AUDITORS’ REPORT

Department of Energy and

Environmental Protection
Council on Environmental Quality
Office of Consumer Counsel
Connecticut Siting Council
FISCAL YEARS ENDED JUNE 30, 2021 AND 2022

STATE OF CONNECTICUT
Auditors of Public Accounts

JOHN C. GERAGOSIAN CRAIG A. MINER

State Auditor State Auditor
 CONTENTS
INTRODUCTION........................................................................................................................................................ 3

S T A T E A U D I T O R S ’ F I N D I N G S A N D R E C O M M E N D A T I O N S ................................................... 4
Controls Over Overtime and Compensatory Time ......................................................................................... 4
Personnel File Documentation for Seasonal Employees................................................................................ 6
Lack of Employee Evaluations ............................................................................................................................. 7
Controls Over Procurement ................................................................................................................................ 8
Controls Over Purchasing Cards ...................................................................................................................... 10
Payment Process for Consultants Hired by the Public Utility Regulatory Authority ................................. 11
Controls Over Ground Water Permit Applications ........................................................................................ 12
Noncompliance with Statutory Requirements of the Nuclear Safety Preparedness Account ................ 14
Inventory Reporting and Controls .................................................................................................................... 15
Controls Over Loss Reporting ........................................................................................................................... 18
Controls Over Fueling Stations and Fuel/Mileage Reporting ..................................................................... 19
Excess Inventory of DEEP-Owned Vehicles and Controls Over Maintenance .......................................... 22
Controls Over Disposals .................................................................................................................................... 23
Controls Over Collection and Documentation of Emergency Spill Cases ................................................ 25
Controls Over Required Reporting .................................................................................................................. 28
Lack of Disaster Recovery Plan .......................................................................................................................... 30
Lack of Segregation of Duties for the Database Administrator ................................................................... 31
DEEP Administered Trust Funds ...................................................................................................................... 32
Foundation Designation and Lack of Agreements........................................................................................ 34
Lack of Central Database for Complaints ....................................................................................................... 37
Mattress Recycling Audit Report Not Obtained ............................................................................................ 38
Inactive Councils and Committees ................................................................................................................... 39
Improper Time Reporting .................................................................................................................................. 40
Improper Paid Administrative Leave ................................................................................................................ 43
S T A T U S O F P R I O R A U D I T R E C O M M E N D A T I O N S ..................................................................... 45

O B J E C T I V E S , S C O P E , A N D M E T H O D O L O G Y .............................................................................. 49

A B O U T T H E A G E N C Y ................................................................................................................................... 51
 STATE OF CONNECTICUT

AUDITORS OF PUBLIC ACCOUNTS

STATE CAPITOL
JOHN C. GERAGOSIAN 210 CAPITOL AVENUE CRAIG A. MINER
HARTFORD, CONNECTICUT 06106-1559

August 28, 2024

INTRODUCTION

We are pleased to submit this audit of the Department of Energy and Environmental Protection (DEEP),
the Council on Environmental Quality (CEQ), the Office of Consumer Counsel (OCC), and the
Connecticut Siting Council (CSC) for the fiscal years ended June 30, 2021 and 2022 in accordance with
the provisions of Section 2-90 of the Connecticut General Statutes. Our audit identified internal control
deficiencies; instances of noncompliance with laws, regulations, and policies; and a need for
improvement in practices and procedures that warrant the attention of management.

The Auditors of Public Accounts wish to express our appreciation for the courtesies and cooperation
extended to our representatives by the personnel of the Department of Energy and Environmental
Protection, the Council on Environmental Quality, the Office of Consumer Counsel, and the Connecticut
Siting Council during the course of our examination.

The Auditors of Public Accounts also would like to acknowledge the auditors who contributed to this
report:

Romina Andrade
George Meleounis
Michael Stemmler

Michael Stemmler
Principal Auditor

Approved:

John C. Geragosian Craig A Miner

State Auditor State Auditor

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer Counsel, and 3
Connecticut Siting Council 2021 and 2022
 STATE AUDITORS’ FINDINGS
AND RECOMMENDATIONS
Our examination of the records of the Department of Energy and Environmental Protection, the Council
on Environmental Quality, the Office of Consumer Counsel, and the Connecticut Siting Council disclosed
the following 23 recommendations, of which 20 have been repeated from the previous audit:

Finding 1

Controls Over Overtime and Compensatory Time

Criteria Section 5-245 of the General Statutes provides that employees can
receive overtime pay when authorized by their appointing authority.

The DEEP overtime and compensatory time policy is included in its

directive Compensatory Time, Overtime, and Lifting the Overtime
Cap – Bargaining Unit Employees. This directive requires advance
supervisory approval of overtime and compensatory time. The policy
also requires that the employee and supervisor keep accurate
records of overtime and compensatory time earned and supervisory
approval of employee timesheets indicating approval of all overtime
and compensatory time.

