun Sentinel. http://articles.sun-sentinel.com/2011-07-28/news/fl-wind-turbines-
everglades-20110728_1_wind-turbines-collisions-with-turbine-blades-wind-farm-proposal.


Data collected by Lauren Teixeira, 26 Jul 2011.
Reviewed by Cindy Mulkey, 8 Nov 2011.

A-23 Georgia

State: Georgia

Wind siting basics: Georgia has no specific siting authority for wind power. Regulation is administered
by local government. (Stemler, 2007).

Approvals needed: Most local governments require a land-use permit (Georgia Wind Working Group).

Evaluation criteria: Voluntary siting and land-acquisition guidelines for developers, created by the
Georgia Wind Working Group, include:
Aesthetic impacts
Avian and bat mortality
Noise
Possible construction impacts
Utility interconnection impacts



Contacts:

Kristofor Anderson
Georgia Environmental Finance Authority
wind@gawwg.org

Rita Kilpatrick
Southern Alliance for Clean Energy
Kilpatrick@cleanergy.org

J im Ozier
Georgia Department of Natural Resources
116 Rum Creek Drive
Forsyth, GA 21029
(478) 994-1438
J im_ozier@dnr.state.ga.us


Georgia Wind Working Group. (Oct 2006). Georgia Wind: A Guidebook to Wind Development in
Georgia.
www.gawwg.org/images/Georgia_Wind_Guidebook_Updated_October_26th,_2006.pdf.

www.fws.gov/habitatconservation/windpower/AFWA%20Wind%20Power%20Final%20Report.pdf.

Reviewed by Rita Kilpatrick and members of the Georgia Wind Working Group, 19 Dec 2011.
Hawaii A-24

State: Hawaii

Wind siting basics: Wind production in Hawaii is mainly small scale, and siting procedures are
administered by local government (Stemler, 2007). Environmental reviews are conducted at the federal,
state, and county levels. No guidelines specific to wind energy have been developed. Regulation is
administered through general permitting guidelines (Hawaii Clean Energy Initiative, 2010).


Approvals needed: At the federal level, permits and reviews include: Environmental Impact Statement,
Environmental Assessment, administered by the Council on Environmental Quality; Incidental Take
Statement, Incidental Take Permit, administered by the National Oceanic and Atmospheric
Administration; Incidental Take Statement, Incidental Take Permit, administered by the U.S. Fish &
Wildlife Service. At the state level, most environmental permits are administered by the Hawaii
Department of Health (DOH); however, depending on the project, other agencies may also issue permits.
All counties in Hawaii require a Shoreline Setback Variance for structures and activities in the Shoreline
Area; counties have their own guidelines for determining the required setback from shore. A Special
Management Area Permit is also required. A utility permit, administered by the Public Utilities
Commission (PUC), is required for all utility construction, reconstruction, or maintenance activities in
Hawaii. (Hawaii Clean Energy Initiative, 2010).

Projects that qualify for the Renewable Energy Facility Siting Process (REFSP) can pursue a streamlined
permitting process. To obtain streamlined permitting, the developer will be charged a fee to cover
application processing costs.

Evaluation criteria: The most important determination is the impact of the project on the environment
and wildlife.

Public input: A public comment period and public hearing are part of the process at both the state and
federal levels.

Relationships to other important energy policies or siting and zoning decisions: Hawaii has a
renewable portfolio standard of 40% by 2030. In 2008, a Memorandum of Understanding between the
state of Hawaii and the U.S. Department of Energy established the Hawaii Clean Energy Initiative
(http://apps1.eere.energy.gov/news/pdfs/hawaii_mou.pdf). Goals of this initiative include a significant
increase in the use of renewable energy and a transition to the exclusive use of renewable energy on
Hawaiis smaller islands. (Database of State Incentives for Renewables & Efficiency, 2011).

Contacts:

Malama Minn, Wind Energy Specialist
Hawaii State Energy Office
(808) 587-3809
malama.c.minn@dbedt.hawaii.gov

Paul Conry, Administrator
Division of Forestry and Wildlife
Department of Land and Natural Resources
(808) 587-0166
Paul.J .Conry@hawaii.gov

A-25 Hawaii


Advanced H
2
0 Power. Hawaii Renewable Energy Siting Process [web page]. Retrieved 1 Nov 2011
from www.advancedh2opower.com/framework/Hydrokinetics%20Knowledge%20Base/Hawaii%
20Renewable%20Energy%20Facility%20Siting%20Process.aspx.

Database of State Incentives for Renewables & Efficiency. (1 J un 2011). Hawaii Incentives/Policies
for Renewables & Efficiency [web page]. Retrieved 1 Nov 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=HI06R&re=1&ee=1.

Hawaii Clean Energy Initiative. (20 Apr 2010). Federal and State Approvals for Wind.
www.hawaiicleanenergyinitiative.org/storage/wind_guidebook.pdf.

Hawaii Department of Business, Economic Development & Tourism, Wind [web page]. Retrieved 1
Nov 2011 from http://hawaii.gov/dbedt/info/energy/renewable/wind.


Idaho A-26

State: Idaho

Wind siting basics: Local-government siting autonomy, with state enabling legislation.

History of siting authority: Idaho Statute Chapter 65 - Local Land Use Planning (2005)
(http://lawjustia.com/codes/idaho/2005/67ftoc/670650002.html,
www.legislature.idaho.gov/idstat/Title67/T67CH65SECT67-6504.htm).

Approvals needed: Developers apply for local zoning approval, for a Conditional Use Permit. Since
there is local siting autonomy, only a city council or board of county commissioners can approve wind
energy projects (www.legislature.idaho.gov/idstat/Title67/T67CH64SECT67-6504.htm).




Contacts:

Sandy Cardon
Boise State Wind Working Group
sandycardon@boisestate.edu

J ohn Chatburn, Administrator
Idaho Office of Energy Resources
304 N. 8
th
Street, Ste. 250
Boise, ID
(208) 332-1660
john.chatburn@oer.idaho.gov


Boise State University. Wind Energy Research [web page]. Retrieved 10 J ul 2011 from
http://coen.boisestate.edu/windenergy/research/.

Idahoans for Responsible Wind Energy [web page]. Retrieved 10 J ul 2011 from
www.eastidahowindaction.org/relateddocs.html.

Idaho Office of Energy Resources. (8 Aug 2011). Resources for Wind Project Development in Idaho.
www.energy.idaho.gov/renewableenergy/wind_productdev.htm,
www.energy.idaho.gov/renewableenergy/wind.htm.

Data collected by Marley Ward, 10 J ul 2011.
Reviewed by John Chatburn 22 Nov 2011.
A-27 Illinois

State: Illinois

Wind siting basics: Local government has autonomy. Each county can set standards (55 ILCS 5/5-
12020). These standards include the device height and number of electricity-generating wind devices, or
wind turbine generators (WTGs)
(www.ilga.gov/legislation/ilcs/ilcs4.asp?DocName=005500050HArt.+5&ActID=750&ChapterID=12&Se
qStart=55300000&SeqEnd=120400000).

History of siting authority: Illinois General Assembly, in 55 ILCS 5/5-12020 (2007), granted authority
for counties to establish standards for wind farms and electric-generating wind devices. Amendments
were made in 2009 and 2010
(www.ilga.gov/legislation/ilcs/fulltext.asp?DocName=005500050K5-12020).

Approvals needed: County approves construction for projects in accordance with local zoning
regulations. In some situations, county must consult Illinois Department of Natural Resources for
approval (see Great Lakes Commission Staff, 2009, Siting and Permitting Wind Farms in Illinois).

Projects have to demonstrate compliance with these federal requirements:

(1) Federal Aviation Administration (FAA): (a) Determination of No Hazard to Air Navigation;
(b) Notice of proposed construction (form FAA 7460-1); (c) Lighting plan; (d) Post construction
form (form FAA 7460-2).
(2) US Fish and Wildlife Services (USFWS): Threatened and Endangered Species Act, Section 7
Consultation and Migratory Bird Act.
(3) US Army Corps of Engineers (COE): (a) Clean Water Act: Section 404 - Discharge of Fill
Materials; (b) Rivers and Harbors Act: Section 10.
(4) Federal Communications Commission (FCC): Microwave Studies.
(5) US Environmental Protection Agency (USEPA): Spill Prevention, Control and Countermeasures
Plan (SPCC Plan, 40 CFR112).
(6) U.S. Military: Determination of non-interference with flight operations and radar.
Obtain approval from municipality, National Pollutant Discharge Elimination System (NPDES) permit
from Illinois Environmental Protection Agency, and road permit from Department of Transportation
(Siting and Permitting Wind Farms in Illinois). At least one public hearing will take place not more than
30 days prior to a county boards siting decision (55 ILCS 5/5-12020).

Evaluation criteria: Standards are set at the county level.

According to the Illinois Endangered Species Act, the Illinois DNR must be consulted for approval if
proposed project would take place in an area where an endangered species or its habitat might be
disrupted.

Illinois Commerce Commission established interconnection standards (August 2008) for distributed
generation systems up to 10 MW (Great Lakes Commission, 2009)
(www.ilga.gov/commission/jcar/admincode/083/08300200sections.html).

Illinois A-28

Illinois has no model ordinance in place. However, a maximum setback limit for WTGs is established for
self-service power. According to (55 ILCS 5/5-12020), [A] county may not require a wind tower or other
renewable energy system that is used exclusively by an end user to be set back more than 1.1 times the
height of the renewable energy system from the end users property line.


Relationships to other important energy and siting and zoning decisions: None identified.

Contacts:

J olene S. Willis, Wind Energy Program Coordinator
Value-Added Sustainable Development Center
Illinois Institute for Rural Affairs
Western Illinois University
1 University Circle
Macomb, IL 61455-1390
(309) 298-2835
www.iira.org
J S-Willis@wiu.edu


Great Lakes Commission. (Mar 2009). Siting and Permitting Wind Farms in Illinois.
http://wiki.glin.net/download/attachments/950461/Illinois.doc.

Illinois Institute for Rural Affairs. Illinois Wind: Zoning [web page]. Retrieved 23 Aug 2011 from
www.illinoiswind.org/resources/zoning.asp.

Ronald S. Cope. (26 Sep 2008). Municipal Wind Farms Zoning and Wind Energy.
www.uhlaw.com/files/Event/031f23de-0014-4f38-bbb1-77b38d731073/Presentation/EventAttach
ment/75b0a760-cf78-499e-9cd4-042f708aa5c1/IML%20Municipal%20Wind%20Farms%20Zoni
ng%20%26%20Wind%20Energy_Ronald%20S.%20Cope%2011.08.pdf.

Data collected by Marley Ward, 1 Jul 2011; Lauren Knapp, 17 Aug 2011.
Reviewed by J ennifer Hinman, Illinois Commerce Commission, 17 Aug 2011; J olene S. Willis, 23 Aug, 1 Sep 2011.
A-29 Indiana

State: Indiana

Wind siting basics: Indiana has no state-level regulations or guidelines for wind power development.
Wind power siting is administered at the local level of government. Siting and permitting requirements
vary according to location. (Stemler, 2007).

History of siting authority: Article 4. (24 Apr 2007). Electric Utilities 170 IAC 4-4.1-1
www.in.gov/legislative/iac/T01700/A00040.PDF.

Approvals needed:

A certificate of need, granted by the Indiana Utility Regulatory Commission, is required for
construction of a new power plant or for delivery of public utility service.
An National Pollutant Discharge Elimination System (NPDES) Permit is required for discharge
of stormwater runoff at construction sites having a size greater than one acre.
A permit from the Indiana Department of Natural Resources is required for excavation,
placement, modification, or repair of a permanent structure over, along, or lakeward of the
shoreline or water line of a freshwater lake. (Great Lakes Commission, 2009).
Any person who desires to erect, make, use, or maintain a structure, an obstruction, or an
excavation in or on the floodway first must obtain a Construction in a Floodway permit from the
Indiana Department of Natural Resources.

Evaluation criteria: All projects must comply with local and state laws governing electric generation and
transmission and environmental laws related to construction (Great Lakes Commission, 2010).


Relationships to other important energy policies or siting and zoning decisions: Indianas Clean
Energy Portfolio Standard establishes a voluntary goal of 10% clean energy by 2025 (Database of State
Incentives for Renewables & Efficiency, 2011).

Contacts:

Matt Buffington, Environmental Supervisor
DNR Division of Fish and Wildlife
(317) 233-4666
mbuffington@dnr.IN.gov

Patrick Flynn, Program Manager
Renewables and Vehicle Technologies
Indiana Office of Energy Development
pflynn@oed.in.gov


Database of Incentives for Renewables & Efficiency. (5 May 2011). Indiana Incentives/Policies for
Renewables & Efficiency [web page]. Retrieved 2 Nov 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=IN12R&re=1&ee=1.

Great Lakes Commission. (Mar 2009). Siting and Permitting Wind Farms in Indiana.
http://wiki.glin.net/download/attachments/950461/Indiana.doc.

Indiana A-30

Great Lakes Commission. (J an 2010). State and Provincial Land-Based Wind Farm Siting Policy in
the Great Lakes Region: Summary and Analysis.
www.glc.org/energy/wind/pdf/GLWC-LandBasedSiting-J an2010.pdf.

Reviewed by Matt Buffington, 9 Nov 2011.
A-31 Iowa

State: Iowa

Wind siting basics:

Local government only: facilities with <25 MW capacity
Dual state and local siting: >25 MW capacity
State utilities board has authority at the state level.

History of siting authority: Iowa Code chapter 476A (1977) established generation-siting law. In 2001,
the decision criteria for issuance of generation certification were revised. The Iowa Utilities Board can
now waive certification requirements for any size facility. (www.legis.state.ia.us/IACODE/2003/476A/)

Approvals needed: A permit from the Iowa Utilities Board is required for larger facilities; otherwise,
local zoning and siting regulations apply; Iowa Code 476A and Iowa Administrative Code Chapter 24
(www.legis.state.ia.us/IACODE/2003/476A/).

Cases are presented to the Iowa Utilities Board to apply for a Construction Approval Waiver; Iowa code
476A and Administrative Code Chapter 24 (199-24.15)
(www.legis.state.ia.us/IACODE/2003/476A/15.html). The IUB has waived the plant certification process
for several projects that would have otherwise required a full certificate proceeding.

Evaluation criteria:

a. consistent with the legislative intent and the economic development policy of the state, and
will not be detrimental to the provision of adequate and reliable electric serviceinclude[ing]
whether the existing transmission network has the capability to reliably support the proposed
additional generation
b. Whether the construction, maintenance, and operationwill be consistent with reasonable land
use and environmental policiesconsidering available technology and the economics of available
alternatives. Such determination shall include:
(1) Whether all adverse impacts attendant the construction, maintenance and operation of the
facility have been reduced to a reasonably acceptable level;
(2) Whether the proposed site represents a reasonable choice among available alternatives;
(3) Whether the proposed facility complies with applicable city, county or airport zoning
requirements.
c. Whether the applicant is willing to construct, maintain, and operate the facility pursuant to the
provisions of the certificate and the Act.
d. Whether the proposed facility meets the permit and licensing requirements of regulatory agencies.
e. The applicant shall use the applicable provisions in the publications listed below as standards of
accepted good practice unless otherwise ordered by the board:

I. Iowa Electrical Safety Code...
II. National Electrical Code...
III. Power Piping-ANSI standard B31.1-2004.

(Iowa Code 476A, www.legis.state.ia.us/IACODE/2003/476A/12.html)

Public input: Intervenors are allowed to participate in proceedings. Office of Consumer Advocate
generally represents residential customers. An informational meeting and hearing (if the case has
contested issues) must be held in the county where the facility is proposed to be built.

Iowa A-32

Relationships to other important energy and siting/zoning decisions: Generally, a generation
certificate is issued contingent upon the applicant receiving appropriate approvals and permits from other
state and local zoning authorities.

Contacts:

Parveen Baig, Utilities Regulation Engineer
Iowa Utilities Board
1375 E. Court Avenue
Des Moines, IA 50319
(515) 725-7343
www.state.ia.us/iub
parveen.baig @iub.iowa.gov


Iowa Alliance for Wind Innovation and Novel Development [web page]. Retrieved 29 J un 2011 from
www.iawind.org.

Iowa Department of Natural Resources, Wind and Wildlife [web page]. Retrieved 19 Oct 2011 from
www.iowadnr.gov/Environment/WildlifeStewardship/NonGameWildlife/Conservation/Windand
Wildlife.aspx.

Iowa Energy Center, Wind Assessment Study and Calculator [web page]. Retrieved 19 Oct 2011 from
www.energy.iastate.edu/renewable/wind/windstudy-index.htm.

Iowa Utilities Board, Wind-powered Electricity Generation in Iowa [web page]. Retrieved 19 Oct
2011 from www.state.ia.us/government/com/util/energy/wind_generation.html.

Iowa Wind Energy Association [web page]. Retrieved 29 J un 2011 from www.iowawindenergy.org/.

J ohn R. Sweet Company. (2001). Top of Iowa Wind Farm Case Study.
http://johnrsweet.com/personal/wind/PDF/TopofIowaWindFarm.pdf.

Data gathered by Marley Ward, 29 J une 2011.
Reviewed by Parveen Baig, 5 Dec 2011.
A-33 Kansas

State: Kansas

Wind siting basics: Local siting autonomy (State Enabling Legislation).

History of siting authority: Kansas Statutes Annotated 12-573
http://kansasstatutes.lesterama.org/Chapter_12/Article_7/12-741.html

Approvals needed: Approval rests with the citys governing body and county commissioners.
http://kansasstatutes.lesterama.org/Chapter_12/Article_7/12-753.html

The now-defunct Kansas Energy Council compiled a wind energy siting handbook with suggested
procedures that counties might use for accepting applications for wind projects. See
http://kec.kansas.gov/reports/wind_siting_handbook.pdf.

KEC suggests an application process including at least the following:
-site plan
-visual impact assessment
-environmental assessment
-economic assessment
-decommissioning and reclamation plan

Evaluation Criteria: Guidelines established by the Kansas Department of Wildlife, Parks and Tourism
(Available from http://kdwpt.state.ks.us/news/Services/Environmental-Reviews/Wind-Power-and-
Wildlife-Issues-in-Kansas, search for wind power position.) for consideration by local governments
when making siting decisions about wind energy projects include:

(1) That wind power facilities should be sited on previously altered landscapes, such as areas of
extensive cultivation or urban and industrial development, and away from extensive areas of
intact native prairie, important wildlife migration corridors, and migration staging areas.
(2) To recommend adherence to the Siting Guidelines for Wind Power Projects in Kansas, produced
by the Kansas Renewable Energy Working Group
(www.kansasenergy.org/documents/KREWGSitingGuidelines.pdf).
(3) To support the study of and establishment of standards for adequate inventory of plant and animal
communities before wind development sites are selected, during construction, and after
development is completed (Manes et al., in review). The resultant improvement in available
knowledge of wind power and wildlife interactions obtained through research and monitoring
should be used to periodically update guidelines regarding the siting of wind power facilities.
(4) That mitigation is appropriate only if significant ecological harm from wind power facilities
cannot be adequately addressed through proper siting.
(5) To support the establishment of processes to ensure a comprehensive and consistent method in
addressing proposed wind power developments.
(6) To advocate the direct coupling of energy conservation and efficiency programs with any new
measures aimed at increasing energy supply whether renewable or conventional.

Additionally, voluntary guidelines offered by the Kansas Energy Councils Wind Siting Handbook
(http://kec.kansas.gov/reports/wind_siting_handbook.pdf) include:

Pre-construction survey recommendations: Requiring environmental assessment in siting decisions;
consideration for the biological setting; use of biological and environmental experts; careful review if
legally protected wildlife. Land use regulation is solely under the purview of local governments.

Kansas A-34

Design/Operation Recommendations: Perches should not be allowed on nacelles; tower design should
not provide perches for avian predators; awareness of the potential for adverse effects of turbine
warning lights on migrating birds.

Site Development Recommendations: Development in large, intact areas of native vegetation is
discouraged; power lines should be buried if possible; turbines should not interfere with important
wildlife or livestock movement corridors and staging areas.

Consultation with wildlife agency, USFWS: Contact with appropriate resource management agencies
early in the planning process.

Mitigation requirements: Mitigation for habitat loss when significant ecological damage in the siting
of a wind power facility cannot be avoided.

Decommissioning recommendations: Plans for future site decommissioning and restoration, including
circumstances under which decommissioning and reclamation may occur and the expected end of the
project life.


Relationships to other important energy and siting/zoning decisions: None identified.

Contacts:

Eric J ohnson
Kansas Department of Wildlife, Parks and Tourism
eric.johnson@ksoutdoors.com


Association of Fish and Wildlife Agencies. (n.d.). Kansas. www.fishwildlife.org/files/Kansas.pdf.

Environmental Law Institute. (May 2011). State Enabling Legislation for Commercial-Scale Wind
Power and the Local Government Role. www.elistore.org/reports_detail.asp?ID=11410.

Kansas Energy Council. (Apr 2005). Wind Energy Siting Handbook: Guideline Options for Kansas
Cities and Counties. http://kec.kansas.gov/reports/wind_siting_handbook.pdf.

Data gathered by Marley Ward, 11 Jul 2011.
Reviewed by Eric J ohnson, 10 Nov 2011, Andy Fry, 25 J an 2012.
A-35 Kentucky

State: Kentucky

Wind siting basics: Kentuckys wind energy potential is considered small. No precedent has been
established for the siting and zoning of wind developments. The Kentucky State Board on Electric
Generation and Transmission Siting (Siting Board) or the Public Service Commission would have
authority over major wind developments. (www.fishwildlife.org/files/Kentucky.pdf.).

