Photo of Emilee Mooney Scott

I am a Partner in the Environmental, Energy + Telecommunications Group. My practice focuses on assisting clients in complying with federal and state environmental laws, with a particular focus on the management of hazardous and toxic substances, especially under the Toxic Substances Control Act and the Emergency Planning and Community Right-to-Know Act. I regularly help clients understand, manage, and limit environmental risk associated with business and property transactions, including assisting clients in complying with transaction-triggered compliance requirements like the Connecticut Transfer Act and the new Release-Based Cleanup Regulations set to go into effect on March 1, 2026. My full bio is here.

This is the ninth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

The final task in the remediation process is documenting that remediation is complete, and no further action is required. This post discusses the documentation requirements under the RBCRs, and

This is the eighth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

As remediation projects are planned and performed, the big question is: “How clean is clean enough?” This post discusses remediation standards under the RBCRs, and how those standards will

This is the seventh in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

Under the Transfer Act, the majority of site remediation efforts are led by licensed environmental professionals (LEPs).  For a minority of sites with especially serious contamination, remediation efforts are

This is the sixth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

The RBCRs require that, following discovery of a release, the “nature and extent of the release must be determined” so an appropriate remediation strategy can be designed and the

The Connecticut Department of Energy and Environmental Protection (DEEP) has issued a new general permit for remediation contractors, known as the General Permit to Act as a Contractor to Contain or Remove or Otherwise Mitigate the Effects of Certain Releases (Registered Existing Release Response Contractor) (Remediation GP). This new Remediation GP supplements the well-established

This is the fifth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

The last post in the RBCR series discussed reporting of new releases under Connecticut’s March 2022 spill regulations. This post discusses immediate response actions required for new releases (and

This is the fourth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

The new RBCRs set forth requirements for the characterization, remediation, and closure of both old and new releases. The last few posts in this RBCR overview series have related

This is the third in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

After a release has been “discovered” (see last post) the next step under the RBCRs is evaluating if and when that release must be reported.  This post, and the

This is the second in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq. 

Under the new RBCRs, the obligation to characterize and, if needed, remediate pre-existing contamination begins with the “discovery” of that contamination by a person who created or is maintaining

Connecticut’s environmental remediation laws are about to change significantly on March 1, 2026. This blog series, and the companion Release Report video series, will highlight key features of the new release-based cleanup regulations (referred to as “RBCRs”) so interested parties can get ready.

Background

At present, much of the environmental remediation in Connecticut is driven