The P-4 bargaining unit contract allows eligible employees to

receive straight overtime for hours worked between 35 and 40, and
time-and-one-half for hours worked over 40.

Condition We reviewed 20 employees who earned overtime and/or

compensatory time during the audited period and noted the
following:

• DEEP lacks a consistent policy to document advance

supervisory approval for non-emergency personnel
overtime or compensatory time. In nine of 13non-
emergency employees reviewed, we could not verify that a
supervisor authorized the accrual of 453 hours of overtime,
and 49 hours of compensatory time.

• In one instance, DEEP overpaid an employee $256.55 in

overtime. DEEP paid five hours at time-and-one-half, rather
than straight time, as specified in the bargaining unit
contract. Upon our notification of this overpayment, the
employee repaid the department.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 4
Counsel, and Connecticut Siting Council 2021 and 2022
 Context Overtime payments at DEEP totaled $1,853,441 and $2,034,101 in
the fiscal years ended June 30, 2021, and 2022, respectively. We
judgmentally selected ten employees for testing, based on amounts
of overtime earned during the audited period. We then
judgmentally selected one pay period for each employee, reviewing
a total of 762 overtime hours.

DEEP employees earned 7,826 and 9,061 hours of compensatory

time in fiscal years ended June 30, 2021, and 2022, respectively. We
judgmentally selected ten employees for testing, based on amounts
of compensatory time earned during the audited period. We then
judgmentally selected one pay period for each employee, reviewing
a total of 333 compensatory hours.

Effect Overtime and compensatory time costs are more difficult to manage
and may be subject to abuse.

Cause DEEP does not have a process to document the preapproval of non-
emergency overtime and compensatory time, which includes the
reason for the overtime and justifies why the work cannot be done
during regular work hours.

Prior Audit Finding This finding was previously reported in the last audit report covering
the fiscal years ended June 30, 2018, through 2020.

Recommendation The Department of Energy and Environmental Protection should

revise its overtime and compensatory time policy for non-
emergency personnel to document the preapproval of overtime and
compensatory time. The documentation should include the reason
for the time and justification as to why the work cannot be performed
during regular hours.

Agency Response “The Department recognizes the importance of ensuring overtime

hours worked are necessary and properly authorized by supervisors.
The Department acknowledges the audit recommendation that a
request form be used for planned overtime requirements. The
Department issued a guidance document to all managers and staff
in September 2022 clarifying the requirements for overtime,
including managerial approval and oversight. A suggested form was
delivered with clarifying guidance on use of Core-CT comments
field for approvals and bureau chief acknowledgement and final
approval of the additional time. The Department continues to work
with the bargaining units and management to ensure acceptance
and compliance. The Bureau of Central Services delivers monthly
managerial reports for all compensatory time and overtime for the
respective bureaus. As mentioned in a prior finding, Payroll staff
have switched from approving timesheets to ensuring that
timesheet approvals are given by the appropriate supervisor or
manager. The Core-CT comments field is used to allow supervisors
and managers the opportunity to formally acknowledge the

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 5
Counsel, and Connecticut Siting Council 2021 and 2022
 necessity of the hours worked during that business cycle. As DEEP
operations include numerous responsibilities that can experience
emergency conditions, the pre-approval of hours in such a formal
method could jeopardize both safety and property. The Department
agrees that only tasks that cannot be performed during the normal
workday should qualify for overtime payments and has taken steps
to minimize overtime earned. The Department will continue to
provide guidance to the bureaus to ensure compliance with the
agency’s overtime directive. This will include supplemental
guidance on managerial review and authorization for programs and
will continue to deliver routine management reports.”

Finding 2

Personnel File Documentation for Seasonal

Employees

Background The Department of Energy and Environmental Protection hires

hundreds of seasonal employees each year at state parks and other
locations. Some seasonal employees are rehired since they are
considered temporary employees and are prohibited from working
more than 1,040 hours per calendar year. A three-month break is
also required before DEEP can rehire the employee.

Criteria The DEEP hiring procedures requires seasonal employees to

complete various forms prior to employment. The DEEP Seasonal
Employee Information Sheet lists these required forms.

DEEP Directive Manual Code 5520 D2, “Request for

Employee’s/Volunteer’s Motor Vehicle Operator’s License Status”
requires that the supervisor of any seasonal employee must have
them complete the license verification request. DEEP policy requires
verification to be conducted before any employee is allowed to
operate a motor vehicle while conducting state business.

Condition Our review of documentation for 15 seasonal employees hired

during the audited period disclosed 14 employees’ required forms
were missing or incomplete. Among these, we noted 21 missing
forms and 19 that lacked proper approval signatures.

Context DEEP hired 617 seasonal employees during the audited period. We
randomly selected 15 employees for review.