According to the Kentucky Integrated Resource Plan, most of the state has Class 2 (out of 7) wind speeds,
making wind power generation economically impractical using currently available technology. A 2011
study by the Department of Economics at Western Kentucky University, entitled Wind Energy Feasibility
in Kentucky, found that the wind resource in one major region of Kentucky (featuring Cumberland
County) can produce affordable electricity. Statewide siting and zoning regulations could be developed as
a result of this study. (www.wku.edu/jaep/html/documents/J AEPVol2708.pdf)


Approvals needed: Siting Board approval is required for merchant plants with a generating capacity of
10 MW or more. For obtaining local government approval, local zoning board rules apply.



Relationships to other important energy policies or siting and zoning: None identified.

Contacts:

Kate Shanks
Division of Renewable Energy
500 Mero Street, 6th Floor, Capital Plaza Tower
Frankfort, KY 40601
(502) 564-7192
Kate.Shanks@ky.gov


Kentucky Economic Association. (2011). Wind Energy Feasibility in Kentucky, Journal of Applied
Economics and Policy, v30, pp. 1-4.
http://kentuckyeconomicassociation.org/jaep/issues/J AEPVol30(1)2011.pdf.

Kentucky Utilities Company. (Mar 2011). Analysis of Supply-side Technology Alternatives.
www.lrc.ky.gov/kar/807/005/058.htm.


Data gathered by Kai Goldynia, 2 August 2011.
Reviewed by Kate Shanks, 24 Oct 2011.
State Wind Sitng and Zoning Survey
Louisiana A-36

State: Louisiana

Wind siting basics: Louisiana has no specific siting authority for wind.






Contacts:

Bryan Crouch
Technology Assessment/Energy Office
Louisiana Department of Natural Resources
J ohn.Crouch@LA.GOV

Michael Seymour, Ornithologist & Scientific Collecting Permits Coordinator
Louisiana Department of Wildlife & Fisheries
Louisiana Natural Heritage Program
2000 Quail Drive, Room 429
P.O. Box 98000
Baton Rouge, LA 70898-9000
(225) 763-3554
mseymour@wlf.louisiana.gov


Database of State Incentives for Renewables & Efficiency. Louisiana Incentives/Policies for
www.dsireusa.org/incentives/index.cfm?getRE=1?re=undefined&ee=1&spv=0&st=0&srp=1&state=A.


Reviewed by Beau Gregory, 9 Dec 2011.
A-37 Maine

State: Maine

Wind siting basics: In 2008, Maine implemented PL 2007 Ch 661, amending the Maine Wind Energy
Act to provide for expedited siting and establish specific concerns regarding visual impact and
community benefits (www.mainelegislature.org/legis/bills/bills_123rd/billtexts/SP090801.asp).

For projects located within the expedited permitting area for wind energy development:

All of the organized areas of Maine are designated for expedited permitting. If a project is wholly
located within organized areas, then the Maine Department of Environmental Protection (DEP) is
the permitting authority at the state level. The municipality may also require a permit.
If a project is wholly located within theunorganized areas of the state, then the Maine Land Use
Regulation Commission (LURC) is the permitting authority at both the state and municipal levels.
If a project is located within the expedited permitting area for wind energy development and is
partially located within the organized areas of the state and partially located within the
unorganized areas, then DEP may choose to be the permitting authority or may opt to review only
the portion of the project located in the organized areas. In this case, LURC would review the
portion in the unorganized areas.
2

For projects not located in the expedited permitting area of the state, LURC is the permitting authority. In
this case, a rezoning would be required first, followed by a development permit.

History of siting authority: Maine Wind Energy Act of 2003
(www.mainelegislature.org/legis/statutes/35-A/title35-Asec3402.html). The Maine Wind Energy Act
includes a state goal of 3,000 MW of wind capacity by 2020.

In 2008 Maine implemented SP 980, which amended the Maine Wind Energy Act to provide for
expedited siting and establish specific concerns about visual impact and benefits to the community
(www.mainelegislature.org/legis/bills/bills_123rd/billtexts/SP090801.asp).

Approvals needed: Depending on the site plans and location, approvals may be needed from:
Independent [Transmission] System Operator for New England (ISO-NE), Maine Department of
Environmental Protection (DEP), Maine Public Utilities Commission (PUC) (for installations
interconnecting at >100kV), the Natural Resources Council of Maine (NRCM), and the U.S. Army Corps
of Engineers (COE). The Maine Department of Inland Fisheries and Wildlife (IFW) is a reviewer of
permit applications for DEP and LURC.

Basic procedures:

1. Pre-application meeting(s) with the applicant and the relevant agencies DEP and/or LURC,
IFW, US Army Corps of Engineers, and others as needed to discuss processing
2. Submit application
3. Permitting authority conducts review to determine whether application is complete for
processing
4. Public meetings or hearing

2
Unorganized areas are those having no local, incorporated municipal government; government is shared
by various state agencies and county government. Organized areas are those having a local government
that is incorporated.

Maine A-38

5. Deliberation and decision
6. Appeals, if any
7. Begin construction

For more information on the LURC process:
www.maine.gov/tools/whatsnew/index.php?topic=lurcfiles&id=2642&v=tplfiles

The DEP procedure is outlined in Maines Site Location Law:
www.maine.gov/dep/land/sitelaw/index.html


The Maine Wind Energy Act, section 9, provides:
- Applicants are required to submit visual impact assessments if the project is within three
miles of scenic resources. Scenic resources are defined in the Act.
- The project must result in tangible benefits to the host community.

DEP criteria (www.maine.gov/dep/land/sitelaw/index.html):
No adverse effect on the natural environment standard of the Site Location Law
(www.maine.gov/dep/land/sitelaw/index.html#rule)
No unreasonable adverse effect on air quality
No unreasonable alterations of climate
No unreasonable alterations of natural drainage ways
No unreasonable effects on runoff/infiltration relationships
No adverse effects on surface water quality
No unreasonable adverse effects on ground water quality or quantity
Sound-level limits
Preservation of historic sites
Preservation of natural areas
No unreasonable effect on scenic character
Protection of wildlife and fisheries

LURC criteria:
Effect on scenic character and related existing uses related to scenic character
Tangible benefits
Public safety-related setbacks

Smaller-scale developments (Other than utility scale)
(www.mainelegislature.org/legis/bills/bills_123rd/billtexts/SP090801.asp):
Projects must meet noise control requirements
Projects must be designed and sited to avoid unreasonable adverse shadow flicker effects
Setbacks must be adequate to protect public safety

Public input: Applicants, petitioners, and other interested persons may request a public hearing. Hearings
may be continued and reconvened as circumstances require.

Relationships to other important energy and siting/zoning decisions: None identified.

Pending issues: Many towns in Maine have already drafted or are in the process of drafting wind-specific
ordinances.

A-39 Maine

Contacts:

Maine Department of Environmental Protection
17 State House Station
Augusta, Maine 04333-0017
(207) 287-7688
(800) 452-1942
www.maine.gov/dep/contact/index.html

Maine Land Use Regulation Commission
22 State House Station
Augusta, Maine 04333-0022
(207) 287-2631
www.maine.gov/doc/lurc/


Land Use Regulation Commission. (Apr 2004). Approval Process for Energy Generation and
Transmission Projects.
www.maine.gov/tools/whatsnew/index.php?topic=lurcfiles&id=2642&v=tplfiles.

Maine State Planning Office. (7 Aug 2009). Municipal Model Wind Energy Facility Ordinance.
http://maine.gov/spo/landuse/docs/ModelWindEnergyFacilityOrdinance.pdf.

Maine State Planning Office. (n.d.). Municipal Role in Wind Power Regulation.
www.maine.gov/doc/mfs/windpower/pubs/pdf/wind_local_reg.pdf.

Data gathered by Lauren Teixeira. J une 23, 2011.
Reviewed by Marcia Famous Spencer, 27 Dec 2011.
Maryland A-40

State: Maryland

Wind siting basics: For any electric generator 70 MW or greater, including wind-based generation, the
Maryland Public Service Law requires the Maryland Public Service Commission (Commission) to issue a
Certificate of Public Convenience and Necessity (CPCN) that authorizes the construction and operation of
the facility. (PUC 7-207 and 208 (http://law.justia.com/codes/maryland/2005/gpu/7-207.html,
http://law.justia.com/codes/maryland/2005/gpu/7-208.html and www.fishwildlife.org/files/Maryland.pdf.)

History of siting authority: The current state siting law was enacted by Chapter 31 of the Laws of 1971.
In 2001, by Chapter 655, the General Assembly began to exempt certain types of generation from the
CPCN process if the facility does not exceed 70 MW and meets certain specified criteria. The exemption
provision is codified in PUC Article 7-207.1 (2005) (http://law.justia.com/codes/maryland/2005/gpu/7-
207.1.html). In 2007, the General Assembly enacted Chapter 163 which allows land-based wind
generation facilities to seek an exemption from the CPCN process if the facility will not exceed 70 MW.
(PUC 7-207.1 and CPCN Exemptions: FAQ at http://webapp.psc.state.md.us/, and
http://esm.versar.com/pprp/ceir15/Report_1_1_2.htm).

Approvals needed: For any generation facility over 70 MW, a developer must obtain a CPCN from the
Maryland Public Service Commission. See PUC 7-207 and 208
(http://law.justia.com/codes/maryland/2005/gpu/7-207.html,
http://law.justia.com/codes/maryland/2005/gpu/7-208.html).

To initiate the process, a developer must file an application with the Commission that contains descriptive
information as to ownership, interconnection, and specified environmental and socioeconomic
information. Depending upon the type of generation being proposed as well as the location, the type of
information and impact analysis required will vary. The necessary contents of the application and
supporting information may be found in Chapter 79 of Title 20 of the Code of Maryland Regulations
(COMAR) (www.dsd.state.md.us/comar/subtitle_chapters/20_Chapters.aspx#Subtitle79). For facilities
applying for an exemption, the requirements are specified in COMAR 20.79.01.03
(www.dsd.state.md.us/comar/SubtitleSearch.aspx?search=20.79.01.*). Certain basic information, such as
ownership, a facility description and location, and interconnection information, is required in either case.

For facilities required to obtain a CPCN, the Power Plant Research Program (PPRP) of the Maryland
Department of Natural Resources (DNR) coordinates the state agency review and environmental
evaluation. DNR is one of seven state agencies that review and comment on every application for a
CPCN. The agencies include the Maryland Departments of Natural Resources, Environment, Agriculture,
Business & Economic Development, Transportation, and Planning and Maryland Energy Administration.
Once the review is completed, PPRP consolidates the findings of these agencies and represents them
along with the states recommended licensing conditions to the Commission as part of the Commissions
hearing process. All facilities must be constructed and operated in compliance with state and federal
requirements (www.dnr.state.md.us/bay/pprp/pp_brochure.html).

Regardless of whether a developer applies for a CPCN or for an exemption, the process begins with an
application to the Commission. If a facility requires a CPCN, the Commission will usually delegate the
application to the Commissions Hearing Office for assignment to a Public Utility Law J udge. The Law
J udge sets a prehearing conference to establish a process for completing the application and developing a
record to support the Commissions ultimate decision whether to grant the CPCN or not. The CPCN
process will involve adjudicatory and public hearings. The time for completing the process depends upon
the complexity of the proposed facility, the extent of environmental and socio-economic impacts, and
public input positive or negative. The process can take several months to a year or more. State law
requires that the application be filed two years before construction is to commence, but this requirement
may be, and usually is, waived upon request. If the facility is requesting an exemption, the Commission

A-41 Maryland

may consider the matter itself without assigning it to the Hearing Division, or it may delegate the matter
to a Law J udge. The Law J udge will establish a public hearing process and ensure that the applicant meets
the requirements for an exemption. The implementing regulations are set 90 days from the date of
application for a decision unless otherwise directed by the Commission. COMAR 20.79.01.03
(www.dsd.state.md.us/comar/SubtitleSearch.aspx?search=20.79.01.*). In exemption proceedings, there
are no compliance requirements imposed by the Commission itself beyond a requirement to ensure
electrical safety and reliability. The Commission is required to hold at least one public hearing and may
issue an exemption if it finds that it is in the public interest to do so. There may be local zoning
requirements and state and local environmental compliance requirements outside of the CPCN process
itself, such as stormwater management, non-tidal wetlands, and sediment control.

Evaluation criteria: The state of Maryland has drafted guidelines for wind power siting; however, these
guidelines have yet to be implemented. Criteria in the draft guidelines include:

(1) Assess species of concern
(2) Minimize seasonal disturbance during construction
(3) Avian and bat breeding seasons
(4) Lighting issues

Public input: Both the PSC CPCN process and the related process for exempting qualifying generators
include public input procedures.

Relationships to other important energy policies or siting and zoning decisions: The Maryland
Renewable Energy Standard (20% by 2022) includes wind as an eligible technology.

In 2003, two commercial wind projects (one for 100 MW and one for 40 MW) each went through a
licensing process and obtained a CPCN to construct and operate wind generation facilities in Garret
County, Maryland. A third facility proposing to build another 40-50 MW also received a CPCN to
construct a facility in Garrett County but with limitations placed on the siting of its wind turbines. Since
then, all proposed commercial wind developments to date have been smaller than 70 MW.

Pending issues: The major issues are implementing the draft siting process guidelines and establishing
procedures for siting offshore wind developments.

Research issues: Bird and bat activity studies in western Maryland, bat activity in the Mid-Atlantic Bight
(a coastal region spanning from Cape Cod, Massachusetts to Cape Hatteras, North Carolina), bat
migration and population size studies, benthic habitat studies in the Maryland Wind Energy Area,
assessments of the wind resource offshore of Maryland, techniques for optimizing turbine array layouts.
Contacts:

Gwen Brewer, Science Program Manager
MD Department of Natural Resources
(410) 260-8558
gbrewer@dnr.state.md.us

Andrew Gohn, Senior Clean Energy Program Manager
MD Energy Administration
(410) 260-7190
agohn@energy.state.md.us

Maryland A-42


Database of State Incentives for Renewables & Efficiency. (J un 2011). Maryland Incentives/Policies
for Renewables & Efficiency [web page]. Retrieved 4 Aug 2011 from
www.dsireusa.org/incentives/index.cfm?getRE=1?re=undefined&ee=1&spv=0&st=0&srp=1&state=MD.
Maryland Energy Administration. (22 Nov 2010). Maryland County Wind Ordinances.
http://energy.md.gov/countyOrdinance.html.

States. U.S. Fish & Wildlife Service. www.fishwildlife.org/files/Maryland.pdf.

Data collected by Kai Goldynia, 4 Aug 2011.
Reviewed by Andrew Gohn, 17 Nov 2011.
A-43 Massachusetts

State: Massachusetts

Wind siting basics: The Energy Facilities Siting Board is the siting authority for facilities with capacities
of 100 MW or larger. At this level there is a one-stop permitting process. Siting of <100 MW facilities
is subject to municipal or regional permitting. No on-shore wind facilities over 100 MW have been
proposed or built in Massachusetts.

History of siting authority: The authority of the Massachusetts Siting Board over energy facilities with
>100 MW of capacity is established by Massachusetts General Law Chapter 164, Section 69H
(www.malegislature.gov/Laws/GeneralLaws/PartI/TitleXXII/Chapter164/Section69H)

Approvals needed: On the federal level, the applicant usually needs the approval of the Environmental
Protection Agency (EPA), Fish and Wildlife Agency, and the Federal Aviation Administration (FAA).
On the state level, permits are generally required under the Massachusetts Environmental Policy Act
(MEPA) and the Massachusetts Natural Heritage Program (MNHP). The Department of Environmental
Protection (DEP) and the Endangered Species program could also regulate the project.

Since permitting in Massachusetts occurs on a local level, the procedure will vary according to the local
bylaw or ordinance. Most procedures involve conducting a pre-construction survey, submitting the
application, holding a public hearing, opportunity for appeals, and then a final approval granted (or denial
issued) by the permitting authority.

The siting and permitting process for wind projects in Massachusetts can take an exceptionally long time.
Under the Massachusetts citizen suit statute citizens can appeal any state or local approved permit
(Chapter 21E, Section 15
www.malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter21E/Section15). This law allows a group
of 10 or more citizens to challenge a permit. Some municipalities have recently adopted as-of-right
zoning in designated locations, which allows wind projects in the designated zones to proceed without a
special permit (Department of Energy Resources, 2011).


The Massachusetts Department of Energy Resources has developed two model by-laws/ordinances, one
for siting projects subject to a special permit and another that allows projects to be sited without a special
permit in designated locations. Generally, these bylaws include standards that address:

Design Standards, including height.
Safety and Environmental Standards, including Setbacks, Shadow/Flicker, and Sound - must comply
with DEP noise regulations (www.airandnoise.com/MA310CMR710.html)
Monitoring and Maintenance
Abandonment or Decommissioning



Pending issues: The Wind Energy Siting Reform Act (S. 1666 Finegold, H. 1775 Smizik, and
others
3
), currently before the J oint Committee on Telecommunications, Utilities and Energy, would:

3
S. 1666 is the language of the conference report that made it to enactment stage in 2009-2010 session.
H. 1775 is the House counterpart.
Massachusetts A-44

Mandate that the Siting Board establish clear and predictable state siting standards for wind
facilities; the standards must be as protective as existing state laws.

Ensure municipalities would still establish and apply their own local standards.

Provide for one-stop permitting at the local level and one stop at the state level for wind projects
over 2 MW.

Maintain home rule. (A municipality is free to reject any wind project, and the Siting Board has
no authority to override that decision. Instead, the proponents only remedy is to go to court the
same remedy as at present.)

Provide for appeals. (If a municipality approves a wind project, opponents would appeal to the
Siting Board. Appeal of a Siting Board ruling would go directly to the State Supreme J udicial
Court. )

Decrease the permitting process from eight years to 18 months, with an additional year if there is
a judicial appeal.
Contacts:

Bram Claeys
Massachusetts Department of Energy Resources
100 Cambridge Street Suite 1020
Boston, MA 02114
(617)626-7874
Bram.claeys@state.ma.us

J ody Lally, Program Manager
Wind Energy Center
University of Massachusetts
(413) 577-0887
lally@ecs.umass.edu


Daley, Beth. (11 J ul 2011). Wampanoag tribe sues over sues over Cape Wind, Boston Globe.
http://articles.boston.com/2011-07-11/lifestyle/29761941_1_cape-wind-wind-farm-horseshoe-shoal.

Department of Energy Resources, Massachusetts Executive Office of Environmental Affairs. (J un
2011). Model As-of-Right Zoning Ordinance or By-law: Allowing Use of Wind Energy Facilities
or By-laws
www.mass.gov/eea/docs/doer/gca/as-of-right-wind-bylaw-june-2011.pdf.

_______. (1 Jan 2007). Developing wind power projects in Massachusetts: Anticipating and
avoiding litigation in the quest to harness wind. Suffolk Journal of Trial and Appellate
Advocacy.
www.thefreelibrary.com/Developing+wind+power+projects+in+Massachusetts%3a+anticipating
+and+...-a0172525557.

A-45 Massachusetts


Massachusetts Department of Energy Resources. Massachusetts Wind Energy Siting Reform.
www.mass.gov/?pageID=eoeeaterminal&L=4&L0=Home&L1=Energy%2c+Utilities+%26+Clea
n+Technologies&L2=Renewable+Energy&L3=Wind&sid=Eoeea&b=terminalcontent&f=doer_re
newables_wind_siting-reform&csid=Eoeea.

Massachusetts Department of Energy Resources. (J un 2011). Model Amendment to a Zoning
Ordinance or By-Law: Allowing Conditional Use of Wind Energy Facilities.
www.mass.gov/eea/energy-utilities-clean-tech/renewable-energy/wind/wind-energy-model-zoning-by-law.html.

State of Massachusetts. Massachusetts Energy Facilities Siting Board [web page]. Retrieved
13 J ul 2011 from www.mass.gov/eea/energy-utilities-clean-tech/energy-facilities-siting-board/.


Reviewed by Meg Lusardi, 12 Dec 2011.
Michigan A-46

State: Michigan

Wind siting basics: Michigan is a home-rule state. Local townships, villages, cities, and counties are
responsible for wind siting and zoning. The state government has responsibility for identifying one or
more Wind Energy Resource Zones, where transmission construction will be facilitated (see
www.michigan.gov/windboard and http://www.michigan.gov/mpsc/0,1607,7-159-16393_52375---
,00.html).


Approvals needed: No state permit process exists for construction of wind farms. Local land use and
zoning regulations apply.

All construction projects can trigger the need for permits:

(1) Soil Erosion and Sedimentation Control obtained from the appointed county or municipal
enforcing agency
(2) National Pollutant Discharge Elimination System (NPDES) Construction activities of 1 acre or
more with a point-source discharge to waters of the state are required to submit a Notice of
Coverage (NOC) to obtain coverage under Permit by Rule from the Michigan Department of
Environmental Quality.
(3) Shoreline Construction from the State of Michigan Department of Environmental Quality
(4) Wetland Construction from the State of Michigan Department of Environmental Quality
(5) Sand Dune Construction from the State of Michigan Department of Environmental Quality

These processes are expected to take no more than a few months. A Soil Erosion and Sedimentation
Control permit is required for all construction projects. Other permits are required, depending on location.

In addition, developers apply to the local township(s) or municipalities, and sometimes county(ies), for
land-use permits (see http://expeng.anr.msu.edu/miwind/zoning_siting).

Like many other states, Michigan faces the challenge of implementing wind technology on the local,
community scale. If zoning exists in a city, village, township, or county with its own existing zoning, the
provisions adopted must be pursuant to the Michigan Zoning Enabling Act (2006 PA 110;
http://legislature.mi.gov/doc.aspx?mcl-Act-110-of-2006). Some Michigan townships rely on county
zoning, in which case the township must work with county planning commissions so that wind generator
provisions are included in the countys zoning ordinance pursuant to the Michigan Zoning Enabling Act.
Where zoning does not already exist, regardless of city, village, or township, it is not possible to adopt
regulations without first adopting zoning (Michigan Department of Labor and Economic Growth, 2008).

