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Environmental Law Alert: "Who Knew That Was Regulated?"

August 24, 2015

The Connecticut Department of Energy & Environmental Protection ("DEEP") has issued a draft General Permit to Construct and Operate a Commercial Facility for the Management of Recyclable Materials and Certain Solid Wastes ("Commercial Permit"). DEEP expects to issue the final Commercial Permit this fall, with required registration and payment of fees to follow thereafter.

The Commercial Permit expands the scope of the soon-to-expire Recycling General Permit to include a number of activities that business owners may not have thought of as "recycling." The Commercial Permit will apply to any facility that accumulates more than 10 cubic yards in the aggregate of certain common, non-hazardous wastes if any of that waste originates at a different property.  The categories of waste include:

  • Asbestos Containing Materials;
  • Ash Residue;
  • Clean Wood including Leaves and Grass clippings;
  • Construction and Demolition debris, 
  • Non-RCRA Hazardous Waste and Compatible Solid Wastes;
  • Recyclables; and
  • Universal Waste and Compatible Solid Wastes. 

As an example, an appliance store that takes back its customers' empty boxes will be subject to this permit if or when it accumulates more than 10 cubic yards of any waste covered by the permit.   

Click here for the draft Commercial Permit.

For more information, contact Anne Peters at (203) 575-2647 or apeters@carmodylaw.com or Pamela Elkow at (203) 252-2672 or pelkow@carmodylaw.com.