Effect If any personnel issues arise, there could be legal ramifications from
missing, incomplete, or unsigned forms.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 6
Counsel, and Connecticut Siting Council 2021 and 2022
 Cause DEEP does not have an adequate process to obtain and store these
forms.

Prior Audit Finding This finding was previously reported in the last audit report covering
the fiscal years ended June 30, 2018, through 2020.

Recommendation The Department of Energy and Environmental Protection should

ensure that all required forms for seasonal employees are in their
personnel files and include necessary signatures.

Agency Response “The Department agrees with the finding and recognizes the
importance of maintaining complete employee files. The Directive is
intended to ensure that DEEP employees and volunteers who are
required to operate a State-owned motor vehicle or personally
owned motor vehicle while on official state business are properly
licensed to do so. Most seasonal staff are assigned to field locations
and will not operate state vehicles or their own vehicles to conduct
state business. The form is not required for these individuals
although the Department would consider requiring completion of
the form for all seasonal and volunteer employees with additional
assistance from DMV. DEEP has recently shifted to an electronic
submission process from field units to the central office for the initial
setup of seasonal staff. The timeliness of submitting these files
electronically allows DAS HR staff and DEEP Payroll staff to follow up
immediately when packages are not complete. Given all the
struggles to secure seasonal and volunteer staff during the
pandemic and post pandemic, the Department is seeking a number
of changes to recruit and manage seasonal and volunteer
employees. The State has made progress on onboarding new
permanent employees and the Department plans on capitalizing on
the software investments and changes coordinated by DAS’s Human
Resources for seasonal staff and volunteers. This includes the
conversion of all HR files to an electronic format, reducing the risk of
documents being lost when employee files are reviewed.”

Finding 3
Lack of Employee Evaluations

Criteria The Department of Administrative Services (DAS) developed the

Performance Assessment and Recognition System (PARS) to support
additional incentive compensation for managerial and confidential
employees in participating agencies. The system serves as a basis
for annual salary increases and includes developing results-oriented,
measurable performance objectives and goals for each manager
and confidential employee; regular communication between
employees and their supervisors on meeting goals and performance

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 7
Counsel, and Connecticut Siting Council 2021 and 2022
 assessments; and providing a basis for differentiating among
performance levels.

Condition We reviewed five managerial and confidential employees and noted

that DEEP did not perform evaluations for any of them during the
audited period. In two instances, the employee had not received an
evaluation in over five years.

Context As of June 30, 2022, DEEP employed 65 managerial employees. We

judgmentally selected five employees for review.

Effect When evaluations are not performed, there is a lack of formal

feedback for management to measure performance goals, the
attainment of such goals, and productivity expectations.

Cause The department had inadequate administrative controls to ensure

the completion of PARS managerial performance evaluations.

Prior Audit Finding This finding has not been previously reported.

Recommendation The Department of Energy and Environmental Protection should

ensure that it prepares annual performance evaluations for all
managers using the Performance Assessment and Recognition
System.

Agency Response “The Department agrees with the finding and recognizes the
importance of managerial performance evaluations. DEEP believes
that the measures are in place to facilitate the ongoing and
constructive dialogue between managers and their respective
supervisors but acknowledges this has not been documented in
many cases.”

Finding 4

Controls Over Procurement

Criteria Section 4a-57 of the General Statutes requires that all purchases be
based on competitive bids or competitive negotiation when
possible.

Section 4-252 of the General Statutes requires vendors to submit

certain ethics affidavits and certifications for state contracts with
values exceeding $50,000.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 8
Counsel, and Connecticut Siting Council 2021 and 2022
 The State Agencies’ Records Retention/Disposition Schedule details
the minimum retention requirements for state records, including
dictating that fiscal records be retained for three years or until
audited, whichever is later.

Condition We reviewed 20 expenditure transactions, totaling $11,632,447,

and noted the following:

• In two instances, DEEP did not provide support for written

quotations. The purchase orders totaled $34,300 and
$47,500.

• In three instances, purchase orders referenced DEEP

contracts, however, the department did not provide these
contracts. The purchase orders totaled $624,663,
$24,469,075, and $769,206. Furthermore, DEEP did not
provide required ethics affidavits and certifications for a
$769,206 contract.

Context There were over 43,000 expenditure transactions, totaling

$556,949,662, during the audited period. We stratified our universe
by transaction amount, including amounts over $50,000, amounts
$10,000 to $49,999, and amounts less than $10,000. We
judgmentally selected a total of 20 for review.

Effect A lack of competitive quotes decreased assurance that DEEP paid

the lowest price.

Without the contract on file, DEEP cannot verify it is adhering to the

contractual terms.

Cause These conditions appear to be the result of a lack of management

oversight.

Prior Audit Finding This finding has not been previously reported.

Recommendation The Department of Energy and Environmental Protection should

strengthen internal controls to ensure compliance with purchasing
laws and retention standards.