Evaluation criteria: Some local governments have passed wind energy ordinances. Common evaluation
criteria include:

(1) Property Setback
(2) Sound Pressure Level
(3) Safety
(4) Visual Impact
(5) Electromagnetic Interference


A-47 Michigan


The Wind Energy Resource Zone Board (WERZ Board) was created by the Michigan Public
Service Commission (MPSC) in Dec 2008 for the purpose of identifying regions in the state with
the greatest potential for harvest of wind energy. In its final report, the WERZ Board determined
two geographical zones with the highest estimated generating capacity.

In one of those zones, a transmission construction project has been approved to accommodate
future wind generation
(http://efile.mpsc.state.mi.us/efile/viewcase.php?casenum=16200&submit.x=21&submit.y=6,
www.midwestiso.org/Planning/TransmissionExpansionPlanning/Pages/TransmissionExpansionPlanning.aspx).
The Michigan Public Service Commission granted an expedited siting certificate to ITC
Transmission for construction of a transmission line and four substations in Michigans Thumb
region, considered the states highest wind energy resource zone. Appeals to this decision were
filed by the Association of Businesses Advocating Tariff Equity (ABATE) and the Michigan
Public Power Agency (MPPA) and Michigan Municipal Electrical Association (MMEA).

Contacts:

J ohn Sarver, Chairman,
Michigan Wind Working Group
(517) 290-8602
johnsarver3@gmail.com

J ulie Baldwin, Renewable Energy Section Manager
Michigan Public Service Commission
(517) 241-6115
Baldwinj2@michigan.gov


Bzdok, Christopher, and J ames Clift. (Oct 2009). "Michigan's Clean Energy Legislation,"
Environmental Law, Michigan Bar Journal. www.michbar.org/journal/pdf/pdf4article1576.pdf.

Great Lakes Commission. (Mar 2009). Siting and Permitting Wind Farms in Michigan.
http://wiki.glin.net/download/attachments/950461/Michigan.doc?version=3

Michigan Department of Energy, Labor and Economic Growth, Bureau of Energy Systems. (16 Apr
2008). Sample Zoning for Wind Energy Systems.
http://miwind.msue.msu.edu/uploads/files/michigan_department_of_energy_growth.pdf.

Michigan Economic Development Corporation, Energy Systems. Michigan Wind Working Group
[webpage]. Retrieved 9 Aug 2011 from
www.michigan.gov/mdcd/0,1607,7-122-25676_25774-75767--,00.html.

Michigan Public Service Commission. Wind [webpage]. Retrieved 9 Aug 2011 from
www.michigan.gov/mpsc/0,1607,7-159-16393_55246-136909--,00.html.

Michigan Public Service Commission, Wind Energy Resource Zones [web page]. Retrieved 19 Oct
2011 from www.michigan.gov/mpsc/0,4639,7-159-16393_52375---,00.html.

Michigan A-48

Phadke, Roopali. Understanding Wind Initiative.
www.macalester.edu/understandingwind/index.html.

U.S. Department of Energy. Wind Powering AmericaMichigan [web page]. Retrieved 28 J un 2011
from www.windpoweringamerica.gov/astate_template.asp?stateab=mi.

Data collected by Kai Goldynia, 28 J une 2011; Deborah Luyo, 19 Oct 2011.
Reviewed by J ulie Baldwin, 20 Oct 2011, J ohn Sarver, 20 Oct 2
A-49 Minnesota

State: Minnesota

Wind siting basics: In 2005, the Minnesota Legislature transferred to Minnesota Public Utilities
Commission (PUC or Commission) from the Minnesota Environmental Quality Board (MEQB) the
permitting authority for wind facilities greater than or equal to 5 MW in capacity (Minnesota statute,
Chapter 216F [Wind Energy Conversion Systems] (www.revisor.mn.gov/statutes/?id=216F). Siting
authority for facilities <5 MW is reserved for local jurisdictions.

Section 216F.08 allows counties to assume authority for permitting of facilities with capacities of up to
25 MW if they, as a minimum, adopt the Commissions General Permit Standards
(www.revisor.mn.gov/statutes/?id=216F.08).

History of siting authority: In 1995, the Minnesota legislature enacted legislation that excluded wind
energy facilities from the requirements of the Power Plant Siting Act, established a review process
specific to wind energy facilities and authorized the MEQB to adopt rules specific to large wind energy
conversion systems. (www.revisor.mn.gov/laws/?doctype=Chapter&year=1995&type=0&id=203).
Minnesota statute 216F.02 gives local governments authority over wind farms less than 5 MW:
www.revisor.mn.gov/statutes/?id=216f.02.

Approvals needed: The Commission, in making its determination on whether to issue a final site permit,
relies on standards, criteria, and factors in Minnesota Rules parts 7850.4000 and 7850.4100
(https://www.revisor.mn.gov/rules/?id=7850) and the record developed in the review process governed by
Minnesota Rules, Chapter 7854 (https://www.revisor.mn.gov/rules/?id=7854). Commission site permit
requirements address site designation, setbacks and site layout restriction, compliance procedures, surveys
and reporting, construction and operation practices, final as built documents, decommissioning,
restoration and abandonment, and special conditions as warranted. The Commissions website at
www.puc.state.mn.us/PUC/energyfacilities/siting-routing/index.html provides access to each project
docket, which contains the primary documents associated with a project, and eDockets, which contains all
of the documents associated with an individual project.

Other permits required for LWECS construction may also include:

Minnesota Public Utilities Commission

Certificate of Need (for facilities generating 50 MW or more).
www.puc.state.mn.us/portal/groups/public/documents/pdf_files/001075.pdf

Minnesota Department of Transportation

Utility Permit (Long Form) - www.dot.state.mn.us/utility/files/pdf/permits/long-form-complete.pdf

Utility Permit (Short Form) www.dot.state.mn.us/utility/files/pdf/permits/short-form-complete.pdf

Access Driveway Permit - www.dot.state.mn.us/utility/files/pdf/permits/access-form-complete.pdf

Oversize/Overweight Permits Page - www.dot.state.mn.us/cvo/oversize/forms_and_applications.html

County and Township Road permits

In Minnesota, it is common practice for wind developers and counties to enter into development
agreements that provide for designation of haul roads, assessment of road and infrastructure conditions
prior to construction, damages, restoration, and ditch requirements. The following link

Minnesota A-50

(www.lrrb.org/trafcalc.aspx) provides a downloadable interactive document that provides web links,
sample ordinances, reports, traffic calculators to quantify the traffic impact on roads, public policy
options to recapture roadway maintenance costs, experience from current projects, and research
information. This site will provide updates when available.

Tall Structure Permits

Wind energy conversion systems near airports may require a permit from the Minnesota Department of
Transportation. Additional information is available on the Department's Aeronautics and Aviation website.
Minnesota Pollution Control Agency
NPDES Permit www.pca.state.mn.us/index.php/water/water-types-and-
programs/stormwater/construction-stormwater/construction-stormwater.html?menuid=&redirect=1). This
may also include and/or satisfy the Soil Erosion and Sediment Control Plan.

Noise Standards. The project must comply with Minnesota Rules Chapter 7030
(www.revisor.leg.state.mn.us/rules/?id=7030) for setbacks from defined facilities.

Minnesota Department of Natural Resources

Permits to cross public lands and waters
(www.dnr.state.mn.us/waters/watermgmt_section/pwpermits/applications.html)

Native Prairie: turbines and associated facilities shall not be place in native prairie unless approved in a
native prairie protection plan (www.dnr.state.mn.us/prairierestoration).

Minnesota Board of Water and Soil Resources

Wetland Conservation Act (WCA) (www.bwsr.state.mn.us/wetlands/forms/form03_B.PDF)

Other PUC Site Permit and or Study Requirements

Archaeological Resource Survey and Consultation (through State Historic Preservation Office
(www.mnhs.org/shpo/).

Avian and Bat Protection Plan: Avian and Bat Assessments, Survey and Monitoring Requirements

Shadow Flicker Modeling, Analysis and Mapping

Noise Modeling, Analysis and Mapping and Post Construction Noise Surveys

Demonstrate Control of Wind Rights

Wind Access Buffer: Turbine towers must be placed a minimum of 5 rotor diameters (RD) from all
boundaries of site on the prevailing wind directions and 3 RD on the non-prevailing directions, unless
otherwise approved by the Commission.

Internal Turbine Spacing Requirements: Turbine towers must be placed a minimum of 5 rotor diameters
apart on the prevailing winds directions and a minimum of 3 RD on the non-prevailing winds within the
permitted site boundaries, unless otherwise approved by the Commission

Off-Air TV Analysis

A-51 Minnesota
AM and FM Radio Reports

Licensed Microwave Report

Land Mobile Report

Freestanding permanent MET Towers

For projects under the authority of the local jurisdiction, the applicant must obtain the appropriate land
use and zoning permits, depending on the ordinance.

Model ordinance: www.cleanenergyresourceteams.org/files/2005_model_wind_ordinance.pdf.

Public input: Commission rules include provisions for application distribution requirements, public
notice, public meetings, public hearings, and other procedural requirements
(https://www.revisor.mn.gov/rules/?id=7854).

The Commission makes a final decision within 180 days of the acceptance of the application. If the
project is approved, a permit is issued with any conditions the Commission considers necessary to protect
the environment, enhance sustainable development, and promote the efficient use of resources. Minn.
Rules 7854 | LWECS Permitting Flowchart.

Minnesota law provides for the creation of wind and solar easements for solar and wind-energy systems.
The Commissions site permit wind access buffer requirements protect the wind rights of both project
participants and non-participants (See Minn. Stat. 500.30).

Pending issues: Health effects and Avian and bat issues.

Research issues: Avian and bat issues.

Contacts:

Minnesota Department of Commerce
Energy Facility Permitting
85 7
th
Place East, Suite 500
St. Paul, MN 55101
(651) 297-2375 or 1-800-657-379
http://mn.gov/commerce/energy/utilities/Energy-Facility-Permits.jsp
www.energyfacilities.puc.state.mn.us/contact.html


Great Lakes Wind Commission. (Mar 2009). Siting and Permitting Wind Farms in Minnesota.
http://wiki.glin.net/download/attachments/950461/Minnesota.doc.

Minnesota Public Utilities Commission. Energy Facilities [web page].
www.puc.state.mn.us/PUC/energyfacilities/index.html.
Minnesota Statutes. (2011). Chapter 216F. Wind Energy Conversion Systems.
https://www.revisor.mn.gov/statutes/?id=216F.

Data collected by Marley Ward, 1 J uly 2011, Deborah Luyo 27 Oct 2011.
Reviewed by Tricia DeBleeckere, 22 Dec 2011, Larry Hartman 9 J an 2012.
Mississippi A-52

State: Mississippi

Wind siting basics: Mississippi has no specific siting authority for wind.






Contacts:

J ohnny Wilson, Staff Officer
Central District
Mississippi Public Service Commission
J ackson Office
501 West St
J ackson, MS 39201
(601) 961-5442
www.psc.state.ms.us/Commissioners/central/staff.html
johnny.wilson@psc.state.ms.us


Database of State Incentives for Renewables & Efficiency. Mississippi Incentives/Policies for
www.dsireusa.org/incentives/index.cfm?getRE=1?re=undefined&ee=1&spv=0&st=0&srp=1&sta
te=MS.


A-53 Missouri

State: Missouri

Wind siting basics: Local siting autonomy (Environmental Law Institute, 2011).


Approvals needed: There is no specific approval process; however, the Public Service Commission and
Department of Natural Resources can have input and provide oversight, depending on the location and
facilities planned. Otherwise, wind energy facilities are subject only to existing local government zoning
regulations (Association of Fish and Wildlife Agencies).

Local government grants permit for construction if project is in compliance with zoning laws.
(Association of Fish and Wildlife Agencies).




Contacts:

Doyle Brown
Policy Coordination Unit
Missouri Department of Conservation
(573) 522-4115 ext. 3355
doyle.brown@mdc.mo.gov

Michael Taylor
Missouri Public Service Commission
P.O. Box 360
J efferson City, MO 65102
(573) 526-5880
Michael.Taylor@psc.mo.gov
www.psc.mo.gov/


Association of Fish and Wildlife Agencies. Missouri. www.fishwildlife.org/files/Missouri.pdf.

Missouri Department of Natural Resources, Wind Energy Resources [web page]. Retrieved 20 Oct
2011 from www.dnr.mo.gov/energy/renewables/wind-energy.htm.

Data collected by Marley Ward, 1 Jul 2011.
Montana A-54

State Name: Montana

Wind siting basics: Wind power development on private land is generally not government regulated, but
under a statewide permit, persons disturbing more than one acre of land are required to file a Storm Water
Pollution Prevention Plan with the Montana Department of Environmental Quality. The Montana
Department of Environmental Quality can regulate projects impinging on wetlands, water quality, and the
like (www.fishwildlife.org/files/Montana.pdf). Each county controls zoning for commercial and industrial
development. The Montana Department of Natural Resources and Conservation must approve projects
on state owned land.


Approvals needed: No specific wind energy siting or zoning approvals are needed from state or local
agencies. If the project encroaches on wildlife, or impacts the human environment, environmental reviews
may be necessary.

Only projects requiring a state permit or approval are subject to review under the Montana Environmental
Policy Act (MEPA). If a wind project is determined to require MEPA review, an Environmental
Assessment (EA) and/or Environmental Impact Statement (EIS) is required. One of the functions of an
EA is to document whether there is potential for a significant impact. If there is a potential significant
impact, an EIS must be prepared by the permitting agency. An EIS details the purpose of the project,
describes the areas and resources affected, and reviews alternatives including the no action alternative and
possible measures to reduce adverse impacts. Public participation is discretionary during EA review, but
mandatory for EIS review.

Evaluation criteria: No specific criteria identified. Permits may be required from the Department of
Environmental Quality depending on circumstances involving:

(1) Electric Transmission
(2) Open-cut Mining
(3) Wastewater
(4) Water Quality

Public Input: Public participation is a vital tool during the Environmental Impact Statement review and
may be required during a state agency during preparation of an Environmental Assessment. The agency
must provide at least a 30-day period for comments on the draft EIS and must not make a decision for a
15-day period following publication of a final EIS. The 30-day comment period may be extended for up
to an additional 30 days unless the state agency is doing a joint review with a federal agency. In addition,
the state agency must inform the public of its decision and its justification for that decision.

Relationships to other important energy policies or siting and zoning decisions: Montanas RPS
requires that all public utilities obtain 15% of their electricity supply from qualified renewable energy
resources by 2015.

Contacts:

Tom Kaiserski
Montana Wind Working Group
(406) 841-2034
tkaiserski@mt.gov

A-55 Montana

Brian Spangler
Department of Environmental Quality
1520 East 6th Avenue
Helena, MT 59601-4541
(406) 841-5250
bspangler@mt.gov

T.O. Smith
Montana Fish, Wildlife & Parks
406-444-3889
tosmith@mt.gov

Citations and Links:

Association of Fish and Wildlife Agencies. Montana. www.fishwildlife.org/files/Montana.pdf.

Gaelectric. (13 Apr 2011). "Study confirms unique features of Montana wind in providing solutions
for Pacific NW power market." www.gaelectric.ie/news-detail.asp?nid=79&id=5.

Montana Wind Group [web page]. Retrieved 13 J ul 2011 from
http://montanawindgroup.org/index.html.

Montana Dept. of Environmental Quality. Wind Energy Permit Requirements [web page]. Retrieved
13 J ul 2011 from www.deq.mt.gov/energy/renewable/windweb/WindPermits.mcpx.

National Wind, Montana Wind Facts [web page]. Retrieved 13 J ul 2011 from
www.nationalwind.com/montana_wind_facts.

Data collected by Kai Goldynia, 12 J ul 2011.
Reviewed by Tom Kaiserski, 12 J an 2012, Tom Ring, 18 J an 2012.
Nebraska A-56

State: Nebraska

Wind siting basics: Nebraska is the only state where all electric power is publicly owned. As such, all
power is regulated by the legislature, a local utility, or the Nebraska Power Review Board (NPRB).

Under 80 MW: Applicants connecting to the electric grid must obtain a power purchase agreement with a
local utility and comply with local ordinances. Applicants must receive approval prior to construction
either from the Federal Energy Regulatory Commission using the PURPA certification process, or from
the NPRB. Customer generators (net metering) with a generator under 25 kilowatts rated capacity are
exempt from the NPRB approval requirement.

Over 80 MW: Applicants must obtain NPRB approval prior to construction. The approval criteria the
NPRB must use is set out in Neb. Rev. Stat. 70-1014 (1996) (www.nprb.state.ne.us/prbmanual/4.html).
A special generation application process is available under Neb. Rev. Stat. 70-1014.01(2) if filed by a
Nebraska utility for a renewable energy project and the total production from all such facilities does not
exceed 10 percent of the utilitys total energy sales. Approval of special generation applications is
allowed if the applicant conducts a public hearing on the proposed project.

Wind-for-export project: Private developers wishing to construct renewable generation facilities can file
an application using special NPRB approval criteria if at least 90 percent of the power will be exported
outside Nebraska. The developer must offer certain public power utilities 10 percent of the renewable-
generated electricity. The utilities can negotiate the utilities do not have to purchase 10 percent. This
process is set out in Neb. Rev. Stat. 70-1014.02.

The Nebraska Power Review Boards approval criteria in Neb. Rev. Stat. 70-1014 for generation and
transmission facilities are based on public convenience and necessity, cost-effectiveness, and feasibility,
as well as whether the proposed facility will duplicate existing facilities. The Board also determines issues
relating to territorial disputes between utilities and is the repository for all Nebraska electric power
suppliers certified service areas.

History of siting authority: The authority of the Nebraska Power Review Board is statutory law:
www.powerreview.nebraska.gov/powerlaws.htm

Terms for wind-for-export projects are defined in Section 70-1014.02, which was added in 2010.
http://uniweb.legislature.ne.gov/laws/laws-index/chap70-full.html

Community-Based (C-BED) legislation was added in 2007, Sections 70-1901 to 70-1907:
http://nebraskalegislature.gov/laws/laws-index/chap70-full.html

Approvals needed: Approval is also needed from: the Federal Aviation Administration, the Department
of Defense, and the Nebraska Game and Parks Commission. The developer must notify either the
Nebraska Game and Parks Commission or the U.S. Wildlife Agency. The project will receive a thumbs
up/thumbs down from federal and state wildlife agencies as a unit. The NPRB is required to consult with
the Nebraska Game and Parks Commission on all applications to ensure that approval will not cause harm
to threatened or endangered species or their critical habitat. The Game and Parks Commission will notify
the NPRB of its determination. The NPRB will also coordinate with the Nebraska Department of
Aeronautics, the State Historical Society and the Nebraska Commission on Indian Affairs.

Omaha Public Power District, the Municipal Energy Agency of Nebraska, and NPPD have all solicited
wind resources through requests for proposals (RFPs). NPPD expects to need 533MW of wind generation
in order to meet its goal of 10% renewables by 2020. The NPPD RFP process is as follows:

A-57 Nebraska

(1) The NPPD submits an RFP, specifying a capacity and general location for the facility.
Developers can propose projects on NPPD land or privately owned land.
(2) Developers submit their proposals during the RFP time period. (The second most recent RFP,
which closed 15 Apr 2009, yielded 22 proposals.)
(3) The NPPD evaluates the proposals and develops a short list.
(4) From this shortlist the NPPD Board of Directors must approve a power purchase agreement.

Evaluation criteria: Energy cost to NPPD, cost of transmission, developers experience, and
environmental impact.

Counties drafting ordinances usually consult the NPPD. Setback distances are recommended by the U.S.
Bureau of Land Management.


Relationships to other important energy policies or siting and zoning decisions: C-BED legislation
gives landowners first right to wind energy development and provides a sales and use tax exemption on
the gross receipts from the sale, lease, or rental of personal property for use in a C-BED project
(http://uniweb.legislature.ne.gov/laws/statutes.php?statute=s7727004057).

Contacts:

J erry Loos
Nebraska Energy Office
P.O. Box 95085
1111 O Street #223
Lincoln, NE 68509-5085
(402) 471-3356
www.neo.ne.gov/
J erry.Loos@nebraska.gov

David Ried, P.E., Division Manager
Energy Marketing & Trading
Omaha Public Power District
444 So 16th Street Mall, 10E/EP 1
Omaha, NE 68102-2247
(402) 514-1025
dried@oppd.com

Tim Texel
Executive Director and General Counsel
Nebraska Power Review Board
P.O. Box 94713
Lincoln, NE 68509
(402) 471-2301
tim.texel@nebraska.gov



Nebraska A-58

Stemler, J odi. (11 Apr 2007). Wind Power Siting Regulations and Wildlife Guidelines in the United

WOWT. NPPD Receives 18 Wind Energy Proposals, WOWT.com.
www.wowt.com/news/headlines/43127912.html?storySection=story.

Reviewed by Jerry Loos, 5 J an 2012; David Ried, 5 J an 2012; Tim Texel, 9 Jan 2012.
A-59 Nevada

State: Nevada

Wind siting basics: Wind siting is done at the local level. The Public Utilities Commission of Nevada
issues a permit for construction of renewable electric generating plants, including wind, with a nameplate
capacity of 70 MW or more.

History of siting authority: Utility Environmental Protection Act; Nevada Revised Statutes 704.820
through 704.900 (1971) (www.leg.state.nv.us/nrs/nrs-704.html). Nevada is a Dillons Rule state.

Approvals needed: Approval at the county level is needed. Applicants are required to file with the
Nevada PUC, including a summary of environmental impact and need. The applicant must also submit a
copy to the Division of Environmental Protection, Nevada Department of Conservation and Natural
Resources, and Nevada State Clearinghouse. Within 150 days, the PUC will grant or deny the
application.

Approximately 85% of Nevada land is federal property, where environmental studies are required by the
federal Bureau of Land Management. Such studies are thorough and usually take up to two years (for an
environmental assessment; EA) or three years (for an environmental impact statement; EIS).

