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Thank you for the opportunity to be here this morning. I was extremely honored to help prepare
comments on the draft State Plan of Conservation and Development on behalf of CCAPA and to, on an
on-going basis, assist with communications for the Government Relations Committee.
Last summer, when OPM released its first public review draft of the state plan, CCAPA members were
encouraged to submit comments. I would like to recognize the individuals who contributed to this effort:
Susmitha Attota, New Haven City Plan Dept.
Glen Chalder, Planimetrics
John Chew and David Hannon, HVCEO
Dan McGuinness, formerly of NWCOG
Chris Smith, Shipman & Goodwin
Me
I combined our comments into a set of draft comments which were fine tuned by the CCAPA
Government Relations Committee and then approved by the Executive Committee before being sent off
to OPM. These comments are available on the CCAPA website. Overall, CCAPA was very pleased with
the text of the state plan and the six growth management principles. Most of the concern, from CCAPA
as well as from other groups, has focused on the Locational Guide Map which looks very different from
the previous version.
OPM carefully and thoroughly responded to each comment submitted by CCAPA and to all who
submitted comments. Their responses are available on OPM’s website. Representatives from OPM are
here today and will be talking about the state plan. Some of the issues raised by CCAPA in their
comments were repeated by other state agencies and organizations.
Here are some highlights:

DECD and CT Audubon shared CCAPA’s concerns regarding the use of census blocks to
delineate Priority Funding Areas. In OPM’s methodology, if a water or sewer line touches a
census block, even a little bit, the entire census block is included as a Priority Funding Area, even
if 99% of the block was actually rural. The concern was this might lead to an incorrect
interpretation of the LGM. In response, OPM allowed municipalities to opt out of the PFA
designation for any census block if it was thought to be inconsistent with the municipal plan.
OPM also agreed to develop a means for agencies and other interested parties to view individual
data layers (such as water and sewer service areas, transit facilities, farmland soils, and aquifer
protection areas), based on their actual boundaries and not just by census block. OPM has since
added a sewer service areas layer to the Interactive Location Guide Map which is fun and easy to
use with a little practice. OPM has prepared some basic instructions on how to use it and it is
very nicely designed however, we are still waiting to see the other map layers that were promised:
namely water service areas, transit facilities, farmland soils and aquifer protection areas.

The Department of Agriculture shared CCAPA’s concerns regarding the manner that farmland
soils were included as Conservation Areas. Initially, farmland soils of additional statewide
importance were left out and soil units less than 25 acres were excluded. In the second version of
the map, this has been corrected. The improved methodology is very apparent in some
communities, especially those with a lot of farmland soils.
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
OPM agreed with our concern that better guidance was needed on how to use the LGM so that
state agencies could use it properly. They greatly expanded the section of the plan dedicated to
this and they used the guidance language that they prepared for the Summer 2012 issue of CT
Planning magazine. I believe they have also offered workshops to state agencies on how to use
the plan.

When CCAPA suggested that OPM consider the need for a formal statewide sewer management
policy, and perhaps also a water supply management policy, and a management policy for all
utilities that can foster greater development densities, OPM gave CCAPA a challenge: They said
such a formal statewide utility management policy would likely require a modification to the
municipal planning statutes to tie sewer and water plans into local Plan’s of Conservation and
Development- an intriguing thought worth considering, even if that is not exactly was we had in
mind.

Lastly, OPM confirmed that the state has no specific implementation strategy for the plan. If
looked upon negatively, the newly adopted plan might be thought of as a passive tool with limited
applications for responsible growth but perhaps this is another challenge. Perhaps thoughtful CT
planners may be of assistance to the Office of Policy and Management in the future strategic
implementation of the Conservation and Development Policies Plan for CT, our most important
statewide planning document.
Thank you.