Agency Response “The Department recognizes the importance of ensuring that

purchasing laws and regulations have been followed and
acknowledge that the documentation could have been handled
differently during the pandemic and post pandemic. As the State
converted its workforce to a remote environment and implemented
tools for managing electronic documentation, not all staff were as
diligent about uploading their backup documentation to Core-CT.
Many of those staff have now left State service and their

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 9
Counsel, and Connecticut Siting Council 2021 and 2022
 documentation is only available in a dormant email account. New
procedures have been implemented to ensure that supporting
materials are captured within Core-CT going forward.”

Finding 5

Controls Over Purchasing Cards

Criteria The State Comptroller’s Purchasing Card Manual makes cardholders

responsible for completing their agency’s reconciliation process,
record all purchases on a purchasing log, and maintain all
supporting documentation such as proper receipts, packing slips,
etc. The manual also states that it is important for cardholders to
emphasize that the purchase is exempt from sales tax.

DEEP’s Purchasing Card Program procedure states that the

completed P-Card Log Sheet or Envelope, along with all the
documentation, must be received in the Purchasing Unit no later
than the 15th of the following month. The procedure also states that
the cardholder is responsible for ensuring no tax is charged on
purchases and utilizing all established state online vendor accounts
which are programmed to provide tax-exempt status.

Condition Our review of five purchasing card statements, consisting of 44

transactions totaling $469,978, noted the following:

• Purchasing card users did not reconcile three statements on

time. The delays ranged from 20 to 56 days.

• In eight instances, DEEP paid a total of $165.81 in sales tax.

Context There were 15,451 purchasing card transactions, totaling

$2,708,948, during the audited period. We judgmentally selected
five purchasing card statements from three months with the largest
expenditures.

Effect The integrity of purchases made on P-Cards is reduced when

policies and procedures are not followed.

Cause The late completion of statement reconciliations and payment of

sales tax appears to be an oversight by management.

Prior Audit Finding This finding has been previously reported in the last audit report
covering the fiscal years ended June 30, 2018, through 2020.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 10
Counsel, and Connecticut Siting Council 2021 and 2022
 Recommendation The Department of Energy and Environmental Protection should
strengthen internal controls over purchasing card transactions by
complying with the State Comptroller’s Purchasing Card Manual, the
department’s Purchasing Card (P-Card) Program and internal
procedures.

Agency Response “The Department agrees with the finding and recognizes the
importance of proper controls with respect to the P-Card program.
DEEP will review the examples identified in this audit to determine if
any actions to be taken.”

Finding 6

Payment Process for Consultants Hired by the

Public Utility Regulatory Authority

Criteria Section 16-18a of the General Statutes allows the Public Utility
Regulatory Authority (PURA) to retain consultants to assist staff in
authority proceedings by providing or supplementing their
expertise. It also limits the amount charged by consultants to not
more than $200,000 per proceeding. The company affected by the
proceeding bears all reasonable and proper expenses.

Section 16-8 of the General Statutes allows PURA to conduct

management audits. Management audits occur every six years but
may occur for other purposes described in the statutes. PURA may
engage professional consultants to perform management audits,
use its own staff, or use the utility’s internal audit staff. The affected
company bears all reasonable and proper expenses for
management audits. While there is no dollar limit per statute, PURA
has limited this cost to $400,000 per audit.

Condition We noted PURA does not properly monitor for statutory or policy
limits in its invoices for consultants or management audits. PURA
receives these invoices and forwards them to the company which
pays the vendor, without going through the state’s accounting
system (Core-CT).

Context PURA paid approximately $1.6 million to 12 consultants during the

audited period.

Effect The costs of consultants retained by PURA is not transparent and

monitored for compliance with statutory and PURA limits. In
addition, it is difficult to determine whether a consultant received an

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 11
Counsel, and Connecticut Siting Council 2021 and 2022
 inordinate number of contracts, as we rely on PURA to provide this
information.

Cause PURA interpreted the statutes to have vendors directly bill the
companies since they are paying for the service. PURA also indicated
it would be difficult budgeting and paying for these services from
the DPUC/Consumer Counsel Fund, which is primarily funded by
utility assessments.

Prior Audit Finding This finding has been previously reported in the last two audit
reports covering fiscal years 2015 through 2020.

Recommendation The Public Utility Regulatory Authority should improve the process
over payments to consultants to properly monitor invoices for
statutory or policy limits, ensure transparency, and comply with
Sections 16-8 and 16-18a of the General Statues.

Agency Response “The Department agrees with the finding is proactively making
changes in the current fiscal period. The Authority has implemented
an internal review, approval, and documentation process for the
retention of consultants under CGS Sections 16-8 or 16-19a. As an
additional level of transparency, each public service company has
been directed to publicly file in Docket 86-09-06re01 on or before
September 1st, for the previous fiscal year ending June 30, a
detailed accounting of all consultant costs paid by the utility,
identifying the costs by the docket number, the agency that retained
the consultant (e.g. PURA, OCC, or DEEP), and the consultant that
performed the work. This will allow the Authority and auditors to
confirm the accuracy of the Authority’s contracting documentation
and cost.”