Evaluation criteria: A community does not have authority to deny approval of a wind energy system if
the owner has written consent from all owners of properties within 300 feet of the system and meets all of
the local jurisdictions ordinances for wind energy systems if in effect (Database of State Incentives for
Renewables & Efficiency, Nevada Solar and Wind Easements & Rights Laws).


Relationships to other important energy policies or siting and zoning decisions: Nevadas most
recent renewable portfolio standard (RPS) mandates that 25% of energy must come from renewable
sources by 2025. Portfolio energy credits (PECs) are used to facilitate the buying and selling of
renewable energy to meet portfolio standards. One PEC is equal to one kilowatt-hour (kWh) produced
from a non-solar renewable source.

Contacts:

Larry Burton
Burton Consulting, LLC
(775) 852-1400
lburton@nvenergy.com

Thomas Clark
Nevada State Wind Working Group
(775) 325-3035
tclark@hollandhart.com

Tom Darin
Western Representative
American Wind Energy Association
(720) 244-3153
tdarin@awea.org

Nevada A-60

Mark Harris, PE
Public Utilities Commission of Nevada
Engineering Division
1150 E. William Stree
Carson City, NV 89701
(775) 684-6165
http://pucweb1.state.nv.us/PUCN/
mpharris@puc.nv.gov


Database of State Incentives for Renewables & Efficiency. (2 J un 2011). Nevada Incentives/Policies
for Renewables & Efficiency [web page]. Retrieved 6 J ul 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NV01R&re=1&ee=1.

Database of State Incentives for Renewables & Efficiency. (16 J un 2011). Nevada Solar and Wind
Easements & Rights Laws [web page]. Retrieved 21 Oct 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NV03R&re=1&ee=1.

Robison, J ennifer. (22 J un 2011). In Wind Farms, Nevada Decidedly Calm, The Las Vegas
Review-Journal. www.lvrj.com/business/in-wind-farms-nevada-decidedly-calm-124337909.html.

United States Court of Appeals for the Ninth Circuit. Western Watersheds Project and Center for
Biological Diversity v. Bureau of Land Management, Docket 11-15799.
www.sustainabilityclimatechangereporter.com/uploads/file/11-15799%5b2%5d.pdf.

Data collected by Francis Motycka, 6, 11 J ul 2011, 4 Aug 2011.
Reviewed by Mark Harris, 31 Oct 2011.
A-61 New Hampshire

State: New Hampshire

Wind siting basics:

Small Wind: Wind siting is done at the local level of government. However, developers of facilities larger
than 5 MW and smaller than 30 MW can petition the New Hampshire Site Evaluation Committee (SEC)
for a Certificate for Site and Facility, which would preempt local jurisdiction
(www.nhsec.nh.gov/rules/index.htm).

Large Wind: The NH SEC has overall siting authority for energy facilities 30 MW or over, as
demonstrated by its decision-making authority in RSA 162-H:16, II
(www.gencourt.state.nh.us/rsa/html/XII/162-H/162-H-16.htm). The committee works closely with the
host community(ies) to ensure orderly development of the region and incorporates local interests as much
as possible in a decision as long as the preamble to RSA 162-H is not compromised. Local ordinances,
etc. are not binding on the NH SEC. The NH SEC possesses the authority to supersede the local host
community(ies) if its requirements conflict with the preamble of the law (RSA 162-H:1,
www.gencourt.state.nh.us/rsa/html/XII/162-H/162-H-1.htm) in favor of the greater good.

History of siting authority: New Hampshire Revised Statute: RSA 162-H:2, XI (1991, 1998, 2009)
(www.gencourt.state.nh.us/rsa/html/XII/162-H/162-H-mrg.htm). New Hampshire is a Home Rule state.

Approvals needed: For Large Wind, theNew Hampshire Energy Facility Siting Evaluation Committee
(SEC) provides a Certificate of Site and Facility.

Within 60 days of submitting an application to the SEC, a decision will be made to either accept or deny
the application. If an application is deemed incomplete, the applicant has 10 days to make corrections or
choose to begin anew. Within five months, all state agencies involved are to submit to the SEC reports of
progress and list any additional information required for permits. Within eight months, the state agencies
are to report their final decisions regarding their respective jurisdictions. Within nine months of the
applications acceptance date, the SEC makes a decision to either issue or deny the certificate.

Evaluation criteria: The SEC must determine that the project:

Applicant has adequate financial, technical, and managerial capability to assure construction and
operation of the facility in continuing compliance with the terms and conditions of the certificate.
Will not unduly interfere with the orderly development of the region, with due consideration
having been given to the views of municipal and regional planning commissions and municipal
governing bodies.
Will not have an unreasonable adverse effect on aesthetics, historic sites, air and water quality,
the natural environment, and public health and safety.

(1) Environmental impact: The New Hampshire Fish & Game Department reviews potential impacts
to wildlife. The New Hampshire Natural Heritage Bureau focuses on the potential impact to
endangered species and plants.
(2) Historic sites: The New Hampshire State Historic Preservation Office is responsible for historic
and cultural resource issues.
(3) Stormwater and wetlands: New Hampshire Department of Environmental Services is responsible
for storm water runoff, wetlands, and alteration of terrain.

Public input: The SEC subcommittee must hold at least one public hearing after acceptance of the
application, and another after submission of final decisions from participating state agencies
(www.nhsec.nh.gov/rules/index.htm).
New Hampshire A-62

Relationships to other important energy policies or siting and zoning decisions: New Hampshires
Renewable Energy Portfolio mandates that 23.8% of electric generation must come from renewable
sources by 2025. Wind energy, among others, is listed as a Class I energy source. Class I energy sources
must increase by 1% every year from 2011 through 2025, reaching 16% by 2025.

Contacts:

Timothy W. Drew, Administrator
Public Information and Permitting Unit
New Hampshire Department of Environmental Services
29 Hazen Drive; PO Box 95
Concord, NH 03302-0095
(603) 271-3306
timothy.drew@des.nh.gov

J ack Ruderman
New Hampshire Public Utilities Commission
21 South Fruit Street Suite 10
Concord, NH 03301
(603) 271-2431
www.puc.nh.gov
jack.ruderman@puc.nh.gov


Database of State Incentives for Renewables & Efficiency. (7 Feb 2011). New Hampshire
Incentives/Policies for Renewables & Efficiency [web page].
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NH09R&re=1&ee=1, retrieved
3 J ul 2011.

Government of New Hampshire. New Hampshire Siting Evaluation Committee [web page]. Retrieved
3 J ul 2011 from www.nhsec.nh.gov/.

New Hampshire Revised Statutes. (8 Aug 2009). Title XII Public Safety and Welfare Chapter
162-H-2, XL Energy Facility Evaluation, siting, Construction and Operation.
www.gencourt.state.nh.us/rsa/html/XII/162-H/162-H-mrg.htm.

Tracy, Paula. (2 Nov 2010). State Wants More Analyses of Wind Projects Effects, New Hampshire
Union Leader. www.wind-watch.org/news/2010/11/02/state-wants-more-analysis-of-wind-
projects-effects/.

Data collected by Francis Motycka, 3, 6 J ul 2011, 4 Aug 2011.
Reviewed by Tim Drew, 4 Nov 2011, Kate Epsen, 26 J an 2012.
A-63 New J ersey

State Name: New J ersey

Wind Siting Basics: New J ersey has no specific wind siting authority.

History of Siting Authority: New J ersey Statute 40:55D-66.11, 31 Mar 2009. Wind and solar facilities
permitted in industrial zones ftp://www.njleg.state.nj.us/20082009/AL09/35_.PDF.

New J ersey Statute 40:55D-66.12, 16 Jan 2010. Municipal ordinances relative to small wind energy
systems www.njleg.state.nj.us/2008/Bills/AL09/244_.PDF.

New J ersey Statutes 13:19-10.1, J an 2010. Wind as a Permitted Use on Piers.
www.njleg.state.nj.us/2010/Bills/S0500/212_R3.PDF.

New J ersey Statutes 48:3-51, 29 Mar 2010. The Offshore Wind Economic Development Act
http://law.onecle.com/new-jersey/48-public-utilities/3-51.html.

Approvals needed: Approval is needed from the Department of Environment Protection and from local
governments through the planning and zoning commission. Offshore wind power, considered the greatest
source of wind power potential in New J ersey, is subject to state coastal zone management rules.

There are two general types of wind energy generation projects in New J ersey; net metered systems
interconnected behind an electric customers meter and merchant wholesale power generators. Developers
of net metered generation facilities must file an interconnection application with the Electric Distribution
Company serving the potential customer-generator. The states Board of Public Utilities (NJ BPU)
promulgates regulations governing how the states franchise Electric Distribution Companies interconnect
and net meter NJ Class I renewable resources, including wind energy.

Developers of new wholesale merchant power generation facilities must file an application with the PJ M
Interconnection. The PJ M will conduct a review, which includes preliminary feasibility, impact and cost
allocation studies.

Evaluation criteria: Pre-construction requirements for projects located in the coastal zone (Four distinct
regions are included in New J erseys coastal zone. Standards for determination of boundaries differ
among regions.) include:

Visual and Audio Bird Surveys
Migratory Bat surveys
Radar Surveys
Post construction monitoring is also required (NJ Department of Environmental Protection, 2010).

Public Input: No specific procedures identified.

Relationships to other important energy policies or siting and zoning decisions: New J erseys
renewable portfolio standard requires that each electricity supplier or provider serving retail electric
customers in the states competitive generation marketplace procure 22.5% of electricity sold from
renewable sources by 2021 (Database of State Incentives for Renewables & Efficiency, 2010).

New J ersey A-64

Contacts:

B. Scott Hunter
Renewable Energy Program Administrator
Office of Clean Energy
New J ersey Board of Public Utilities
44 S. Clinton Ave., POB 350
Trenton, NJ 08625-0350
b.hunter@bpu.state.nj.us

Ted Nichols, Principal Biologist
Division of Fish and Wildlife
New J ersey Department of Environmental Protection
tnichols@gtc3.com


Database of State Incentives for Renewables & Efficiency. (10 May 2010), New Jersey
Incentives/Policies for Renewables & Efficiency [web page]. Retrieved 1 Nov 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NJ 05R.

Database of State Incentives for Renewables & Efficiency. (11 Feb 2011). New Jersey Solar and
Wind Permitting Laws [web page]. Retrieved 1 Nov 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NJ 17R&re=1&ee=1.

Edison Electric Institute. (2004). State Generation & Transmission Siting Directory: Agencies,
Contacts, and Regulations.
www.eei.org/ourissues/ElectricityTransmission/Documents/State_Generation_Transmission_Siti
ng_Directory.pdf.

New J ersey Department of Environmental Protection. (7 Sep 2010). Technical Manual for Evaluating
Wildlife Impacts of Wind Turbines Requiring Coastal Permits.
www.state.nj.us/dep/landuse/forms/wind_monitoring_protocol.pdf.

New J ersey Department of Environmental Protection. Division of Land Use Regulation. Regulation
of Wind Turbines in New Jerseys Coastal Zone [web page]. Retrieved 1 Nov 2011 from
www.nj.gov/dep/landuse/windturbine.html.

Stemler, J odi. (Oct 2007). Wind Power Siting, Incentives and Wildlife Guidelines in the United States.
U.S. Fish & Wildlife Service.
www.fws.gov/habitatconservation/windpower/AFWA%20Wind%20Power%20Final%20Report.
pdf.

Reviewed by B. Scott Hunter, 20 J an 2012.
A-65 New Mexico

State: New Mexico

Wind siting basics: Local siting with local autonomy for projects up to 300 MW (Environmental Law
Institute, 2011). The New Mexico Public Regulation Commission has authority for projects greater than
300 MW. State agencies have the authority to override local decisions, if they are not within the
guidelines of Section 62-9-3 of the 2009 New Mexico Code
(http://law.justia.com/codes/new-mexico/2009/chapter-62/article-9/section-62-9-3/).

History of siting authority: 2009 New Mexico Code (http://law.justia.com/codes/new-
mexico/2009/chapter-3/article-21/section-3-21-1).

Approvals needed: Approval of projects by county government is based on zoning laws.

New Mexicos Public Regulation Commission has no process for review of potential wind projects.

Evaluation criteria: Guidelines from the New Mexico Department of Game & Fish include:

Turbines should not be place in documented locations of any species of wildlife, fish or plant
protected under the Federal Endangered Species Act.
Turbines should not be located in known local bird migration pathways or in areas where birds
are highly concentrated, unless mortality risk is low.
Turbines should not be placed near known bat hibernation, breeding, and maternity/nursery
colonies, in migration corridors, or in flight paths between colonies and feeding areas.
Configure turbine locations to avoid areas or features of the landscape known to attract raptors
(hawks, falcons, eagles, owls).
Configure turbine arrays to avoid potential avian mortality where feasible.
Avoid fragmenting large, contiguous tracts of wildlife habitat.
Avoid placing turbines in habitat known to be occupied by Lesser Prairie Chickens or other
species that exhibit extreme avoidance of vertical features and/or structural habitat fragmentation.
Minimize roads, fences, and other infrastructure.
Develop a habitat restoration plan for proposed sites that avoids or minimizes negative impacts on
vulnerable wildlife while maintaining or enhancing habitat values for other species.
Post-development mortality studies should be a part of any site development plan.



Contacts:

Rachel J ankowitz, Habitat Specialist
Conservation Services Division
NM Dept of Game & Fish
rachel.jankowitz@state.nm.us

J eremy Lewis
New Mexico Wind Energy Working Group
(505) 476-3323
jeremy.lewis@state.nm.us

New Mexico A-66

Michael McDiarmid
New Mexico Energy
Minerals and Natural Resources Department -- Wind Contact
(505) 476-3319
Michael.McDiarmid@state.nm.us


Power and the Local Government Role. www.eli.org/pressdetail.cfm?ID=224.

New Mexico Dept. of Game & Fish. (J an 2004). Impacts of Wind Energy Development on Wildlife.
www.wildlife.state.nm.us/conservation/habitat_handbook/documents/WindEnergyGuidelines.htm

New Mexico Energy, Minerals and Natural Resources Dept., New Mexico Wind Working Group [web
page]. Retrieved 13 J ul 2011 from
www.emnrd.state.nm.us/ECMD/RenewableEnergy/WWG.htm.

New Mexico Energy, Minerals and Natural Resources Department, Renewable Energy: Wind
[web page]. Retrieved 13 J ul 2011 from
www.emnrd.state.nm.us/ECMD/RenewableEnergy/wind.htm.

Stemler, J odi. (Oct 2007). Wind-Power Siting, Incentives, and Wildlife Guidelines in the United
States,
www.fws.gov/habitatconservation/windpower/AFWA%20Wind%20Power%20Final%20Report.
pdf.

U.S. Department of Energy Wind Powering America, New Mexico Wind Activities [web page].
Retrieved 13 J ul 2011 from www.windpoweringamerica.gov/astate_template.asp?stateab=nm.

Reviewed by Rachel J ankowitz, 8 Nov 2011.
A-67 New York

State: New York

Wind siting basics: Projects with a nameplate capacity of 25 MW or more require a Certificate of Public
Convenience and Necessity from the Public Service Commission. Wind energy projects may require
specific approvals from state or federal agencies, for example wetland or stream disturbance permits from
the Department of Environmental Conservation (DEC) or U.S. Army Corps of Engineers (USACE).
Before local and State agencies can issue these approvals, an environmental review must be conducted
according to the State Environmental Quality Review Act (SEQRA).

History of siting authority: Public Service Law (PSL) 617, 1996. Co-generation, Small Hydro and
Alternate Energy Production Facilities; New York Code: Energy Law Article 21 - 21-106, 2010. State
Environmental Quality Review Act (SEQRA), 2011. New York is a Home Rule State.

Approvals needed: The pre-application process involves submission of an application to the siting board,
which includes five state agency officials and two ad hoc members from the community. Depending on
location and environmental impact, required permits could include:

(1) Construction stormwater permit
(2) Coastal erosion control permit
(3) Freshwater wetland permit
(4) Protection of waters permit
(5) Tidal wetlands permit
(6) Endangered and threatened species take permit

The first step in the approval process is initiating the SEQRA review, where a local agency is typically
the Lead Agency. If at least one potential adverse environmental impact is identified, depending on the
type and amount of impact, an Environmental Impact Statement (EIS) could be required. After
completion of the SEQRA process, which sometimes includes a public comment period, all involved
agencies make decisions, based on each agencys jurisdiction, to approve or deny the project. SEQRA
publishes its procedures (www.riverkeeper.org/wp-content/uploads/2009/06/A_Citizens_Guid-1.pdf).

The Department of Environmental Conservation has issued guidelines for pre- and post-construction bird
and bat monitoring (www.dec.ny.gov/energy/40966.html). Prior to construction, at least one year of
monitoring is encouraged, longer if findings indicate that more study is needed. Post-construction
monitoring is typically done for a minimum of two years at each project, longer if findings indicate that
more study is needed or if site-specific situations warrant further observation.

Evaluation criteria: The following criteria are from the Model Ordinance developed by the New York
State Research and Development Authority (NYSERDA; http://nyserda.ny.gov/):

Controls and brakes: All wind turbines shall have an automatic braking, governing or feathering
system.
Climb prevention and locks: a fence six feet high with a locking portal shall be placed around
the facilitys tower base or the tower climbing apparatus shall be limited to no lower than 12 feet
from the ground, or the facilitys tower may be mounted on a roof top.
Decommissioning: Any wind energy system found to be unsafe shall be repairedor
removed within six months. If any wind energy system is not operated for a continuous period of
12 months, the Town will notify the landowner.
Environmental: Wind turbines shall be set back at least 2,500 feet from Important Bird Areas
and at least 1,500 feet from State-identified wetlands.

New York A-68

Interference with communications devices: The applicant shall minimize or mitigate any
interference with electromagnetic communications.
Liability insurance: Prior to issuance of a building permit, the applicant shall provide the town
proof of insurance.
Lighting: Towers shall be equipped with air traffic warning lights and shall have prominent
markings on the rotor blade tips of an international orange color where the total height of the
tower exceeds 175 feet.
Minimum property setbacks: The minimum setback distance shall be equal to no less than 1.5
times the sum of proposed structure height plus the rotor radius.
Power lines: All wiring between wind turbines and the wind energy facility substation shall be
underground.
Protection of public roads: if new roads are needed, minimize the amount of land used for
new roads and locate them so as to minimize adverse environmental impacts.
Sound levels: Individual wind turbine towers shall be located so that the level of noise produced
by wind turbine operation shall not exceed 55 dBA.
Substation: if new substations are needed, minimize the number of new substations.
Visual appearance of wind turbines and related infrastructure: Brand names or advertising
shall not be visible from any public access and colors and surface treatment shall minimize
visual disruption. Where wind characteristics permit, wind towers shall be set back from the
tops of visually prominent ridgelines.


Relationships to other important energy policies or siting and zoning decisions: The state of New
York has a renewable portfolio standard (RPS) of 24% percent by 2013. Main tier sources, including
wind power, must provide at least 93% of this standard.

Pending issues: On 22 J un 2011, the New York State Assembly passed the State Power Act of 2011,
which will create a centralized and streamlined process for wind facility siting for projects over 25 MW.
The new siting board will be composed of executives at various state agencies.
http://public.leginfo.state.ny.us/LAWSSEAF.cgi?QUERYTYPE=LAWS+&QUERYDATA=$$PBS18-
A$$@TXPBS018-A+&LIST=LAW+&BROWSER=EXPLORER+&TOKEN=21386711+&TARGET=VIEW.

Contacts:

Brianna Gary, Avian Ecologist
NYSDEC
625 Broadway
Albany, NY 12233-4756
(518) 402-8858
bmgary@gw.dec.state.ny.us


Database of State Incentives for Renewables & Efficiency. (10 Dec 2010), New York
Incentives/Policies for Renewables & Efficiency [web page]. Retrieved 5 J ul 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NY03R&re=1&ee=1.

A-69 New York

Erikson, Gregory D. (2009). Breaking Wind, Fixing Wind: Facilitating Wind Energy Development
in New York State, Syracuse Law Review, v60, Book I.
www.burtonawards.com/uploaddir/Eriksen,%20Gregory%20-%20SUCOL%20Law%20Review
%20article%2012-14-09.pdf.

New York State Assembly. (22 J un 2011). The Power NY Act of 2011.
http://public.leginfo.state.ny.us/LAWSSEAF.cgi?QUERYTYPE=LAWS+&QUERYDATA=@L
LPBS+&LIST=LAW+&BROWSER=EXPLORER+&TOKEN=56666590+&TARGET=VIEW.

New York Department of Environmental Conservation. (Aug 2009). Guidelines for Conducting Bird
and Bat Studies at Commercial Wind Energy Projects. Division of Fish, Wildlife and Marine
Resources. www.dec.ny.gov/energy/40966.html.

New York Department of Environmental Conservation, SEQR Cookbook [web page]. Retrieved 5 J ul
2011 from www.dec.ny.gov/permits/57228.html.

New York State Energy Research and Development Authority, Wind Energy Toolkit; Including
Model Ordinance [web page]. Retrieved 5 J ul 2011 from
www.powernaturally.org/programs/wind/toolkit.asp,
www.powernaturally.org/programs/wind/toolkit/2_windenergymodel.pdf.

New York Statutes. New York Environmental Conservation: (2009) 15, 17, 24, 25, 30, 70; (2006)
6 NYCRR 661; (1998) 6 NYCRR 505; (2006) 6 NYCRR 663; (2009) 6 NYCRR 608.
http://public.leginfo.state.ny.us/menuf.cgi and www.dec.ny.gov/regs/4490.html#18106.

Stahl, Brent. (2009). Wind Energy Laws and Incentives: A Survey of Selected State Rules,
Washburn Law Review. www.washburnlaw.edu/wlj/49-1/articles/stahl-brent.pdf.

Data collected by Francis Motycka, 5, 11, J ul 2011, 4 Aug 2011.
Reviewed by Brianna Gary, 10 Nov 2011.
North Carolina A-70

State: North Carolina

Wind siting basics: Wind siting is done at the local level of government.

