---------------------------> Joel R. Anderson
13 George Drive
Old Saybrook CT 06475-2636
29 May 2010
Mary Jane Engle, R.S., MPH, Dir.
CT River Area Health District
166 Main St, Unit #2
Old Saybrook, CT 06475-2386
Dear Director Engle:
Re Connecticut River Area Health District (CRAHD)'s rev.
2Apr2010, Dear Property Owner, Re 'Notice of Entry,' (NOEL).
By what right does CRAHD, or the Old Saybrook Water Pollution
Control Authority (WPCA), or the Town of Old Saybrook (Town),
discriminate between property owners solely on the basis of
how compliance with the wastewater ordinance is financed?
See NOEL: Exhibit A; 'Box A,' (accepting Clean Water
Funds (CWF)), vs 'Box B,' waiving CWF and enacting
Exhibit D (Owner financed). Exhibit D pushes off the
WPCA/Town's cost and responsibility for Exhibit D,
paragraphs b-g, onto property owners solely because
owners are self-financing (D, i). This is wrong.
Under 'Box A,' CWF-financed compliance, the WPCA/Town
contributes 25 percent. That contribution most certainly
cannot be withheld from 'Box B,' owner-financed compliance,
nor can it be withheld from any owner anywhere in Town.
Exhibit D, paragraphs a-h, under 'Box A' criteria are
at the expense of CRAHD, the WPCA, or the Town. They
must be treated the same way under 'Box B' criteria.
Exhibit D describes the duties of the WPCA as the
distributed-wastewater-plant manager for the Town, the
same as if the Town had elected to build a sewer plant.
The WPCA/Town must supply identical services to all
property owners without regard to where the properties
are located or how the distributed wastewater solution
is financed. George Drive, Bokum Road, or Schoolhouse
Road; all owners must be treated the same.
I need a letter from you (CRAHD), the WPCA, and the Town,
expressly stating that owner-financed compliance will be
provided with the same services as provided to CWF-financed
compliance, on the same terms, with the same consideration.
The NOEL must be redrafted to include the provisions cited in
the paragraph above.
Very truly yours,
Joel R. Anderson
N.B: the 6-page Notice of Entry Letter (NOEL) is online here,
A copy of this letter is posted to my website, oswpca.com
e: Exhibit A and D of the NOEL (pages 3 and 6 respectively)
Office of the Board of Selectmen Office of the Board of Selectmen
Michael A. Pace, First Selectman William A. Peace, Selectman
302 Main Street 302 Main Street
Old Saybrook CT 06475-2384 Old Saybrook CT 06475-2384
Office of the Board of Selectmen Michael E. Cronin, Jr.
Carol Manning, Selectman Old Saybrook Town Counsel
302 Main Street 201 Main Street, P.O. Box 454
Old Saybrook CT 06475-2384 Old Saybrook CT 06475
Robert W. Fish John E. Wertam, Partner
Treasurer, Old Saybrook Shipman & Goodwin LLP
49 Obed Heights Rd One Constitution Plaza
Old Saybrook CT 06475 Hartford, CT 06103-1919
Eugene M. Evangelisti, Chm. OSWPCA Hon. Richard Blumenthal, AG
Town of Old Saybrook Office of the Attorney General
302 Main St 55 Elm St.
Old Saybrook CT 06475 PO Box 120
Hartford CT 06141-0120
Gratia Lewis, Fin. Mgr OSWPCA re Public Inquiry #339871
37 Old Boston Post Rd or #340861 (or both)
Old Saybrook CT 06475
Nora R. Dannehy, US Attorney
Betsey Wingfield, Bureau Chief, DEP US Attorney's Office
Bureau of Water Protection & Land Reuse Connecticut Financial Center
79 Elm St 157 Church Street, Floor 23
Hartford CT 06106-5127 New Haven, CT 06510