Finding 7

Controls Over Ground Water Permit Applications

Background The Ground Water Discharge Permit Program regulates discharges

to ground water from any source, including but not limited to large
septic systems, agricultural waste management systems, and all
waste landfills. Applicants for groundwater discharge permits are
required to pay an application fee, as well as an annual fee to cover
the cost of monitoring compliance with permit terms and conditions.
Individual groundwater applications are generally issued for ten or
30 years, depending on the agreement. To renew the permit, the
client must submit a new application a few months prior to
expiration and pay another application fee. Although review and
approval for most applications takes years, DEEP considers the
permits active, even if it has expired, until it renews them.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 12
Counsel, and Connecticut Siting Council 2021 and 2022
 Criteria Section 22a-430(i) of the General Statutes provides for the issuance
of permits for discharge of waters of the state. It also specifies the
duration of these permits.

40 CFR Section 144.36(a) states that permits for Class I and V wells
shall be effective for a fixed term not to exceed ten years. DEEP
applies this stricter term when applicable.

Section 4-182 of the General Statutes provides that, when a

permittee has made a timely and sufficient application for the
renewal of a permit or a new permit with reference to any activity of
a continuing nature, the existing permit does not expire until the
department makes a final determination on the application. DEEP
does not collect fees for water pollution control permits during a
pending application.

Condition Our review of groundwater discharge permits noted 37 permits in a

pending status for more than ten years, including nine pending for
more than 20 years.

Context Fifty-seven permits were pending as of June 30, 2022. During the
audited period, DEEP received six new permit applications, two of
which were closed (issued or withdrawn).

Effect DEEP sacrificed permit fee revenue. The permitting process in the
General Statutes is intended to protect the state’s waters. The
lengthy delays in permitting may allow clients to discharge polluting
substances into the water.

Cause There was a lack of management oversight over pending permits.

Prior Audit Finding This finding has been previously reported in the last four audit
reports covering the fiscal years ended June 30, 2010, through
2020.

Recommendation The Department of Energy and Environmental Protection should

work to issue water discharge permits on time. The department
should immediately address permit applications that have been
pending for more than ten years.

Agency Response “The Department agrees with the finding and continues to make
progress in reducing the permit backlog. The Program lost a
significant number of staff as a result of the recent retirement wave,
that we are diligently looking to replace. Permits are continued in
effect to ensure that annual fee revenue is generated to support
regulated activities of the permittee. This administration has made
further commitments to regulated entities as evidenced by the
Agency’s 20 by 20 goals and recently reissued general permits.”

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 13
Counsel, and Connecticut Siting Council 2021 and 2022
 Finding 8

Noncompliance with Statutory Requirements of the

Nuclear Safety Preparedness Account

Background There is a memorandum of understanding (MOU), dated July 31,

2013, concerning the Nuclear Safety Emergency Preparedness
Program. The parties subject to the MOU include DEEP, the
Department of Emergency Services and Public Protection (DESPP)
Division of Emergency Management and Homeland Security
(DEMHS), and the Office of Policy and Management (OPM). Per the
MOU, the commissioner of DESPP, in consultation with the
commissioner of DEEP, are required to submit a plan and proposed
budget annually to the Secretary of OPM for approval to carry out
the Nuclear Safety Emergency Program (NSEP). The MOU states that
the Public Utilities Regulatory Authority (PURA) will assess the state’s
nuclear licensees in two installments and prorate 70% of the total
assessment billed on July 1 and 30% on December 1 each fiscal
year. These funds are used to support the activities of the program.

DEEP calculates the annual assessment by taking the full OPM

approved budget and billing the utility companies 70% of that
amount in July. When the expenses for the prior fiscal year are
certified, any surplus from the prior year assessment is deducted
from the remaining 30% and the balance is billed to the utilities for
the second installment (approximately December).

Criteria Section 28-31(a) of the General Statutes requires PURA to establish

a nuclear safety preparedness account within the General Fund.
PURA may assess licensees for the program expenses, provided the
balance in the account at the end of the fiscal year does not exceed
$300,000.

Condition The balances for the nuclear preparedness account were

$1,353,530 and $1,391,408 as of June 30, 2021, and 2022,
respectively.

It does not appear DEEP considers the account balance when

preparing the December billing. Since the balance exceeded
$300,000 in each fiscal year, an assessment was not necessary.

Context Budgeted amounts for fiscal years 2021 and 2022 totaled
$5,537,043 and $5,489,723, respectively. The final expenses for
fiscal years 2021 and 2022 totaled $4,183,513 and $4,098,315,
respectively.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 14
Counsel, and Connecticut Siting Council 2021 and 2022
 Effect DEEP appears to be over assessing nuclear licensees.