History of siting authority: North Carolina General Statutes, Chapter 62 (1963)
(www.ncga.state.nc.us/enactedlegislation/statutes/html/bychapter/chapter_62.html)

Rule R8-61regarding certificates of public convenience and necessity for construction of electric
generation and related transmission facilities in North Carolina (Feb 2008)
(http://ncrules.state.nc.us/ncac/title%2004%20-%20commerce/chapter%2011%20-
%20utilities%20commission/04%20ncac%2011%20r08-61.pdf)

North Carolina Environmental Policy Act (SEPA) (1971, 1991)
(www.ncleg.net/EnactedLegislation/Statutes/HTML/ByChapter/Chapter_113A.html)

North Carolina is a Home Rule state.

Approvals needed: The following agencies should be contacted:

(1) North Carolina Department of Environment
(2) North Carolina Department of Natural Resources
(3) U.S. Army Corps of Engineers for projects in or around streams, wetlands, or other waters
(4) County government

The developer must obtain a Certificate of Public Convenience and Necessity from the NCUC. If the
project is 300 MW or more, the applicant must submit a summary at least 120 days before filing an
application.

Evaluation criteria: Criteria from the Watuaga County ordinance (2006) include:

(1) Decommissioning
(2) Demographics of surrounding area
(3) Location, topography and wetland assessments
(4) Maintenance
(5) Noise
(6) Public health and safety
(7) Tourism and community benefits
(8) Visual impacts, with a special emphasis on the Blue Ridge Parkway viewshed.

Public input: Within ten days of filing an application, the applicant must provide at least three public
notifications through the local newspaper to all residents in the county and municipality that will be
affected by the facility. A project summary must also be forwarded to the North Carolina State
Environmental Review Clearinghouse (www.doa.state.nc.us/clearing/).

Relationships to other important energy policies or siting and zoning decisions: North Carolinas
renewable portfolio standard (RPS) requires 12.5% of 2020 electricity sales to come from renewable
sources. Each utility shall file compliance reports in 2012, 2013, 2014, 2015, 2018, and 2021, detailing
the previous years electricity sales. (Database of State Incentives for Renewables & Efficiency, 2011).

Pending issues: The Desert Wind Energy Project, North Carolinas first utility-scale wind facility, a 300
MW wind facility in the counties of Pasquotank and Perquimans, has received approval from the North
Carolina Utilities Commission. Electricity generation is anticipated to begin by the end of 2012.

A-71 North Carolina

Contacts:

Sam Watson
North Carolina Utilities Commission
430 N. Salisbury Street
Raleigh, NC 27611
Phone: (919) 715-7057
www.ncuc.commerce.state.nc.us
swatson@ncuc.net


Database of State Incentives for Renewables & Efficiency. (May 2011). North Carolina
Incentives/Policies for Renewables & Efficiency [web page]. Retrieved 12 J ul 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NC09R&re=1&ee=1.

Murawski, J ohn. (3 May 2011). Giant Wind Farm Clears First Hurdle, Gets N.C. Approval, The
Charlotte Observer. www.charlotteobserver.com/2011/05/03/2268865/giant-wind-farm-clears-
first-hurdle.html.

Watauga County Wind Ordinance (May 2006)
(www.at.appstate.edu/documents/WataugaCountywindordinance.pdf).

Data collected by Francis Motycka 6, 11, 12 J ul , 3 Aug 2011.

North Dakota A-72

State: North Dakota

Wind siting basics: The North Dakota Public Service Commission (PSC) regulates the siting of wind
facilities greater than 0.5 MW (www.legis.nd.gov/cencode/t49c22.pdf). Smaller facilities are regulated at
the local level (by either county or township board).

History of siting authority: The Energy Conversion and Transmission Facility Siting
General Provisions were amended in 1979, and again in 1982, 2008, and most recently in 2011.
4
Passage
of Senate Bill 2196 (Sixty Second Legislative Assembly of North Dakota, 2011) closed what one state
senator referred to as a loophole that allowed wind developers to avoid the state siting provisions by
breaking up larger wind projects into smaller ones simply to keep under the minimum capacity threshold
(ND PSC may get broader wind farm siting authority, 2011). Prior to this amendment, North Dakota
PSC had authority to review energy conversion facilities for projects over 60 MW. The 2011 amendments
lower the limit for wind generators to 0.5 MW and all other generators to 50 MW.

Approvals needed: For any wind project greater than 0.5 MW, applicants must obtain a Certificate of
Site Compatibility from the North Dakota Public Service Commission. The Commission works in concert
with as many as 21 state agencies in determining whether to issue a Certificate.
5

The North Dakota PSC outlines a comprehensive list of procedures and required certificates and permits.
These include:

(1) General Provisions
Advisory Committees
Public Hearings
(2) Utility Reporting Requirements
(3) Letter of Intent
(4) Certificate of Site or Corridor Compatibility
(5) Transmission Facility Permit
(6) Waiver of Procedures and Time Schedules
(7) Criteria
(8) Continuing Suitability of Certificate or Permit

The timetable for application review is undetermined, dependent upon completion of all requirements.

Evaluation criteria: Criteria for evaluating energy conversion facility siting decisions include:

(1) Exclusion zones
national parks, forests, etc.
state parks, forests, etc.
irrigated lands

4
North Dakota Administrative Code, Title 69-06, www.legis.nd.gov/information/acdata/html/69-06.html.
5
The list of 21 state agencies required to receive notice of applications for Energy Conversion Facilities
and Transmission Facilities is included in 69-06-01-05. These include the North Dakota Departments of
Agriculture, Health, Human Services, Labor, Career and Technical Education, and the Aeronautics
Commission, Attorney General, Economic Development Commission Energy Development Impact
Office, Game and Fish Department, Geological Survey, Governor, Highway Department, State Historical
Society of North Dakota, Indian Affairs Commission, J ob Service of North Dakota, Land Development,
Parks and Recreation Department, Division of Community Services-Department of Commerce, Soil
Conservation Committee, and State Water Commission.
A-73 North Dakota

areas important to the life-cycle of endangered species
(2) Avoidance areas
geologically unstable areas
historically significant areas
woodlands and wetlands

(3) Selection criterion evaluation of impacts on:
Agriculture
Law enforcement
School systems and educational programs
Governmental services and education programs
General and mental health care facilities
Recreational programs and facilities
Transportation facilities and networks
Retail service facilities
Utility services
Local institutions
Noise-sensitive land uses
Rural residences and businesses
Aquifers
Human health and safety
Animal health and safety
Plant life
Temporary and permanent housing
Temporary and permanent skilled and unskilled labor

Public input: General hearings are held prior to adopting or modifying the criteria, or suspending a
certificate or permit. Application hearings are held for a certificate or permit.

Relationships to other important energy policies or siting and zoning decisions: North Dakota has a
Renewable Portfolio Standard of 10% by 2015. North Dakota already has over 1,400 MW of installed
wind capacity (Wind Powering America, 2011).

Contacts:

Christopher Marohl
Public Utility Analyst
ND Public Service Commission
camarohl@nd.gov

J ohn Schumacher
Resource Biologist
ND Game & Fish Dept
(701) 328-6321
jdschumacher@nd.gov

North Dakota A-74


Database of State Incentives for Renewables & Efficiency, North Dakota Incentives/Policies for
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=ND05R&re=1&ee=1.

_______. (2 Feb 2011). ND PSC may get broader wind farm siting authority. AgWeek.
www.agweek.com/event/article/id/17872/.

North Dakota Public Service Commission. Energy Conversion and Transmission Facility Siting.
www.legis.nd.gov/information/acdata/html/69-06.html.

Sixty Second Legislative Assembly of North Dakota. (19 April 2011). Senate Bill No. 2196.
www.legis.nd.gov/assembly/62-2011/documents/11-8182-01000.pdf.


Wind Powering America. U.S. Installed Wind Capacity [web page]. Retrieved 23 Oct 2011 from
www.windpoweringamerica.gov/wind_installed_capacity.asp.

Data gathered by Kai Goldynia, 23 J ul 2011.
Reviewed by Christopher Marohl, 31 Oct 2011.
A-75 Ohio

State: Ohio

Wind siting basics: The Ohio Power Siting Board (OPSB) has regulatory jurisdiction for the siting of all
wind projects in Ohio with a generating capacity of at least 5 megawatts (MWs). For wind projects less
than 5 MW, the local zoning requirements would apply.

History of siting authority: Previously, the OPSB had jurisdiction for wind farms with a capacity of at
least 50 megawatts; however, as of 2008, the legislature extended the Boards jurisdiction to also include
economically significant wind farms, defined as having generating capacities between 5 and 50 MWs
(http://codes.ohio.gov/orc/4906.20).

Approvals needed: Developers who wish to site wind facilities designed for or capable of generating five
or more megawatts must first apply for and obtain a certificate of environmental compatibility and public
need from the OPSB.

Permits required for construction could include at least:

National Pollutant Discharge Elimination System (NPDES) Permit Construction that disturbs 1
acre or more requires a stormwater-discharge permit from the Ohio Environmental Protection
Agency (EPA).
Water Quality Certificate Construction that disturbs lakes, rivers, streams, and wetlands
requires a water-quality certificate from the Ohio EPA.
Shoreline Shore structure construction requires a permit from the Ohio Department of Natural
Resources. (Great Lakes Commission, 2009).

Evaluation criteria: For the complete Basis for Decision Granting or Denying Certificate (Ohio
Revised Code 4906.10), see http://codes.ohio.gov/orc/4906.10. The OPSB criteria include:

The need for the facility if the facility is an electric transmission line;
The probable environmental impact of the proposed facility;
Whether the facility represents the minimum adverse environmental impact;
In the case of electric transmission lines, that the facility is consistent with regional plans for
expansion of the electric power grid of the electric systems serving Ohio
That the facility will comply with all air and water pollution control and solid waste disposal laws
and regulations;
That the facility will serve the public interest, convenience, and necessity;
The facilitys impact on the viability as agricultural land of any land in an existing agricultural
district; and
That the facility incorporates maximum feasible water conservation practices as determined by
the Board. (Ohio Power Siting Board, 2010).

Public input: The Ohio power siting process includes several opportunities for public input, including
mandatory public information meetings prior to the filing of an application and public hearings. Members
of the public can seek to intervene in the siting proceeding, testify at public hearings without intervening,
and submit letters that are considered by the Board in making its decisions.
(www.puco.ohio.gov/emplibrary/files/OPSB/Presentations_Manuals/OPSBbrochure2010.pdf).

Ohio A-76

Relationships to other important energy policies or siting and zoning decisions: Ohio has an
alternative energy resource standard of 25 percent by 2025; at least half must come from renewable
sources, including a specific in-state requirement (Database of State Incentives for Renewables &
Efficiency).

Contacts:

Christina OKeeffe
Ohio Wind Working Group
(614) 466-8396
Christina.Okeeffe@development.ohio.gov

J ennifer Norris, Wind Energy Wildlife Biologist
Ohio Department of Natural Resources
Division of Wildlife
J ennifer.Norris@dnr.state.oh.us

Megan Seymour, Wildlife Biologist
U.S. Fish and Wildlife Service
Reynoldsburg Field Office
megan_seymour@fws.gov


Database of State Incentives for Renewables & Efficiency, Ohio Incentives/Policies for Renewables
& Efficiency Alternative Energy Resource Standard [web page]. Retrieved 31 Oct 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=OH14R&re=1&ee=1.

Great Lakes Commission Staff. (Mar 2009). Siting and Permitting Wind Farms in Ohio.
http://wiki.glin.net/download/attachments/950461/Ohio.doc?version=3.

Green Energy Ohio. Steps to Installing a Wind Turbine [web page]. Retrieved 23 J un 2011 from
www.greenenergyohio.org/page.cfm?pageID=2229.

Ohio Administrative Code. Chapter 4906. http://codes.ohio.gov/oac/4906.

Ohio Department of Natural Resources. (14 Mar 2008). Ohio Department of Natural Resources
Terrestrial Wind Energy Voluntary Cooperation Agreement.
www.dnr.state.oh.us/LinkClick.aspx?fileticket=GsssB%2BJ eczA%3D&tabid=21467.

Ohio Revised Code. Chapter 4906. http://codes.ohio.gov/orc/4906.

Ohio Power Siting Board. (Mar 2010). Siting New Energy Infrastructure in Ohio: A Guidance
Document.
www.puco.ohio.gov/emplibrary/files/OPSB/Presentations_Manuals/OhioSitingManual.pdf.

Ohio Wind Working Group. (2008). Ohio's Alternative Energy Portfolio Standard.
www.ohiowind.org/Ohio-Advanced-Energy-Portfolio-Standard.cms.aspx.

Data collected by Kai Goldynia, 23 J une 2011.
Reviewed by Stuart Siegfried, 8 Nov 2011.
A-77 Oklahoma

State: Oklahoma

Wind siting basics: Responsibility for wind siting is entirely at the local level of government. Wind
power projects can go through a voluntary review by the Oklahoma Corporation Commission.

History of siting authority: The Oklahoma Wind Energy Development Act (J un 2010) Oklahoma
Statutes Title 17, 160.11 160.19 (www.occeweb.com/GC/OKLaw.html). Oklahoma is a Dillon Rule
state (National League of Cities).

Approvals needed: Applicants must adhere to the requirements mandated by the local jurisdiction.

The Oklahoma Wind Energy Development Act regulates decommissioning, requires wind farm operators
to provide prompt statements regarding royalty payments to land-owners, and requires commercial
liability insurance with the landowner insured (Oklahoma Statutes Title 17, 160.14 et seq.) .



Relationships to other important energy policies or siting and zoning decisions: Oklahoma has a
renewable energy portfolio standard (RPS) mandating that 15% of energy capacity will come from
renewable sources, including wind, by 2015. Each utility files an annual report to the Oklahoma
Corporation Commission, including total kilowatt-hours (kWh) and the sources for generation. Oklahoma
has no specific provisions for using or trading renewable energy credits (RECs) (Database of State
Incentives for Renewables & Efficiency).

Pending issues: The Oklahoma Exploration Rights of 2011 (52-801 52-805
www.oklegislature.gov/osstatuestitle.html) mandates that the exploratory rights of oil and natural gas
companies "not be diminished, abrogated or interfered with in any respect by a wind or solar energy
agreement except with the prior written consent of the owner of exploration rights, which consent may be
granted or withheld for any reason or for no reason.

Contacts:

George Kiser
Oklahoma Corporation Commission
Public Utility Division
2201 N. Lincoln Boulevard
Oklahoma City, OK 73105
(405) 521-6878
www.occ.state.ok.us
g.kiser@occemail.com

Oklahoma Corporation Commission
PO Box 52000
Oklahoma City, OK 73152-2000
(405) 521-2211
www.occeweb.com/index.html

Oklahoma A-78


Carr, Housley. (28 Mar 2011). Oil, gas development rights bill seen as threat to Oklahoma wind
energy, Electric Utility Week.

Database of State Incentives for Renewables & Efficiency. Oklahoma Incentives/Policies for
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=OK05R&re=1&ee=1.
National League of Cities. Local Government Authority [web page]. Retrieved 25 Oct 2011
http://nlc.org/build-skills-networks/resources/cities-101/local-government-authority.

Oklahoma Statutes. (J un 2010). The Oklahoma Wind Energy Development Act, Title 17, 160.11
160.19. www.occeweb.com/GC/OKLaw.html.

Oklahoma Wind Power Initiative [web page]. Retrieved 10 J ul 2011 from
www.seic.okstate.edu/owpi/.

Data collected by Francis Motycka, 8, 10, 11 J ul 2011.
Reviewed by George Kiser, 16 Dec 2011.
A-79 Oregon

State: Oregon

Wind siting basics: Wind projects smaller than 105 MW are regulated by cities and counties. The
Oregon Energy Facility Siting Council (EFSC) regulates larger projects.

History of siting authority: The Energy Facility Siting Council and the Oregon Department of Energy
were created in 1975 (Oregon Statutes Chapter 469, www.leg.state.or.us/ors/469.html).

Approvals needed: For small wind applications, applicants must obtain local land-use permits and
electrical (building) permits. For large wind, developers must apply to the EFSC for a site certificate.


Small Wind

Turbines must be mounted on towers between 60-100 feet tall, at least 30 feet above obstructions
Residential wind turbines must range from 500 watts to 10 kilowatts

Large Wind

General Standards
Noise
Wetlands
Water Pollution Control Facility
Water Rights

Specific Standards
Organizational Expertise: helps ensure that the applicant has the abilities and resources to
successfully build and operate the facility.
Structural Standard: protects public health and safety, including the safety of
facility workers, from seismic hazards.
Soil Protection
Protected Areas
Fish and Wildlife Habitat
Threatened and Endangered Species
Scenic Resources
Historical, Cultural, and Archaeological Resources
Recreation
Public Services
Waste Minimization
Carbon Dioxide Emissions
A "one-stop" process in which the Council determines compliance with specific standards of the
Council and other state and local permitting agencies.
Appeals requiring judicial review go directly to the Oregon Supreme Court.

Public input: For large wind, public comment periods take place during the early phase of the process
and are followed by formal contested case proceedings.

Relationship to other important energy policies or siting and zoning decisions: Oregons Renewable
Portfolio Standard directs utilities to reach 25% of retail electricity needs with qualified renewable
resources by 2025.
Oregon A-80

Pending issues: A major issue for Oregon large wind generation arises due to competition with
hydroelectric power for limited transmission capacity. The Bonneville Power Authority (BPA) has
sometimes issued curtailment orders for wind farms along the Columbia River (Laskow, 2011). On 7 Dec
2011, the Federal Energy Regulatory Commission (FERC) ruled that curtailment of wind power is
discriminatory (Ranken, 2011).

Contacts:

Andy Ginsburg, Air Quality Administrator
Oregon Department of Environmental Quality
811 SW Sixth Ave
Portland, OR 97204
(503) 229-5397
ginsburg.andy@deq.state.or.us

Diana Enright, Assistant Director
Renewable Energy Division
Oregon Department of Energy
625 Marion St. NE
Salem, OR 97301-3737
diana.enright@state.or.us

Tom Stoops, Council Secretary
Energy Facility Siting Council
Oregon Department of Energy
625 Marion St. NE
Salem, OR 97301-3737
Tom.stoops@state.or.us


Laskow, Sarah. (15 J un 1011). "Renewable v. Renewable: Oregon wind and hydro fight over grid
space," Grist. www.grist.org/list/2011-06-15-renewable-v.-renewable-oregon-wind-and-hydro-
fight-over-grid-spa/PALL/print.

Oregon Department of Energy. Permitting and Siting Wind Facilities [web page]. Retrieved
10 J ul 2011 from www.oregon.gov/ENERGY/RENEW/Wind/Permitting.shtm.

Oregon Department of Energy. Wind Energy Information for Landowners [web page]. Retrieved
10 J ul 2011 from www.oregon.gov/ENERGY/RENEW/Wind/windinfo.shtml.

Oregon Statutes. (2009). Chapter 469 - Energy; Conservation Programs; Energy Facilities.
www.leg.state.or.us/ors/469.html.

Ranken, Tom. (11 Dec 2011). FERC Rules That BPA Curtailment of Wind Energy Violates Federal
Power Act. U.S. Department of Energy. (1 J un 2010). Oregon Model Wind Ordinance.
www.windpoweringamerica.gov/filter_detail.asp?itemid=2746.

Data collected by Kai Goldynia, 10 J ul 2011.
A-81 Pennsylvania

State: Pennsylvania

Wind siting basics: Siting responsibility lies at the municipal level of government. A model ordinance
was created in 2006; however, many local municipalities have developed their own guidelines and
ordinances (Pennsylvania Department of Environmental Protection, 2006).

History of siting authority: Pennsylvania Municipalites Planning Code (MPC) Act of 1968, P.L.805,
No.247. http://mpc.landuselawinpa.com/mpc_full.html

Approvals needed: Within 30 days of a permit application, the municipality will determine whether or
not the application is complete. Once the application is determined to be complete, the municipality will
schedule a public hearing, and, within 120 days or 45 days after any hearing is completed, whichever is
later, the municipality will decide to issue or deny the permit application (Pennsylvania Department of
Environmental Protection, 2006).

A cooperative agreement with the Pennsylvania Game Commission addressing bat, bird, and wildlife
issues is voluntary. Specific wildlife surveys can be required, depending on projected impacts. According
to the Wind Energy Voluntary Cooperation Agreement with the Pennsylvania Game Commission, the
developer must notify the PGC 14 months prior to construction. Within 45 days of the notification, the
PGC will communicate its findings on the potential impact of the wind development site on wildlife and
habitat.

For erosion and sediment control, the Pennsylvania Department of Environmental Protection (DEP)
requires a general or individual NPDES Permit for Storm Water Discharges Associated with Construction
Activities. For water obstruction and encroachment and wetlands, developers must obtain a separate DEP
permit (Commonwealth of Pennsylvania). In addition, before submitting to the DEP, the applicant must
complete an online Pennsylvania Natural Diversity Inventory (PNDI) Environmental Review
(Commonwealth of Pennsylvania Office of Energy and Technology Development, Department of
Environmental Protection).

Evaluation criteria: No firm criteria identified. The Model Ordinance includes:

Controls and brakes: All Wind Energy Facilities shall be equipped with a redundant braking
system.

Climb prevention and locks: Wind Turbines shall not be climbable up to fifteen (15) feet above
ground surface, and All access doors to Wind Turbines and electrical equipment shall be locked
or fenced, as appropriate.

Decommissioning: The Facility Owner and Operator shall complete decommissioning of the
Wind Energy Facility, or individual Wind Turbines, within (12) twelve months after the end of
the useful life of the Facility or individual Wind Turbines

Dispute resolution: The Facility Owner and Operator shall maintain a phone number and
identify a responsible person for the public to contact with inquiries and complaints.

Interference with communications devices: The Applicant shall make reasonable efforts to avoid
any disruption or loss of radio, telephone, television or similar signals, and shall mitigate any
harm caused by the Wind Energy Facility.

