CT DEEP Submits Revised Regulations for Replacement Program for Legislative Approval
The Connecticut Department of Energy & Environmental Protection (DEEP) has reached the next milestone in setting up its “Release-Based Cleanup Program” to replace the burdensome Transfer Act.
After kicking-off the formal regulation adoption process this past July, including soliciting public comments, DEEP recently announced its intention to move forward, issuing a revised version of the proposed program regulations—the “RBCRs”—and sending them off to their last stop: the Legislative Regulation Review Committee (LRRC). This bipartisan committee of State legislators is tasked with reviewing and approving all regulations proposed by state agencies. While multiple rounds of review and comment can be anticipated by the LRRC, making the timing of the new program implementation uncertain, DEEP has proposed that the new program go into effect on March 1, 2026. While the ultimate effective date is subject to change, once effective, the “Transfer Act” will officially sunset.
More information on the current draft of the RBCRs and the State’s adoption process is available here, and all materials, including the current draft regulations, are in the State’s eRegulations System in Docket No. PR2024-025.
As an engaged stakeholder in the State’s environmental framework revamp, Carmody continues to closely track the new program development and help clients understand its potential future implications.
Please contact our Environmental group if you would like additional information or need advice about the State’s ongoing new program development:
Deborah R. Brancato
Partner
203.252.2648
dbrancato@carmodylaw.com
This information is for educational purposes only to provide general information and a general understanding of the law. It does not constitute legal advice and does not establish any attorney-client relationship.