Cause DESPP, in consultation with DEEP, did not consider the statutory
limitation on the balance in the restricted fund account when
preparing the budget. Furthermore, the MOU does not address the
$300,000 statutory limit on the nuclear safety preparedness account.

Prior Audit Finding This finding has been previously reported in the last four audit
reports covering fiscal years 2010 through 2020.

Recommendation The Department of Energy and Environmental Protection should

consider the balance in the nuclear safety preparedness account
prior to calculating assessments or seek legislation to amend the
balance limitation in Section 28-31(a) of the General Statutes.

Agency Response “The Department agrees with the finding and acknowledges the
Department of Emergency Services and Public Protection’s
(Administering Agency) request to carryforward additional funds
related to unliquidated purchase orders. This was more prevalent
during the audit as unforeseen procurement delays caused by the
pandemic and post pandemic supply chain, delayed delivery of
goods and services to State agencies and municipalities. This
funding supports critical public safety equipment and services. The
$300,000 balance should be maintained although recognition
should be made regarding unliquidated procurements. The
procurements were initiated prior to the close of the fiscal year but
remained pending as delivery dates were extended by vendors. For
some municipalities this is the only source of funding for emergency
preparedness items related to the nuclear operations. We will
continue to work with the Department of Emergency Services and
Public Protection, to coordinate timely procurement and limit
carryforwards into the new fiscal year. The Department of
Emergency Services and Public Protection (DESPP) manages all
Nuclear Safety proceeds. DESPP provides an annual reconciliation
to the Department as outlined in an MOU between DEEP, OPM and
DESPP. The Department has billing responsibilities and budgetary
responsibilities limited to DEEP share of the nuclear assessment. The
management of the Fund, the Budget and expenditures is
completely transparent and accepted by the two utilities.”

Finding 9
Inventory Reporting and Controls

Criteria Section 4-36 of the General Statutes requires each state agency to
maintain inventory records in the form prescribed by the State

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 15
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 Comptroller and to submit an annual report of its inventory balances
to the State Comptroller.

The State Property Control Manual prescribes the inventory

procedures that agencies should follow. These policies and
procedures include:

• The CO-59 property control report should accurately reflect

all capitalized real and personal property as of June 30th.
Agencies preparing the report must use specific queries to
gather the applicable information in the Asset Management
System Module of Core-CT.

• It highly recommends appraisals for works of art and

historical treasures when resources are available. It also
recommends expert appraisals for all permanent collection
pieces over $10,000 every five years.

• Every agency must conduct an annual physical inventory to

accurately track and account for assets as of June 30th.

Condition The department did not comply with the requirements of the State
Property Control Manual. Our review disclosed the following:

CO-59 Reporting

• We found $158,269,649 in variances between ending

balances reported on the fiscal year 2021 and 2022 CO-59
property control report, and balances in Core-CT. In each
year, we noted eight of the nine asset categories from Core-
CT did not agree with the ending balances on the CO-59.
DEEP could not provide support for these variances.

• DEEP did not include the value of fuel in the tanks at its
fifteen fueling stations on its CO-59 property control report.
The department should have reported this balance as stores
and supplies.

• DEEP did not record a value for state-owned software

(capitalized). The department provided us with a listing of
28 applications developed internally as of June 30, 2022.

• DEEP did not report any additions for easements on its CO-
59 property control report for the fiscal year ended June 30,
2021. Per Core-CT, there were $473,500 in easement
additions.

Internal Control

• Our review of ten capital/controllable assets purchased

during the audited period noted two instances in which

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 16
Counsel, and Connecticut Siting Council 2021 and 2022
 DEEP could not locate $11,460 in assets. In another
instance, we found a $26,626 asset in a different location
than listed on the inventory records.

• We noted that DEEP conducted the most recent physical

inventory in fiscal year 2018. During this inventory, the
department only inventoried eighteen items. Most assets
had inventory dates of 2006 or earlier.

• DEEP has not conducted a fine art inventory and has not
appraised any of its fine art since 2000. The department has
reported $760,264 of fine art on its CO-59 since 2009.

Context DEEP reported $607,826,919 and $610,040,406 in real and

personal property on its CO-59 as of June 30, 2021, and 2022,
respectively.

The most recent inventory listing included 7,411 assets valued at

$55,289,132. DEEP purchased 278 assets, totaling $2,652,010,
during the audited period. We randomly selected ten of these
assets, valued at $317,346.

Effect Control deficiencies result in inaccurate and incomplete financial

reporting, as well as a decreased ability to safeguard assets.

Cause The department’s controls were not sufficient to prevent this

condition.

DEEP informed us a lack of staff contributed to this condition.

Prior Audit Finding This finding has been previously reported in the last six audit reports
covering the fiscal years ended June 30, 2006, through 2020.