Liability insurance: There shall be maintained a current general liability policy.

Pennsylvania A-82

Minimum property setbacks: Wind Turbines shall be set back from the nearest Occupied
Building a distance1.1 times the Turbine Height. For non-participating landowners, Wind
Turbines shall be set back from the nearest Occupied Building located on a Non-participating
Landowners property a distance of not less than five (5) times the Hub Height.

Power lines: On-site transmission and power lines between Wind Turbines shall be placed
underground.

Protection of public roads: Any road damage caused by the applicant or its contractors shall be
promptly repaired at the Applicants expense.

Shadow flicker: There are no specific standards in the Model Ordinance.

Sound levels: Audible sound from a Wind Energy Facility shall not exceed fifty (55) dBA.

Visual appearance of wind turbines and related infrastructure: Wind Turbines shall be a non-
obtrusive color and Wind Turbines shall not display advertising.


Relationships to other important energy policies or siting and zoning decisions: Pennsylvanias
Advanced Energy Portfolio Standard (AEPS) mandates that 18% of electricity sold by each electric
distribution company (EDC) and electric generation supplier (EGS) within Pennsylvania must be
generated from alternative energy sources by the year 2020. The standard includes a mandate for 8% of
the energy sources to come from Tier 1 sources, which includes wind, among other sources.

Contacts:

Thurman Brendlinger
Clean Air Council
135 South 19th St. Suite 300
Philadelphia, PA 19103
(215) 567-4004 x104
brendlinger@cleanair.org

Kerry Campbell
Office of Pollution Prevention and Compliance Assistance
Pennsylvania Department of Environmental Protection
Harrisburg, PA 17105
(717) 772.5985
kcampbell@state.pa.us

Scott Gebhardt, Analyst
Pennsylvania Public Utility Commission
P.O. Box 3265
Harrisburg, PA 17105-3265
(717) 425-7584
www.puc.state.pa.us/
ra-aeps@state.pa.us

A-83 Pennsylvania


Commonwealth of Pennsylvania. (1968). Pennsylvania Municipalities Planning Code Act of 1968,
P.L. 805, No. 247. http://mpc.landuselawinpa.com/MPCode.pdf.
Commonwealth of Pennsylvania Office of Energy and Technology Development, Department of
Environmental Protection. (2005). Process and Regulations Specific to Wind Farm Development.
Commonwealth of Pennsylvania. Pennsylvania Planning Code Title 25 Environmental Protection.
www.pacode.com/secure/data/025/025toc.html.
EBR Staff Writer. (8 J ul 2011). BP signs agreements to sell power from Pennsylvania wind farm,
Energy Business Review. http://wind.energy-business-review.com/news/bp-signs-agreements-to-
sell-power-from-pennsylvania-wind-farm-080711.
Pennsylvania Department of Environmental Protection. (2006). Model Ordinance for Wind Energy
Facilities in PA.
www.portal.state.pa.us/portal/server.pt/document/903580/wind_model_ordinance_draft_%2812-
8-06%29_doc?qid=15224179&rank=10.

Pennsylvania Game Commission. (23 Feb 2007). Wind Energy Voluntary Cooperation Agreement.
www.crisciassociates.com/Newsletter/docs/3/GameComWindAgree.pdf.

Stahl, Brent. (2009). Wind Energy Laws and Incentives: A Survey of Selected State Rules.
www.washburnlaw.edu/wlj/49-1/articles/stahl-brent.pdf.

Data collected by Francis Motycka, 5, 8 J ul 2011.
Reviewed by Scott Gebhardt and Kerry Campbell, 11 Nov 2011.
Rhode Island A-84

State: Rhode Island

Wind siting basics: For projects 40 MW and over, the Rhode Island Energy Facilities Siting Board is in
charge. For projects under 40 MW, local governments have siting authority.

History of siting authority: The Energy Facility Siting Act, most recently updated in 2001
(www.rilin.state.ri.us/Statutes/TITLE42/42-98/INDEX.HTM).

The Comprehensive Energy Conservation Efficiency and Affordability Act of 2006 gives the Rhode
Island Division of Planning the authority to establish standards and guidelines for locating renewable
energy facilities (www.rilin.state.ri.us/BillText/BillText06/SenateText06/S2903Baa.pdf).

Approvals needed: For facilities over 40 MW, the Siting Board collaborates with various state and local
agencies to ensure that the applicant is complying with state and local regulations and then issues a
one-stop permit. The only on-shore wind facilities in Rhode Island, as well as any that have been
proposed to date, are far under 40 MWs (Gonsalves, Paul, Rhode Island Division of Planning, personal
communication, 8 Aug 2011). Therefore, applicants are permitted by the local government. In this case,
the applicant would at least need approval from the local Planning Commission and a special use permit
from the zoning board.

Evaluation Criteria:

A report by the Rhode Island Department of Environmental Management (DEM) proposed the following
guidelines for siting wind turbines on state lands:

-Distance from nearest property line: 1.5 times hub height +rotor radius
-Distance from nearest structure: 1.5 times hub height +rotor radius
-Distance from roads: 1.5 times hub height +rotor radius
-Distance to protect from icing: 820 feet
-Public safety distance: 1.5 times hub height +rotor radius
-Noise: Project must not exceed 35 DBA in the evening, 45 DBA in the daytime in residential areas.
Cannot increase background tonal sound by more than 3 DB.

The Rhode Island Division of Planning is currently in the process of developing wind siting guidelines for
the municipalities, and possibly a model ordinance. The guidelines should be released next month.

Rhode Island Energy Plan (includes discussion of wind guidelines):
www.planning.ri.gov/landuse/Energy%20plan311.pdf

Public input: None identified. Municipalities can hold public hearings.

Relationships to other important energy policies or siting and zoning decisions: Rhode Island has an
RPS of 16% by 2019. A separate and distinct standard enacted in J une 2009 (Long-Term Contracting
Standard for Renewable Energy) requires electric distribution companies to solicit proposals and enter
into long-term contracts for capacity, energy and attributes from new renewable energy facilities.
(DSIRE, 10 Aug 2011).

Pending issues: Over 95% of wind energy potential in Rhode Island is located offshore. As such, the
Rhode Island Coastal Resources Management Council has developed the Ocean Special Area
Management Plan (Ocean SAMP), in an effort to encourage renewable energy development offshore.
Link to the Ocean SAMP:
http://seagrant.gso.uri.edu/oceansamp/pdf/samp_approved/800_renewable_OCRMchanges_5.4_Clean.pdf

A-85 Rhode Island

Several towns currently in the process of permitting a wind turbine have placed a moratorium on
permitting until the RI Division of Planning releases its new wind siting guidelines.

Contacts:

Patrick McCarthy, Administrator of Energy Programs
State of Rhode Island
Office of Energy Resources
One Capitol Hill
Providence, RI 02908
(401) 574-9100
Patrick.McCarthy@energy.ri.gov

Paul Gonsalves
Rhode Island Division of Planning
Senior Planner
401-222-1756
Paul.gonsalves@doa.ri.gov


Database of State Incentives for Renewables & Efficiency. (10 Aug 2011). Rhode Island
Incentives/Policies for Renewables & Efficiency [web page]. Retrieved 3 Oct 2011 from
www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=RI08R&re=1&ee=1.

Environmental Law Institute. (May 2011). State Enabling Legislation for Commercial-Scale Wind
Power Siting and the Local Government Role. www.elistore.org/reports_detail.asp?ID=11410.

Kuffner, Alex. (10 Feb 2011). R.I. plans to adopt wind turbine guidelines by October, Providence
Journal. www.projo.com/news/content/WIND_POWER_STANDARDS_02-10-
11_7GMDPFQ_v9.16aaf3c.html.

Statewide Planning Technical Committee. (4 Mar 2011). RI Energy Plan (Update) and the Renewable
Energy Siting Guidelines and Standards. www.planning.ri.gov/landuse/Energy%20plan311.pdf


South Carolina 86

State Name: South Carolina

Wind siting basics: The Utility Facility Siting and Environmental Protection Act (S.C. Code Ann. 58-
33-10, www.scstatehouse.gov/code/t58c033.php) governs siting of major utility facilities. Currently, wind
power projects less than 75 MW are not regulated at either the state or local level of government. Electric
suppliers regulated by the Public Service Commission (PSC) seeking to build an electric generating plant
of 75 MW or greater must obtain a Certificate of Public Convenience and Necessity (CPCN), issued by
the PSC. The application includes a description of the facility, its location, a statement explaining the
need for the facility, and environmental impact studies.

The South Carolina Office of Regulatory Staff (ORS) has sole responsibility for the inspection, auditing,
and examination of public utilities, and represents the public interest in regulation of the major utility
industries (Act 175 of 2004, www.scstatehouse.gov/code/t58c003.php).


Approvals needed: No state level approval is needed, unless the facility is covered under the Utility
Facility Siting and Environmental Protection Act or involves lands otherwise subject to regulation, such
as wetlands.



Relationships to other important energy policies or siting and zoning decisions: South Carolina
currently has no Renewable Portfolio Standard. The potential for use of offshore wind as a key renewable
technology is currently a subject of discussion in South Carolina.

Pending issues: South Carolina Act 318 of 2008 (www.scstatehouse.gov/code/t48c052.php) established
the Wind Production Farms Feasibility Study Committee to evaluate wind power feasibility. The study
results were issued in a 1 J an 2010 report to the Governor and South Carolina General Assembly
(http://energy.sc.gov/index.aspx?m=6&t=123).

The Regulatory Task Force for Coastal Clean Energy was established as an objective of a 2008 grant
from the U.S. Department of Energy, which has the goal of identifying and overcoming existing barriers
for coastal clean energy development for wind, wave and tidal energy projects in South Carolina
(http://energy.sc.gov/index.aspx?m=6&t=85&h=904).

Contacts:

South Carolina Office of Regulatory Staff
1401 Main Street, Suite 900
Columbia, SC 29201
www.regulatorystaff.sc.gov/


South Carolina Energy Office. Wind Energy [web page]. Retrieved 4 Aug 2011 from
www.energy.sc.gov/index.aspx?m=6&t=85.

South Carolina Energy Office. Wind Energy Production Farms Feasibility Study Committee [web
page]. Retrieved 27 Oct 2011 from www.energy.sc.gov/index.aspx?m=6&t=123.


A-87 South Carolina

South Carolina General Assembly. (11 J un 2008). A318. www.scstatehouse.gov/sess117_2007-
2008/bills/4766.htm.

South Carolina Public Service Authority. (2010). Integrated Resource Plan.
www.energy.sc.gov/publications/2010_IRP_SCPSA.pdf.


Data gathered by Kai Goldynia, 4 August 2011, Deborah Luyo 27 Oct 2011.
Reviewed by Allyn Powell, 20 J an 2012.
South Dakota A-88

State: South Dakota

Wind siting basics: A permit from the South Dakota Public Utilities Commission (PUC) is required for
electric generating facilities with a capacity over 100 MW.
http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=49-41B-35

History of siting authority: Siting authority created by SD Legislature in SDCL 49-41B (1977)
(http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=49-41B-1).

SDCL 43-13-21 through 24 (2009) established setbacks for wind turbines
(http://legis.statse.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=43-13).
Draft Model Ordinance for Siting of Wind Energy Systems (2008)
(http://puc.sd.gov/commission/twg/WindEnergyOrdinance.pdf).

Approvals needed: In addition to the permit from the PUC, approvals are required from the following
agencies:

South Dakota Game, Fish & Parks, concerning grasslands, wetlands and wildlife,
http://gfp.sd.gov/.

South Dakota State Historic Preservation Office, concerning historically important sites,
http://history.sd.gov/Preservation/.

South Dakota Department of Environment and Natural Resources, concerning air and water
protection, http://denr.sd.gov/.

South Dakota Department of Transportation, www.sddot.com/ Need is dependent on whether the
site will utilize state right-of-way.

Local Government (County/City Commission) Building permits typically required regardless of
project size.

The time frame for obtaining a permit from the PUC is (Binder, 2009):

Notice of intent filed six months prior to Application for Permit. (Notice of intent process only
applies to non-wind energy conversion facilities over 100 MW.)
Application for Permit filed.
Public Hearing within 60 Days.
Decision within six months of receipt of Application (one year for non-wind energy conversion
facilities).

Evaluation criteria: Evaluation criteria are laid out in SDCL 49-41B
(http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=49-41B) and ARSD 20:10:22
(http://legis.state.sd.us/rules/DisplayRule.aspx?Rule=20:10:22).

The Public Utilities Commission shall also hear and receive evidence presented by any state department,
agency, or units of local government relative to the environmental, social, and economic conditions and
projected changes therein
(http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=49-41B-19).

A-89 South Dakota

Public input: Per SDCL 49-41B-16, a public hearing shall be held as close as practicable to the
proposed facilitys location. Timing requirements usually schedule this about 60 days after the application
is filed (http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=49-41B-16).


Contacts:

Brian Rounds, Staff Analyst
S.D. Public Utilities Commission
Capitol Building, 1
st
Floor
500 East Capitol Avenue
Pierre, SD 57501
(605) 773-3201
http://puc.sd.gov
brian.rounds@state.sd.us


Binder, Tim. (21 Oct 2009). Wind Energy Facility Siting and Permitting in South Dakota. South
Dakota Public Utilities Commission.
www.ndltap.org/events/conference/downloads/10-20Binder.pdf.

Power and the Local Government Role. www.eli.org/pressdetail.cfm?ID=224.

South Dakota Bat Working Group. (Apr 2009). Siting Guidelines for Wind Power Projects in South
Dakota. Department of Game, Fish and Parks. http://gfp.sd.gov/wildlife/docs/wind-power-siting-
guidelines.pdf.

South Dakota Public Utilities Commission. Wind Energy Development in South Dakota [web page].
Retrieved 24 Oct 2011 from http://puc.sd.gov/energy/Wind/default.aspx.

Wind Resource Assessment Network, South Dakota [web page]. Retrieved 1 J ul 2011 from
www.sdwind.com/.

Data collected by Marley Ward, 1 J ul 2011, Deborah Luyo, 24 Oct 2011.
Reviewed by Brian Rounds, 1 Dec 2011.

Tennessee A-90

State: Tennessee

Wind siting basics: Wind siting is done at the local level of government. The applicant could apply to the
Tennessee Department of Economic and Community Development (TECD) for energy facilities that will
produce over 50 MW.


Approvals needed: TECD will find information regarding economic need and transmission. If the
application meets TECD approval, it is then forwarded to the Tennessee Department of Environment &
Conservation for environmental permitting. Tennessee is a Home Rule state.




Contacts:

Katie Stokes
Southern Alliance for Clean Energy
(865) 637-6055 ext. 22
Katie@cleanenergy.org

Vivian Michael-Wilhoite, Outreach Coordinator
Tennessee Regulatory Authority
460 J ames Robertson Parkway
Nashville, TN 37243
vivian.michael-wilhoite@tn.gov



Tennessee Department of Economic and Community Development [web page]. Retrieved 6 J ul 2011
from www.tn.gov/ecd/.

Tennessee Regulatory Authority, Utility Division [web page]. Retrieved 6 J ul 2011 from
www.tn.gov/tra/utility.html.

Tennessee Valley Authority. Green Switch [web page]. Retrieved 6 J ul 2011 from
www.tva.gov/greenpowerswitch/.

Tennessee Valley Authority. Wind Turbine Energy [web page]. Retrieved 6 J ul 2011 from
www.tva.gov/greenpowerswitch/wind_faq.htm.

Data collected by Francis Motycka, 6, 11 J ul 2011.
A-91 Texas

State: Texas

Wind siting basics: All siting authority is delegated to the local governments. If asked, the Texas Parks
and Wildlife Department will review projects for compliance with wildlife protection guidelines. The
Texas PUC has some indirect authority (see discussion of transmission below).

History of siting authority: 2007 Statute regarding Competitive Renewable Energy Zones:
www.statutes.legis.state.tx.us/Docs/UT/htm/UT.39.htm#39.904.

Title 7. Regulation Of Land Use, Structures, Business, and Related Activities (1987)
(www.statutes.legis.state.tx.us/Docs/LG/htm/LG.231.htm)

Approvals needed: No approval is needed from anyone, except leases with landowners; however, wind
developments are subject to federal and state laws protecting endangered species. Applicants can request
a review from the Texas Parks and Wildlife Department. The Departments findings are not binding
(Boydston, 2011). Applicants can ask the county comptroller for a property tax abatement, based on the
jobs and general economic benefits expected. The county board can deny the property tax abatement if
there is public opposition.

Most projects take about 18 months to begin commercial operation, and few projects take longer than two
years (Boydston, Kathy, Texas Parks and Wildlife Department, personal communication, 24 J un 2011).

Evaluation criteria: Although there are no officially required criteria, developers often conduct pre-
construction wildlife surveys.


Relationships to other important energy policies or siting and zoning decisions: Competitive
Renewable Energy Zone (CREZ) legislation passed in 2007. The Texas PUC designates CREZs, which
allow construction of transmission lines to serve the zone, prior to the commercial operation of new
renewable energy generators. In this way, the Texas PUC has indirect siting authority.

Contacts:

Kathy Boydston
Texas Parks and Wildlife Department
(512) 389-4638
kathy.boydston@tpwd.state.tx.us

Thomas Gleeson, Project Manager
Public Utility Commission of Texas
William B. Travis Building
1701 N. Congress Avenue
Austin, TX 78701
thomas.gleeson@puc.state.tx.us

Lindsey Hughes, Associate Director
Wind coalition
(512) 651-0291
Lindsey@WindCoalition.org

Texas A-92



Hurlbut, David. (22 J un 2009). Competitive Renewable Energy Zones in Texas. National Renewable
Energy Laboratory. www.dora.state.co.us/puc/DocketsDecisions/DocketFilings/08I-227E/08I-
227E_NREL06-15-09CompetitiveRenewableZones.ppt.

Public Utility Commission of Texas. PUCT CREZ Home Page [web page]. Retrieved 29 Oct 2011
from www.texascrezprojects.com/default.aspx.


Texas Comptroller of Public Accounts. (May 2008). The Energy Report.
www.window.state.tx.us/specialrpt/energy/pdf/11-WindEnergy.pdf.

Data collected by Lauren Teixeira, 24 J un 2011, Deborah Luyo, 29 Oct 2011.
Reviewed by Brian Almon, 8 Nov 2011.
A-93 Utah

State: Utah

Wind siting basics: Wind siting is done at the local level of government. Utah does not have a state
agency with sole authority over electric plant siting. The developer must contact the various agencies that
could have responsibility. Those agencies will determine what approvals are required (Stemler, 2007).
Utah is a Home Rule state.

History of siting authority: UTAH CODE TITLE 541-1 PUBLIC SERVICE COMMISSION
Establishment of Commission Functions (1983),
http://le.utah.gov/~code/TITLE54/htm/54_01_000100.htm.

UTAH CODE TITLE 54-4a-1 DIVISION OF PUBLIC UTILITIES Establishment of Division
Functions (1989), http://le.utah.gov/~code/TITLE54/htm/54_04a000100.htm.

UTAH CODE TITLE 79-2-201 DEPARTMENT OF NATURAL RESOURCES Department of
Natural Resources Created, http://le.utah.gov/~code/TITLE79/htm/79_02_020100.htm.

UTAH CODE TITLE 23-14-1 DIVISION OF WILDLIFE RESOURCES AND WILDLIFE BOARD
Division of Wildlife Resources Creation General Powers and Duties Limits on Authority of
Political Subdivisions (1995), http://le.utah.gov/~code/TITLE23/htm/23_14_000100.htm.

Approvals needed: A Certificate of Public Convenience and Necessity from the Utah Public Service
Commission is required for new generation facilities. Developers should also contact the Utah Division of
Public Utilities, the Utah Department of Natural Resources, and the Utah Division of Wildlife.

If the project includes facilities on or near lands that are under the jurisdiction of the federal Bureau of
Land Management (BLM), an application must be submitted to the BLM. (United States Department of
the Interior, Bureau of Land Management, 2008).

Evaluation criteria: Utahs Model Wind Ordinance (2009) lists:

Climb prevention and locks
Decommissioning
Height and blade height (clearance above the ground)
Lighting
Maintenance
Minimum property setbacks (110% of the height of the system from all inhabited structures,
overhead utility lines, and public roads or public right-of-ways; 4.1.2)
Sound levels (compliance with the existing noise or sound ordinance; 4.1.9)
Visual appearance of wind turbines and related infrastructure


Relationships to other important energy policies or siting and zoning decisions: The Energy Resource
and Carbon Emissions Reduction Initiative was passed into law in 2008, with a goal of 20% electricity
generated from renewable sources by 2025. The first compliance year will be 2025.

Utah A-94

Pending issues: On 23 Mar 2011 the Utah Association of Counties and the Uintah County Commission
filed a lawsuit (United States Department of the Interior) against Ken Salazar, Secretary of the Interior, et
al., in response to Secretarial Order 3310, declaring 385,000 acres of Uintah County land wild lands
territory (The Secretary of the Interior, 2010). The declaration will expand the power of the Bureau of
Land Management in control of public land and would place additional restrictions on the potential for
wind development.

Contacts:

Chris Tallackson
Office of Energy Development
195 N 1950 West, 2nd Floor
Salt Lake City, UT 84116
Phone: (801) 536-4280
http://geology.utah.gov/sep/
ctallackson@utah.gov

Denise Brems
Utah State Energy Program Parner Coordinator
Utah Geological Survey
dbeaudoin@Utah.gov


Edison Electric Institute. (2004). State Generation & Transmission Siting Directory: Agencies,
Contacts, and Regulations.
www.eei.org/ourissues/ElectricityTransmission/Documents/State_Generation_Transmission_Siting_Directory.pdf.

ODonoghue, Amy J oi. (23 Mar 2011). Utah Groups Launch Challenge to Salazars Wild Lands
Policy, Deseret News. www.deseretnews.com/article/705369255/Utah-groups-launch-challenge-
to-Salazars-wild-lands-policy.html.

