--------------------------> Joel R. Anderson
13 George Drive
Old Saybrook CT 06475-2636
6 March 2013
WPCA Chairman Elsa Payne
Old Saybrook Town Hall
302 Main St
Old Saybrook CT 06475-2369
To make a mistake and not to correct it is
Dear Chairman Payne:
to make another mistake. - Chinese proverb
The WPCA has no legal access to Cornfield Park properties. The
WPCA can't let contracts, put them out to bid (as it has), on
properties to which it has no legal access.
The CRAHD form "Exhibit A" granting access to WWMD properties
isn't approved by the Commissioner of the Department of Public
Health as required by the Public Health Code.
The Town's own Ordinance, ARTICLE II, Decentralized Wastewater
Management District, [Adopted 8-11-2009], Section 173-24(B)
cites, 'an application (on a form to be provided by the
Director of Health) pursuant to Section 19-13-B103e(c) of the
Public Health Code.'
The Commissioner of Public Health does not approve Exhibit A.
The WWMD septic upgrade program is absurd on its face:
The WPCA can't credibly claim to be ignorant of its own
ordinance and the requirement for approval by the
Commissioner of DPH for its Application.
Town Counsel Cronin commented on the requirement for DPH
approval; noted in the 13Apr2009 Minutes of the WPCA.
The program calls for substituting one Permit to Discharge
for another. It boggles the mind Why a WWMD owner would want
a 2nd Permit to Discharge when they already had one. The
Town is using a cheat, a lawyer-trick of which Shipman &
and the Town should be ashamed.
The WWMD Ordinance went to Referendum on 11Aug09 lacking
Standards that were part of the Ordinance. No elector could
have known what they were voting on, had they inquired.
Very truly yours,
Joel R. Anderson
e: Bid for Cornfield Park - Contract CPK-1
N.B: a copy of this letter is posted to oswpca.com.
Electronic and paper copies have been distributed
to interested parties.