Recommendation The Department of Energy and Environmental Protection should

strengthen internal controls over inventory to comply with the
requirements in the State Property Control Manual and the State
Comptroller’s reporting instructions.

Agency Response “The Department agrees with the finding and recognizes that there
is a need for more training and oversight for the reporting of the
annual CO-59. As such, GL [general ledger] corrections were not
made for capital assets/additions purchased against incorrect
account codes. The department is finalizing a methodology for
implementing real-time inventory utilizing new tools available in
Core-CT and will be revaluing agency assets including software
development. Several staff have been dedicated to assist in both the
implementation of controls and to assist with ensuring that assets are
properly captured in both CO-59 reporting and on the Core-CT GL.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 17
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 Several steps have been taken by the Department to identify and
correct inaccuracies in the reporting of State-owned assets.

The Department will perform a holistic review of amounts reported

under the “Fine Art” category to determine whether these values
should be represented on the annual CO-59 report and if so, at what
value.”

Finding 10
Controls Over Loss Reporting

Criteria Section 4-33a of the General Statutes requires state agencies to

promptly notify the Auditors of Public Accounts and the Comptroller
of any unauthorized, illegal, irregular, or unsafe handling or
expenditure of state funds or breakdowns in the safekeeping of any
state resources.

Condition DEEP does not have an adequate process to report required matters
to the Auditors of Public Accounts and the State Comptroller in
accordance with Section 4-33a of the General Statutes.

DEEP reported three losses to the Auditors of Public Accounts in

fiscal year 2022 and none in fiscal year 2021. The department did
not promptly report these losses, with delays ranging from 20 days
to two and a half years. We also identified several unreported losses.

Context DEEP reported $607,826,919 and $610,040,406 in real and

personal property on its CO-59 as of June 30, 2021, and 2022,
respectively.

Effect The failure to report losses and breakdowns in internal controls

prevents an independent review by the Auditors of Public Accounts
and the State Comptroller to avoid future losses.

Cause DEEP did not have an adequate process to educate management at

various field locations on its statutory reporting requirements.

Prior Audit Finding The finding has been previously reported in the last three audit
reports covering the fiscal years ended June 30, 2012, through
2020.

Recommendation The Department of Energy and Environmental Protection should

promptly notify the Auditors of Public Accounts and the Office of the

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 18
Counsel, and Connecticut Siting Council 2021 and 2022
 State Comptroller of any losses and irregular handling of funds in
accordance with Section 4-33a of the General Statutes.

Agency Response “The Department recognizes the need to report losses and has taken
steps to improve communications between field staff responsible for
managing assets throughout the state, the Department’s police
department (ENCON) in their role of leading investigations, and
fiscal staff in our Hartford office, that are responsible to report losses
to OSC and the State Auditors. Losses on state property are
reported to ENCON. ENCON will typically lead investigations and
will assist in preparing loss or incident reports. Greater awareness
has been made to ensure that all three groups participate in
finalizing and reporting losses and irregularities to OSC and the
State Auditors.”

Finding 11
Controls Over Fueling Stations and Fuel/Mileage
Reporting

Background DEEP employees obtain gasoline and diesel from several sources,
including fifteen DEEP fueling stations, and Department of
Transportation (DOT)and commercial fueling stations. Conservation
officers and emergency response personnel also may obtain fuel
from Connecticut State Police (CSP) stations.

Criteria The Department of Administrative Services (DAS) General Letter No.

115 (GL-115), Policy for Motor Vehicles Used for State Business,
requires agencies to keep daily mileage logs on a monthly usage
report (Form CCP-40) for each assigned state-owned vehicle. The
operator of the vehicle must certify daily activity as true and correct
and the supervisor must review and confirm the travel.

Good internal controls require that DEEP establish adequate

policies and procedures regarding the use and safeguarding of fuel
at its fueling stations. The department should ensure that employees
accurately prepare manual fuel usage reports and clearly show any
corrections. Employees should always list the equipment number.
Electronic sheets that are prepared from the manual sheets should
identify all errors and irregularities and be provided to management
for review and/or investigation.

DEEP’s Vehicle Policy and Procedure requires employees to

separately record all fuel from state and commercial stations on their
monthly mileage report to the nearest 1/10 of a gallon.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 19
Counsel, and Connecticut Siting Council 2021 and 2022
 Good internal controls require that the fuel received for all vehicles
from state and/or commercial sources be reconciled to the
employee’s monthly mileage reports.

Condition Our review of 293 mileage logs (CCP-40) completed during the
month of April 2022 disclosed the following:

• DEEP employees did not complete mileage logs for every

vehicle. DEEP provided us a listing of 502 of its vehicles as
of April 30, 2022. However, DEEP only made 293 April
mileage logs available for review.

• Twenty-one mileage logs lacked a supervisor’s signature.