Stemler, J ody. (Oct 2007). Wind Power Siting, Incentives, and Wildlife Guidelines in the United
States.

The Secretary of the Interior. (22 Dec 2010). Secretarial Order 3310.
www.blm.gov/pgdata/etc/medialib/blm/wo/Communications_Directorate/public_affairs/news_rel
ease_attachments.Par.26564.File.dat/sec_order_3310.pdf.

United States Department of the Interior Bureau of Land Management. (19 Dec 2008). Wind Energy
Development Policy.
www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/national_instruction/2
009/IM_2009-043.html.

United States District Court District of Utah, Central Division. (22 Mar 2011). Plaintiffs First
Amended and Supplemental Complaint for Declaratory, Mandatory and Injunctive Relief.
www.eenews.net/assets/2011/03/23/document_gw_01.pdf.

Utah Clean Energy. Wind Zoning & Ordinances [web page]. Retrieved 6 J ul 2011 from
http://utahcleanenergy.org/our_work/utah_wind_power_campaign/zoning.

A-95 Utah

Utah Geological Survey. Utah Wind Working Group [web page]. Retrieved 6 J ul 2011 from
http://geology.utah.gov/sep/wind/uwwg/index.htm.

Utah State Energy Program. (2009). Utah Model Wind Ordinance.
http://geology.utah.gov/sep/wind/pdf/model_wind_ordinance.pdf.

Data collected by Francis Motycka, 6, 11 J ul 2011; Deborah Luyo, 21 Oct 2011.
Vermont A-96

State Name: Vermont

Wind siting basics: The Vermont Public Service Board (PSB) issues a Certificate of Public Good (CPG)
for all wind facilities, with the exception of those operated solely for the customers on-site consumption.
Net metering systems do require a CPG. The Vermont Department of Public Service (DPS), which
represents ratepayers in PSB proceedings, and the Vermont Agency of Natural Resources (ANR) are
automatic parties to any proceeding.

History of siting authority:
30 V.S.A. 248 www.leg.state.vt.us/statutes/fullsection.cfm?Title=30&Chapter=005&Section=00248
PSB Rule 5.400
http://psb.vermont.gov/sites/psb/files/rules/OfficialAdoptedRules/5400_248_Requirements.pdf

Approvals needed: The PSB regulates all grid-connected wind developments and must find that the
facility will promote the general good of the state before it can issue a CPG. In addition, the Vermont
Agency of Natural Resources (ANR) has independent jurisdiction over certain permits that may be
required by the facility; these may include permits involving the facilitys impact on wetlands and water
quality.

Local permits are not required; however, the PSB is required to give due consideration to the
recommendations of municipal and regional planning organizations as well as the recommendations of
municipal legislative bodies.

Evaluation criteria: Pursuant to statute, the PSB must find that the facility meets certain criteria. These
include whether the project will:

1. adversely affect system stability and reliability;
2. provide an economic benefit to the state; and
3. have an undue adverse impact on natural resources and aesthetics.

In analyzing the projects impacts on natural resources, developers often provide information regarding:

(1) Radar and acoustical surveys to develop an understanding of bird and bat activity and migration
characteristics
(2) Evaluation of the presence of rare, threatened, and endangered species and associated habitat(s)
(3) Analysis of suitable habitat for endangered bat species
(4) Resident avian and breeding survey
(5) Necessary wildlife habitat surveys
(6) Delineation of habitats that may be especially vulnerable

ANR requests that developers follow specific voluntary procedures in accordance with ANR guidelines,
including:

(1) Completion of pre-construction survey
(2) Site development recommendations
(3) Consultation with wildlife agency, USFWS
(4) Mitigation requirements
(5) Post-construction/operational surveys
(6) Decommissioning procedures

A-97 Vermont

Public Input: With the exception of net metered projects, and projects of limited size and scope, all PSB
siting proceedings involve a public hearing in the county in which the facility is located. In addition, the
deadline for intervention requests is typically after the public hearing in order to allow members of the
public that meet the PSBs standards for intervention to participate in the proceeding.

Relationships to other important energy policies or siting and zoning decisions: Vermont has a state-
wide voluntary renewable goal of 20% by 2017. 30 V.S.A. 8005(d)(2).
http://www.leg.state.vt.us/statutes/fullsection.cfm?Title=30&Chapter=089&Section=08005

Pending issues: On 3 Oct 2011 the PSB recommended an RPS of 75% by 2034
(http://psb.vermont.gov/sites/psb/files/publications/Reports%20to%20legislature/RPSreport2011/Study%
20on%20Renewable%20Electricity%20Requirements%20-%20Final.pdf).

Contacts:

J eannine McCrumb
Vermont Agency of Natural Resources
(802) 241-3691
jeannine.mccrumb@state.vt.us

Ed McNamara
Vermont Public Service Board
112 State Street, Drawer 20
Montpelier, VT 05620-2701
(802) 828-2358
http://psb.vermont.gov/
ed.mcnamara@state.vt.us


Database of State Incentives for Renewables & Efficiency, Vermont Incentives/Policies for
Renewables & Efficiency [web page]. Retrieved 6 Aug 2011 from
www.dsireusa.org/incentives/index.cfm?State=VT.


U.S. Department of Energy. Vermont Wind Activities [web page]. Retrieved 6 Aug 2011 from
www.windpoweringamerica.gov/astate_template.asp?stateab=vt.

Vermont Agency of Natural Resources. (20 Apr 2006). Guidelines for the Review and Evaluation of
Potential Natural Resources Impacts from Utility-Scale Wind Energy Facilities in Vermont.
www.anr.state.vt.us/site/html/plan/DraftWindGuidelines.pdf.

Vermont Agency of Natural Resources. (Dec 2004). Wind Energy and Other Renewable Energy
Development on ANR Lands. www.vtfpr.org/lands/documents/windpower.pdf/.

Data collected by Kai Goldynia, 6 Aug 2011.
Reviewed by Ed McNamara, 24 J an 2012.
Virginia A-98

State: Virginia

Wind siting basics: Siting for renewable energy projects is conducted under the authority of local
government. The permitting program for construction and operation of renewable energy projects is
administered at the state level by the Virginia Department of Environment Quality (DEQ), which
explicitly considers the impacts of the project on natural resources (in particular, on wildlife and historical
resources).

The Virginia Department of Environmental Quality permits small renewable energy projects up to
100 MW (https://leg1.state.va.us/cgi-bin/legp504.exe?091+ful+CHAP0808). The State Corporation
Commission (SCC) has siting authority for energy facilities over 100 MW, constructed by rate-regulated
utilities (1999, as amended) ( https://leg1.state.va.us/cgi-bin/legp504.exe?000+cod+56-580).

History of siting authority: Codeof Virginia: Chapter 11.1 of Title 10.1, Article 5, sections 10.1-1197.5
through 10.1-1197.11 (https://leg1.state.va.us/cgi-bin/legp504.exe?091+ful+CHAP0808). Previously,
authority over wildlife and historic resources resided with the SCC. This authority was transferred to the
DEQ in 2009 for small renewable energy projects.

Approvals needed: A special use permit or zoning approval comes from the local government. Virginia
is a Dillons Rule state.

Among the Virginia counties that have enacted wind ordinances are Pulaski County and Rockingham
County, which are inland, and Northampton, located on the coast.

Article 26, the Pulaski County Draft Wind Ordinance,
www.pulaskicounty.org/planning/minutes%20and%20agendas/2010/08-10-10%20minutes.pdf

Ordinance Repealing and Re-enacting Certain Designated Definitions Section 17-6 and 17-6.2 of the
Code of Ordinances of Rockingham County Virginia,
www.preserverockingham.org/images/Wind_Energy_Conversion_System_Draft_Oct_8_2010_Changes_Accepted.pdf

Draft revised to incorporate Planning Commission Recommendations of August 2, 2011
& Board of Supervisors Intended Recommendations of August 18, 2011,
www.co.northampton.va.us/departments/pdf/Wind%20Tower%20draft%20%20incl%20PC%20recs
%208-2-11%20and%20BOS%208-18-11%20edits%20_2_.pdf.

Code of Virginia: Title 10.1, Chapter 11.1, Article 5 (2009), vests authority in the Virginia Department of
Environmental Quality for permitting a small renewable energy project, defined as having a rated
capacity not exceeding 100 megawatts .

Mitigation authority, under the DEQ process, is limited to wildlife and historic resources. Specific
wildlife considerations include the effects of wind development on threatened and endangered species,
bats, coastal avian protection zones, and sea turtle nesting beaches.

Evaluation criteria: As prerequisites to the renewable energy permit-by-rule application to the DEQ, 14
statutory requirements (from https://leg1.state.va.us/cgi-bin/legp504.exe?091+ful+CHAP0808) must be
met:

1. A notice of intentto submit the necessary documentation for a permit by rule for a small
renewable energy project;
2. A certification by the [local] governing body[ies] that the project complies with all applicable
land-use ordinances;

A-99 Virginia

3. Copies of all [electric grid] interconnection studies;
4. A copy of the final interconnection agreement ;
5. A certification that the maximum generation capacity does not exceed 100 megawatts;
6. An analysis of potential environmental impacts on attainment of national ambient air quality
standards;
7. Where relevant, an analysis of the beneficial and adverse impacts on natural resources;
8. If the Department determines that significant adverse impacts to wildlife or historic resources
are likely, the submission of a mitigation planincluding plans to measure the efficacy of
mitigation actions;
9. A certification [that the design is] in accordance with all of the standards that are established in
the regulations applicable;
10. An operating plan describing how any standards will be achieved;
11. A detailed site plan with project location maps;
12. all necessary environmental permits;
13. A requirement that the applicant hold a public meeting; and
14. A 30-day public review and comment period.

The process by which DEQs wind permit-by-rule regulations were developed involved 22 Regulatory
Advisory Panel meetings, 2 public comment periods, 1 public hearing, and 1 public meeting.
(http://vwec.cisat.jmu.edu/workshop/Presentations/Wampler%20-%20Navigating%20Wind%20PBR.pdf)

Criteria common to the three county ordinances cited above include:

Wind turbines must be of a non-obtrusive color
Wind energy systems cannot display advertising
Wind energy systems cannot be artificially lit unless required by the FAA
Audible sound cannot exceed 55-60 decibels
Setback requirements
Height restrictions


Relationships to other important energy policies or siting and zoning decisions: Virginia has a
voluntary Renewable Portfolio goal for 15% of electricity to come from renewable energy sources by
2025. Yearly percentage goals are formulated with 2007 as the base year upon which future years are
calculated. To help facilitate these goals, the SCC provides an increased rate of return for participating
utilities that meet the requirements. Onshore wind production credits are doubled for compliance purposes
(www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=VA10R&re=1&ee=1).

Pending issues: A model wind ordinance is under consideration by an informal Local Government
Outreach Stakeholder Group, which includes professionals from state and local government, academia,
environmental groups, and industry. A suggested model ordinance is expected by year end 2011. (Contact
Carol Wampler, Department of Environmental Quality.)

Research issues: The DEQ would like to know more about the impact of wind turbines on bats, avian
species, other wildlife, and historic resources. Research is ongoing.

Virginia A-100

Contacts:

Greg Abbott
Virginia State Corporation Commission
Division of Energy Regulation
1300 East Main Street
Richmond, VA 23219
(804) 371-9611
Greg.Abbott@scc.virginia.gov

Carol Wampler
Renewable Energy Policy Manager
Department of Environmental Quality
629 East Main Street
Richmond, Virginia 23219
804-698-4579
carol.wampler@deq.virginia.gov

Larry Land
Director of Policy Development
Virginia Association of Counties
1207 East Main Street, Suite 300
Richmond, Virginia 23219-3627
804-788-6652
lland@vaco.org


Bradley, Gloria. (15 Oct 2011). Wind tests, new jobs are coming to county, delmarvaNOW!com.
www.delmarvanow.com/article/20111015/ESN01/110150301.

Virginia Department of Environmental Quality [web page]. Retrieved 26 J un 2011 from
www.deq.virginia.gov/.

Virginia State Corporation Commission [web page]. Retrieved 17 Oct 2011 from
www.scc.virginia.gov/.

Virginia Wind Energy Collaborative [web page]. Retrieved 26 J un 2011 from
http://vwec.cisat.jmu.edu/.

Wampler, Carol. (16 J une 2010). Navigating DEQs Wind Energy Permit by Rule.
http://vwec.cisat.jmu.edu/workshop/Presentations/Wampler%20-
%20Navigating%20Wind%20PBR.pdf.

Data collected by Francis Motycka, 6 Jun, 3, 12 J ul 2011; Deborah Luyo, 14 Oct 2011.
Reviewed by Carol Wampler, 18 Nov 2011.
A-101 Washington

State: Washington

Wind siting basics: Review by the Energy Facility Site Evaluation Council (EFSEC) is available for
proposed wind power projects, but applicants must opt in to EFSECs process. Most existing wind
projects have been permitted through counties.

History of siting authority: Revised Code of Washington (RCW) 80.50. 040 (1970, 2001)
(http://apps.leg.wa.gov/rcw/default.aspx?cite=80.50.040)

Approvals needed: From the EFSEC website:

The EFSEC certification process was designed to give applicants an opportunity to present their
proposals, allow interested parties to express their concerns to the Council, and have the Council to [sic]
address issues related to the application.
There are six major steps in the certification process:
I. Application Submittal
II. Application Review
III. Initial public hearings
IV. Environmental impact statement
V. Adjudicative proceedings and permits review
VI. Recommendation to the Governor

Each step has specific requirements the applicant and the Council must follow to ensure a comprehensive
and balanced review of the project. Many of the steps take place at the same time.
(www.efsec.wa.gov/cert.shtml#Certification2).
Applicants who qualify, as determined by the Council, can undergo an expedited process. The Council
has four months to evaluate the application to determine whether to grant expedited processing. The
Council has an additional two months to forward a recommendation of approval to the governor. This
schedule may be modified as mutually agreed to by the applicant and the Council.
Evaluation criteria: Criteria used by the Department of Fish and Wildlife include:

(1) Baseline and Monitoring Studies: Calls for pre-project assessments of wind power sites with the
goal of avoiding and minimizing bird and bat impacts related to wind turbines; information review;
habitat mapping; bird and bat surveys, and threatened and endangered species surveys.
(2) Minimization of Wildlife Impacts: Outlines the path for avoiding and minimizing potential
impacts related to construction methods and sensitive habitat areas.
(3) Operational Monitoring: Details the post-construction monitoring recommendations and the role
of the Technical Advisory Committee (TAC), which is recommended for the purpose of providing
advice to the project owner and the permitting authority. Members of the TAC can include wind
project owners and developers, landowners, and representatives from environmental groups, counties,
tribes, and state and federal resources agencies.
(4) Research-oriented Studies: Offers recommendations and examples for research needs related to
wind power development as it relates to wildlife habitats and species.
(5) Habitat Types and Mitigation: Provides statewide ecoregional definitions of habitat types
throughout Washington State; encourages development into previously disturbed and developed areas
and away from undeveloped fish and wildlife habitat; provides ratios for replacement habitat as
mitigation for temporary and permanent wind project impacts; adheres to the principle of no loss of
habitat functions and values. (http://wdfw.wa.gov/conservation/habitat/planning/energy/wind.html)

Washington A-102

Public input: State regulations provide opportunities for public input at several points during the
licensing process.

Relationships to other important energy and siting/zoning decisions: EFSEC is statutorily authorized
to preempt local land-use/zoning ordinances for the siting of energy projects.

Contacts:

Steve J ohnson
Washington Utilities and Transportation Commission
1300 South Evergreen Park Drive, SW
P.O. Box 47250
Olympia, WA 98504-7250
(360) 664-1346
www.utc.wa.gov
sjohnson@utc.wa.gov

Travis Nelson
Renewable Energy Policy
Washington Department of Fish & Wildlife
Travis.Nelson@dfw.wa.gov

Washington State Department of Commerce
State Energy Office
1011 Plum Street SE
P.O. Box 42525
Olympia, WA 98504-2525
(360) 725-3118
www.commerce.wa.gov


Washington Department of Fish and Wildlife. (Apr 2009). Washington Department of Fish and
Wildlife Wind Power Guidelines. http://wdfw.wa.gov/publications/00294/wdfw00294.pdf

Leta Liou, Suzanne. (28 Oct 2008). Wind Siting Guidelines in Oregon and Washington.
http://old.nationalwind.org/pdf/LetaLiouSuzanne.pdf.

Reviewed by Meg OLeary, 14 Dec 2011.
A-103 West Virginia

State: West Virginia

Wind siting basics: The Public Service Commission (PSC) has sole authority of all public utility siting.

History of siting authority: West Virginia Code 24-2-1 (1991)
(www.legis.state.wv.us/WVCODE/Code.cfm?chap=24&art=2#02).

Approvals needed: Developers of wind generation that will produce electricity for sale in wholesale
markets need a certificate of public convenience and necessity from the PSC (West Virginia Code 24-2-
11, www.legis.state.wv.us/WVCODE/ChapterEntire.cfm?chap=24&art=2&section=11#02). West
Virginia is a Dillons Rule state.

An applicant must give the PSC a 30-day notice before filing an application for the certificate of public
convenience and necessity. After an application is filed, the PSC will either issue or deny the certificate
within 270 days. If the projected cost is over $50 million, the PSC will issue or deny the certificate within
400 days.



Relationships to other important energy policies or siting and zoning decisions: West Virginias
Renewable Portfolio Standard (RPS) mandates that utility companies with more than 30,000 residential
consumers must have at least 25% of their energy from alternative and renewable sources by 2025, with
no minimum requirement from renewable sources. Alternative energy credits (AEPs) are used for
compliance. Each megawatt-hour of renewable energy (wind) is equal to two AEP credits. Utility
companies must have submitted their compliance strategies to the West Virginia PSC by 1 J an 2011,
followed by annual compliance reports. The PSC will impose penalties for utilities not in compliance on
1 J an 2015 (www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=WV05R&re=1&ee=1).

Pending issues: The Cow Knob Wind Farm is a proposed project in Pendleton County. Solaya Energy
LLC has requested that Pendleton County create an ordinance to help facilitate wind facility construction
(Adams, 2011).

Research issues: The Beech Ridge Wind Farm in Greenbrier County is currently shutting down its
turbines at night, from 1 Apr to 15 Nov, because of concerns over potential harm to the Indiana bat, an
endangered species. The developer faces a lawsuit on claims that it did not obtain a permit from the U.S.
Fish and Wildlife Service when siting this facility (Hammack, 2011).

Contacts:

Patrick Mann
West Virginia Wind Working Group
Bureau of Business and Economic Research
West Virginia University
(304) 599-2641
Patrick.mann@mail.wvu.edu

West Virginia A-104

J eff Herholdt
West Virginia Division of Energy
Bldg. 6, Room 553
State Capitol Complex
Charleston, WV 25305-0311
(304) 558-2234
www.energywv.org
jherholdt@energywv.org


Adams, Anne. (23 J un 2011). Pendleton Asked to Create Wind Energy Ordinance: New Project
Would Straddle Va.-W.Va State Line, The Recorder.
www.wind-watch.org/news/2011/06/23/pendleton-asked-to-create-wind-energy-ordinance-new-
project-would-straddle-va-w-va-state-line/.

Hammack, Laurence. (12 J un 2011). Opposing Winds, The Roanoke Times.
www.roanoke.com/news/roanoke/wb/289595.

Mountain Communities for Responsible Energy [web page]. Retrieved 12 J ul 2011 from
www.wvmcre.org/.

West Virginia Division of Natural Resources [web page]. Retrieved 12 J ul 2011 from
www.wvdnr.gov/.

West Virginia Public Service Commission (PSC) [web page]. Retrieved 12 J ul 2011 from
www.psc.state.wv.us/.

Data collected by Francis Motycka, 6, 11, 12 J ul 2011.
Reviewed by Earl Melton, 10 Oct 2011.
A-105 Wisconsin

State: Wisconsin

Wind siting basics: Power plants with a capacity of 100 MW or more must have a Certificate of Public
Convenience and Necessity (CPCN) from the Public Service Commission of Wisconsin (PSCW) prior to
construction. Projects having less than 100 MW capacity may require a Certificate of Authority (CA)
from the PSCW.

History of siting authority: In 2009, Wisconsin Act 40 (Wisc. Stat. 196.378(4g)(b))
directed the PSCW to establish statewide wind energy siting rules
(http://psc.wi.gov/renewables/windSitingRules.htm). The new law required the PSCW to appoint a Wind
Siting Council, to advise the PSCW in developing its standards
(http://psc.wi.gov/renewables/windSitingCouncil.htm). The Act also provided that local government wind
siting ordinances could not be more restrictive than the PSCW rules. The Act dictated that the rules were
to include:

setback requirements that provide reasonable protection from any health effects, including health
effects from noise and shadow flicker decommissioning and may include visual appearance,
lighting, electrical connections to the power grid, setback distances, maximum audible sound
levels, shadow flicker, proper means of measuring noise, interference with radio, telephone, or
television signals, or other matters.

(See https://docs.legis.wisconsin.gov/statutes/statutes/196/378/4g/b and
https://docs.legis.wisconsin.gov/statutes/statutes/66/IV/0401).

In March 2011, before the Councils proposed rules could take effect, the state legislatures J oint
Committee for the Review of Administrative Rules suspended the rules indefinitely. (See
http://psc.wi.gov/apps35/ERF_view/viewdoc.aspx?docid=145834).

Approvals needed: The PSCW and the Wisconsin Environmental Policy Act require that applicants
provide information on at least two sites. The PSCW then prepares an environmental impact statement, in
conjunction with the Wisconsin Department of Natural Resources (WDNR), or an environmental
assessment.

Developers must submit an engineering plan to the Wisconsin Department of Natural Resources (DNR) at
least 60 days prior to filing an application for a CPCN.


Pending issues: How and when the legislature will act on the WPSC proposed rules.

Relationships to other important energy and siting and zoning policies: Wisconsin has a wind (and
solar) access law, which protects a right to wind access, via local land-use easement, if the land owner
installs a wind generator.

To assist counties, towns, and municipalities in interpreting Wisconsin's wind access laws, chiefly Wis.
Stat. 66.0401, the state developed a Model Small Wind Ordinance which suggests appropriate zoning
language for wind energy systems of 100 kilowatts (kW) or less.
(http://dsireusa.org/incentives/incentive.cfm?Incentive_Code=WI16R&re=1&ee=1).

Wisconsin A-106

Contacts:

Scot Cullen, Chief Electric Engineer
Public Service Commission of Wisconsin
610 North Whitney Way
P.O. Box 7854
Madison, WI 53707-7854
(608) 267-9229
Scot.Cullen@wisconsin.gov

Deborah Erwin
Public Service Commission of Wisconsin
610 North Whitney Way
P.O. Box 7854
Madison, WI 53707-7854
(608) 266-3905
Deborah.Erwin@wisconsin.gov


Barbour, Clay. (9 Oct 2011). Wind siting rules still stuck in limbo, Wisconsin State Journal,
http://host.madison.com/wsj/news/local/environment/article_31b4855d-a73f-52cb-a0a6-0dad9ff84bcf.html.

Database of State Incentives for Renewables & Efficiency. (9 Mar 2011). Wisconsin - Wind Siting
Rules and Model Small Wind Ordinance [web page]. Retrieved 20 Oct 2011 from
http://dsireusa.org/incentives/incentive.cfm?Incentive_Code=WI16R&re=1&ee=1.

Public Service Commission of Wisconsin. Wind Siting Council [web page]. Retrieved 20 Oct 2011
from http://psc.wi.gov/renewables/windSitingCouncil.htm.

Public Service Commission of Wisconsin. Wind Siting Rules [web page]. Retrieved 20 Oct 2011 from
http://psc.wi.gov/renewables/windSitingRules.htm.

RENEW Wisconsin. Wisconsin Wind Policy [web page]. Retrieved 24 J un 2011 from
www.wiwindinfo.net/policy/siting.html.

Data gathered by Kai Goldynia, 24 J un 2011; Tom Stanton, 20 Oct 2011.
A-107 Wyoming

State: Wyoming

Wind siting basics: Under Wyoming law, all wind energy facilities with a capacity greater than 0.5 MW
(500 kW) must obtain county permits. Facilities with 30 or more turbines must, in addition, obtain a
permit from the Wyoming Industrial Siting Council (part of the state Department of Environmental
Quality). Any application for a project that does not meet the statutory definition of a facility can be
referred to the Industrial Siting Council, consistent with the requirements of the Industrial Development
Information and Siting Act. No county may adopt wind siting laws less stringent than those of the state. If
any part of the proposed project is to occupy federal lands, the applicant must also obtain a permit from
the federal Bureau of Land Management (BLM).

History of siting authority: Wyoming Statutes 18-5-501 to 18-5-509 are the most relevant (Wyoming
Legislature).

Approvals needed: A permit from the Industrial Siting Council may be required for proposed facilities
with less than 30 turbines if the county authority finds that a proposed facility poses certain significant
environmental or societal risks that the county does not feel qualified to assess.

Procedures for application include:

(1) Developer must submit application to the County Board of Commissioners
Notifications
Applicant must have made reasonable efforts to provide notice to all owners of land
within one mile of the facility and to all cities and towns located within 20 miles of the
facility.
Applicant must publish a notice of application in a widely circulated newspaper at least
20 days prior to a public hearing.
(2) The board will conduct a review to determine whether the application is complete.
(3) Within 45 days after completion of the hearing period, the Board shall make complete findings
and issue its decision granting or denying the application.
(4) Any party can file an appeal in district court. The decision issued in the appeal is considered final.
(5) If the facility does not automatically fall under the Industrial Siting Council, the County Board
may refer the applicant to the Industrial Siting Council for further permitting.

Evaluation Criteria: Environmental approval is part of a collaborative review process in which the
Industrial Siting Council asks for input on environmental standards from the Wyoming Fish and Game
Department. The Council has the authority to require wildlife mitigation measures.

Various other standards must be met and certified in the application:

Setbacks
A turbine must be sited at least 110% of its height from any property line contiguous or
adjacent to the proposed facility, unless the property owner waives the setback distance in
writing.
A turbine must be sited at least 110% of its height from public roads.
A turbine must be 550% of its height and no fewer than 1000 feet away from platted
subdivisions.
A turbine must be 550% of its height and no fewer than 1000 feet away from a residential
dwelling.
A turbine must be at least a half mile from city limits.

Wyoming A-108

Other criteria:
Must have an emergency management plan.
Must have a waste management plan (including decommissioning).
Must conduct a traffic study of any public roadways leading to and away from the proposed
facility. (Applicant can be required to enter into reasonable road use agreements.)
There can be no advertising on the facility, with the exception of the applicants logo on the
nacelle.
Must have a reclamation and decommissioning plan that indicates the planned life of the
wind energy facility.
Must certify that the landowners have been consulted.
The decommissioning/reclamation plan must be updated every five years.

Public input: Once the application is determined to be complete, the Board must provide notice of the
date and time of completion of the hearing period. The public hearing period is no fewer than 45 days and
no more than 60 days after the application has been determined to be complete.

Relationships to other important energy policies or siting and zoning decisions: Wyoming statutory
law requires that applicants proposing to build a wind energy facility include in their application a
project plan indicating proposed roadways, tower locations and substation locations, transmission,
collector and gathering and lines, and other ancillary facility components
(http://legisweb.state.wy.us/statutes/statutes.aspx?file=titles/Title18/T18CH5AR5.htm)

Research issues: Wyoming is home to over half of all sage grouse, an endangered species, in the United
States. Conservationists have expressed concern that wind development and the building of ancillary
transmission lines will harm the sage grouse. Horizon Wind, a developer, has called for peer-reviewed
study to establish the impact of turbines on the sage grouse. The United States Bureau of Land
Management (BLM) has announced its intention to include sage grouse conservation measures in land
management plans in Wyoming and nine other western states, including Colorado, North Dakota, South
Dakota, Utah, Montana, California, Idaho, Nevada, and Oregon
(www.blm.gov/wo/st/en/info/newsroom/2011/december/NR_12_08_2011.html).

In an effort to protect the sage grouse, there has been a movement by conservationists, supported by the
governor, to draw up core areas in Wyoming where no energy development, agriculture, or recreation
will be allowed. According to state government estimates, the proposed areas include only 14% of
Wyomings windy land. (Stoddard, 2009).

In an effort by the Federal Bureau of Land Management to facilitate development of renewable energy
sources on public lands, the Wyoming Wind and Transmission Study is being conducted to analyze
Wyomings wind resources in order to identify potential sites for wind power development. The study is
expected to be completed within approximately three years.

Contacts:

Cindy DeLancey
Wyoming County Commissioners Association
Post Office Box 86
409 W. 24
th
Street
Cheyenne, WY 82003
(307) 632-5409
cdelancey@wyo-wcca.org

A-109 Wyoming

Todd Parfitt
Administrator
Industrial Siting Division
Wyoming Department of Environmental Quality
307-777-7555
Todd.parfitt@wyo.gov
http://deq.state.wy.us/isd/


Bleizeffer, Dustin. (17 Oct 2010). Against the wind?: Tax policy may be hurting Wyoming
industry, Billings Gazette. http://billingsgazette.com/news/state-and-
regional/wyoming/article_ef9c8ee6-d9b6-11df-9982-001cc4c03286.html.


Herrera, Adam. (15 J un 2011). Wasatch Wind gains permit from ISC, Douglas Budget.
www.douglas-budget.com/news/article_fb5ba3f6-9780-11e0-8860-001cc4c03286.html.

Morton, Tom. (1 Mar 2010). Utah company seeks OK from BLM for wind farm, Billings Gazette.
http://billingsgazette.com/news/state-and-regional/wyoming/article_f1b33494-25b3-11df-b3bb-
001cc4c002e0.html.


Stoddard, Ed. (3 Aug 2009). Sage grouse unlikely focus of Wyoming wind wars, Reuters.
www.reuters.com/article/2009/08/03/us-usa-windpower-habitat-idUSTRE5720AF20090803.

Thompson, J onathan. (21 Dec 2009).Wind Resistance, High Country News.
www.hcn.org/issues/41.22/the-messy-mix-of-energy-and-sage-grouse.

Wyoming Department of Environmental Quality. Industrial Siting [web page]. Retrieved 5 J ul 2011
from http://deq.state.wy.us/isd/.

Wyoming Legislature. Article 5 Wind Energy Facilities, Statutes 18-5-501 to 18-5-509.
http://legisweb.state.wy.us/statutes/statutes.aspx?file=titles/Title18/T18CH5AR5.htm.

Data collected by Lauren Teixeira, 5 J ul 2011.

REVIEW OF STATE REGULATIONS

December 16, 2013

The Connecticut Conference of Municipalities (CCM) is Connecticuts statewide association of
towns and cities and the voice of local government - your partners in governing Connecticut. Our
members represent over 95% of Connecticuts population.

We appreciate the opportunity to provide comments regarding obsolete and burdensome
regulations to towns and cities. The following regulations are among those that local officials
have stated should be amended or repealed:

Department of Administrative Services Division of Construction Services
Amend Section 29-292-7e of the State Fire Safety Code to relieve local fire marshals
from having to inspect every three-family dwelling each year. Fire Marshals from the
States larger cities have stated that annual inspection of these properties is too
burdensome, and in some cases where an illegal third family apartment is located, it
exposes local officials to added liability if not inspected. Municipalities do not have the
staff to perform this state mandate.

Update the State Building Code as they relate to newer building standards to identify
potential efficiencies for municipalities by updating the state building.

Department of Education
Amend Sections 10-145d-582 to 10-145d-587 of the State Board of Education
regulations to modify certification requirements for school superintendents to permit
school districts to choose qualified superintendents from non-traditional, but relevant
management and other backgrounds.

Department of Emergency Services and Public Protection
Amend regulations to require adequate preparation and enforcement measures to
minimize vibration, noise, and adverse impacts on nearby property caused by explosives
and blasting agents. The regulations should be amended in consultation with the
Department of Energy and Environmental Protection.

Department of Energy and Environmental Protection Siting Council
Eliminate the current regulation that requires municipalities to report to the Siting
Council annually the location of telecommunication towers within their town or city. The
reporting responsibility should be directed at tower owners rather than the host
municipality.

Amend regulations to allow local officials the option to decide their EMS provider and
the terms of contracts, particularly to change companies that fail to adequately provide
adequate services.

Modernize current public health laws to reflect the mission and essential services
provided by local health officials. Current practice mandates that local health departments
perform 8 basic public health services, outlined in Public Health regulations, Section 19a-
76-2. It should be amended to more accurately reflect the current practices and services
provided by public health departments.

Amend regulations to streamline testing requirements for the Emergency Medical
Technician training certification process. In particular, eliminate redundant and frequent
testing requirements.

Amend regulations regarding non transient water supplies to make it easier for the
development of these systems, and eliminate standards that are an undue burden on these
supplies.

Amend current regulations to provide that suspended Emergency Medical Technicians, or
those prohibited from actively treating patients, should not be allowed to also be
Emergency Medical Technician instructors.

Amend the current regulations that exempt school-based day care centers from certain
requirements to also include daycare centers operated by municipal recreational
departments.

Repeal the following five (5) Public Health Code Regulations as the governance is
duplicated under 19-13-B42: Sanitation of places dispensing food or beverages.
o 19-13-B40: Sanitation of Food, Fair Grounds, Ice Plants and Trailer Coaches
o 19-13-B41: Sanitation of public fair grounds, horse shows, horse races, and
automobile races
o 19-13-B44: Sanitation of trailer coaches
o 19-13-B48: Itinerant Food Vending and Catering
o 19-13-B49: Catering and food service

###

For more information, please contact Ron Thomas (rthomas@ccm-ct.org), Bob Labanara
(rlabanara@ccm-ct.org) or Mike Muszynski (mmuszynski@ccm-ct.org) of CCM, at (203) 498-
3000.

I am writing to comment on the updating of state regulations Section 15-140f-1 and Section 15-140j-2. If
these regulations were to change to allow online education, for knowledge based information that is
incorporated in the basic boating safety course that leads to certification, it would have a very positive
outcome. Having the ability to take online courses opens up the ability for many more residents to
advantage of that type of learning experience as it will be used for new boaters but also refreshers for
those of us who have been boating for years. On line classes afford State residents to take the class
when it is best for them.
The move to online education will free current D.E.E.P. staff allowing them to expand their on water
skills concept to more boaters. The on water boating education, which is being promoted by the USCG,
will help to create a safer boating experience on Connecticut waters.
Small changes can make big difference, from saving funds to saving lives; these changes warrant your
consideration.
Sincerely,

Peter Gumprecht
Member of CT B.A.S.S. Nation

I am writing to comment on the updating of state regulations Section 15-140f-1 and Section 15-140j-2. If
outcome. Having the ability to take online courses opens up the ability for many more residents to
advantage of that type of learning experience as it will be used for new boaters but also refreshers for
those of us who have been boating for years. On line classes afford State residents to take the class
when it is best for them.
The move to online education will free current D.E.E.P. staff allowing them to expand their on water
will help to create a safer boating experience on Connecticut waters.
consideration.
Sincerely,

Ronald Frisk
Youth Director/High School Director
CT B.A.S.S. Nation

the D.E.E.P. Boating Division would be to shift personnel from change to One of the regulations that

comments regarding the benefits of online education for knowledge based information that is
incorporated in the basic boating safety course that leads to certification. As I mentioned to you,
allowing the Dept. to go to online education for this portion of boating education would allow us to
enter another phase of boating safety education that is being promoted by the USCG that of on water
boating education. This voluntary course would teach skills based proficiencies. Having online courses
available for those that wanted to take advantage of that type of learning experience will free our staff
to expand the on water skills concept.

Attached is the Executive Order issued by the Governor that provides a mechanism for commenting.
Please note that the last date to comment through the Governors website is Monday, December 16.
Also, the regulation that currently requires a class room course to satisfy the requirement for boater
certification is Section 15-140f-1 and Section 15-140j-2.

I concur that we need to make it easy for new boaters to get into the sport and that adapting to the way
people want to obtain their education, is prudent.

December 16, 2013
Im writing to comment on the updating of state regulations Section 15-140f-1 and Section 15-140j-2. If
outcome. Having the ability to take online courses opens up the opportunity for many more residents
to take advantage of that type of learning experience. It could be used for new boaters as well as for
refreshers for those of us who have been boating for years. Online classes will allow State residents to
take the class when it is best for them.
The move to online education will free up current D.E.E.P. staff allowing them to expand their on water
will help to create a safer boating experience on Connecticut waters. Just like learning to drive a car,
practical experience behind the wheel of a boat is invaluable to boater safety.
consideration.
Sincerely,

Steve Deguzis
Member CT B.A.S.S. Nation

12/16/13
Page 1

Home Health and Hospice Regulatory Revisions/Updates:
Recommendations by the CT Association for Healthcare at Home
Thank you for the opportunity to conduct an independent review of current home
health and hospice regulations and to offer recommendations for revisions. The Hospice
and Palliative Committee as well as the Policy Committee of the CT Association for
Healthcare at Home respectfully submit the following revision recommendations and
ask that the respective department (DSS or DPH) contact the Association (Tracy
Wodatch VP of Clinical and Regulatory Services) with any questions or need for further
clarification. Tracys contact info is as follows: wodatch@cthealthcareathome.org or
203-774-4940.
Many of our recommendations are listed to align the regulations with current Medicare
Conditions of Participation and with the states plan to rebalance encouraging more
people to live in the home and community-based setting. In order to meet the needs of
this growing population, home health care agencies will need to offer more abundant
services which will require significantly more dedicated, skilled staff. As clinicians
transition from their management and direct care staff roles in inpatient facilities, the
skills and experience level of these qualified clinicians can and should be utilized in
home health and hospice care; however, the current regulations can be limiting
especially the DPH regulations for administrative and supervisory roles. We ask that you
consider the following updates.
DSS Home Health Provider Manual Chapter 7:
P2: 17b-262-7 Refusal to Serve
Forms and process should be made current to ensure agency is tracking any
refusals to serve and can produce tracking log should DSS request.
Remove (b) and (c) and replace with language to reflect the requirement in the
DPH Home Health Care Agency regulations:
DPH regs: 19-13-D72. Patient care policies (pp14-15)
(1) Conditions of Admission:
(D) Circumstances which render a patient ineligible for agency services,
including but not limited to level of care needs which make care
at home unsafe, kinds of treatments agency will not accept,
payment policy and limitations on condition of admission, if any;

12/16/13
Page 2

(E) Plan for referral of patients not accepted for care;
(3) Discharge from Service:
(A) Agency policies shall define categories for discharge of patients.
These categories shall include but not be limited to:
(ii) Emergency discharge--termination of service(s) due to the
presence of safety issues which place the patient and/or agency
staff in immediate jeopardy and prevent the agency from
delivering home health care services;
(C) In the case of an emergency discharge the agency shall immediately
take all measures deemed appropriate to the situation to ensure patient
safety. In addition, the agency shall immediately notify the patient, the
patient's physician, and any other persons or agencies involved in the
provision of home health care services. Written notification of action
taken, including date and reason for emergency discharge, shall be
forwarded to the patient and/or family, patient's physician, and any
other agencies involved in the provision of home health care services
within five (5) calendar days.

P9: 17b-262-728
Definition of Nursing Services needs to include assessment
From DPH regulations 19-13-D69 p6 ((D) Regular evaluation of patient progress,
prompt action when any change in the patient's condition is noted or reported,
and termination of care when goals of management are attained) nursing
services include assessment and evaluation of pt progress. Need to add to sec
17b-262-728 Services covered.
DSS Hospice Provider Manual Chapter 7:
P8: 17b-262-838
Services covered (a)(1): mirror Medicare CoPs for CTI requirement to bill. Verbal
orders are acceptable provided a written order is received prior to billing the
claim. (remove within 48 hours of the verbal order).
RCH Regulations
The Association respectfully requests that DPH review the section in the RCH
regulations that addresses the storage and labeling of medications. With
rebalancing initiatives in full swing in CT, this regulation does not allow for any

12/16/13
Page 3

in-house medication pre-fills of any kind including, electronically locked
medication boxes.
DPH Regulations for Home Health Care Agencies:
P3: 19-13-D67 Personnel
(a) The administrator of an agency shall be a person with one of the following
(1)-(7) should align with the Medicare CoPs which state: Administrator, home
health agency. A person who:(a) Is a licensed physician; or(b) Is a registered nurse; or(c) Has
training and experience in health service administration and at least 1 year of supervisory or
administrative experience in home health care or related health programs.
(b)(1)-(4)remove and replace with
(b)(1) An agency supervisor of clinical services (SCS) shall be a registered nurse
(RN) with an active license to practice nursing in this state who has a minimum of
three (3) years clinical experience in nursing. In addition and within the first
year in SCS role, if the RN obtained nursing degree through diploma or
associates program, said RN would also need to complete at least six credits in
community health nursing and/or health care management from an accredited
college or university program or school of nursing.
(f)Replace with An agency supervisor of social work services shall be licensed
pursuant to the Chapter 383b of the Connecticut General Statutes who has a
minimum of three (3) years clinical experience in social work.
19-13-D68 General Requirements
(c) Professional Advisory Committee (p5)
(1) There shall be a professional advisory committee, , one registered nurse
(preferably a public health nurse) this language reflects Medicare CoPs
(e) Supervisor of Clinical Services (6):
(1) and (4) where possible eliminate staffing ratios and replace with
language aligned with DPH regulations for Hospice Inpatient Facilities:
The SCS is responsible for ensuring that the staffing for all services reflect
the agencys volume of patients, their acuity, and the level of intensity of
services needed to ensure that the plan of care outcomes are achieved
and negative outcomes are avoided.

12/16/13
Page 4

19-13-D69 Services
(d) Homemaker-Home Health Aide Serviceconsider changing the term to
Home Health Aide (eliminating Homemaker)
(4) Supervision of homemaker-home health aides: eliminate (D) staffing ratio to
align with CoPs and allow for more optimal care team integration
19-13-D70 Contracted Services
(g) A term not to exceed one year unless the parties agree otherwise.
19-13-D71 Personnel policies
P13 (a)(5) Physical examination, including tuberculosis screening per CDC guidelines
and a physicians or his/her designee statement that employee is capable of
performing job functions as outlined in their job description.
19-13-D72 Patient care policies
P21 (b)(2)(K) An agency offering a hospice program shall designate a medical director
(eliminate employ and replace with designate to mirror the hospice CoPs).
19-13-D73 Patient Care Plan
P23 (b) The original plan of care and any modifications shall be signed by the
patients physician or dentist within 30 days (remove 21 days and replace with
30 days to mirror the CoPs).
(c) The plan for each agencyat least every sixty (60) days except for hospice
plans of care which will be reviewed according to their established hospice
benefit periods or 90 days for first and second benefit periods and every 60 days
thereafter.
19-13-D76 Quality Assurance program
Align with CoPs where possible
P25: (c)(4) eliminate 120-day report duplicative of annual reporting requirement, not
federally mandated.
(c)(5) Ensure that a copy of the annual QA report is maintained by the agency
(eliminate and the progress report on implementation)

12/16/13
Page 5

(d)(2) remove in a 5 year cycle
(e)(1) remove after approval by the commissioner.
(f) Add Within to beginning of sentence so sentence reads Within 6 months
after employment and annually thereafter(this allows agencies to do sooner
(90 days if appropriate).
P26 (g) replace with current CoP OBQI language from the State Operations Manual
19-13-D77 Administrative organization and records
P26 (d) remove entire sentence
19-13-D79 Facilities
P28 (c)(5)remove entire sentence as record storage is addressed on p24 19-13-D75
(a)(4).

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