At each DEEP fueling station, a monthly fuel sheet is maintained and

updated manually upon pumping. Each month, all sheets are
forwarded to DEEP’s Central Services for entry onto an excel
spreadsheet. We reviewed manual logs and the Excel spreadsheets
for the month of April 2022 and noted the following:

• In fifteen instances, totaling 243 gallons, the fuel entry had

no name. Some had vehicle identification numbers, but
DEEP could not be assured that the employee associated
with the vehicle pumped the fuel.

• In two instances, the ending fuel pump balance did not

match the beginning balance of the next entry. The missing
amounts totaled 38 and 39 gallons.

Context As of April 30, 2022, DEEP maintained a fleet of 502 vehicles, 347
DEEP-owned and 155 leased from DAS. We judgmentally selected
April and reviewed all mileage and fuel logs.

Per the department’s Excel spreadsheets, DEEP fueling stations

pumped 14,295 gallons of gasoline and 3,077 gallons of diesel
during April 2022.

Effect Management may not promptly detect misuse of vehicles or fuel.

Cause Management does not appear to be regularly obtaining all required

mileage logs or reviewing hand-written fuel sheets for accurate
amounts and incomplete entries. In addition, Environmental
Conservation (EnCon) officers do not complete mileage logs,
because they do not believe that the DAS GL-115 applies to them.

DEEP has an antiquated system for monitoring vehicle and fuel

usage. Fuel pumps are accessed using a key in each DEEP vehicle.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 20
Counsel, and Connecticut Siting Council 2021 and 2022
 Prior Audit Finding This finding has been previously reported in the last two audit
reports covering the fiscal years ended June 30, 2015, through
2020.

Recommendation The Department of Energy and Environmental Protection should

ensure that monthly mileage logs are prepared and approved for all
its vehicles. The department should also upgrade its fueling stations
to better account for fuel, or close its stations and require employees
to use Department of Transportation facilities. The department
should ensure that employees accurately complete fuel logs and
include equipment numbers on all entries.

Agency Response “The Department agrees with the finding regarding refueling
stations and the fuel log at each pump and has taken numerous
steps to mitigate the concerns presented. As DEEP fuel tanks reach
the end of their 30 year service life, an evaluation is done to
determine whether or not a replacement is warranted at the location.
Several tanks have been decommissioned already and replacement
tanks that have been installed have the capacity to be outfitted with
electronic fuel tracking measures similar to DOT and CSP tanks.
Additionally, DEEP participated in a statewide LEAN event to
explore the potential for consolidation of state-owned refueling
stations in areas where commercially-owned opportunities were
limited. A number of consolidation opportunities were noted,
however nothing formal has been done towards this effort. The
Department will further evaluate the assignment of WEX fuel cards
to all staff with assigned vehicles to minimize the dependency on
DEEP refueling stations.

The Department acknowledges the finding regarding the CCP-40

form for reporting daily mileage. DEEP believes a modern statewide
means of tracking and reporting mileage using available technology
should be implemented. DAS Fleet Operations has implemented
telematics (GPS) tracking in all leased vehicles which can assist with
daily use reporting, fuel consumption and driver safety compliance.
We will explore adding this equipment in agency owned vehicles
and maximizing its functionality for management of the Agency’s
overall fleet. The current paper-based approach is prone to error,
requires significant staffing resources to acquire, consolidate and
track and offers very limited benefit to agencies from a data utility
perspective.”

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 21
Counsel, and Connecticut Siting Council 2021 and 2022
 Finding 12

Excess Inventory of DEEP-Owned Vehicles and

Controls Over Maintenance

Background The Department of Energy and Environmental Protection purchases

its vehicles or leases vehicles from the Department of Administrative
Services (DAS). DAS vehicles may be leased daily, monthly, or yearly.

DEEP has garages in Thomaston (Western District) and Moosup

(Eastern District) for the maintenance of its vehicles.

Criteria Agencies are responsible for ensuring that their state-owned

vehicles are used in the most cost effective and efficient manner.

A fleet management system should properly document

maintenance costs.

Condition Our review of 293 vehicle mileage reports completed for April 2022
disclosed 105 instances in which a vehicle was used five times or less
during the month. This included 36 instances in which a vehicle had
no reported use. It appears some vehicles are being underutilized.

Our review of controls over vehicle maintenance noted that DEEP

does not have a fleet management system to manage vehicle costs.
DEEP employees prepare a Vehicle/Equipment/Facility Repair
Request form listing the work requested and completed, but the
department does not centrally track forms.

Context As of April 30, 2022, DEEP maintained a fleet of 502 vehicles. This
includes 347 DEEP-owned and 155 leased from DAS. We
judgmentally selected the month of April for review.

Effect The lack of a fleet management system prevents DEEP from

efficiently and effectively managing vehicle utilization and costs.

Cause DEEP did not utilize a fleet management software to track utilization,
monitor service on its vehicles, or document all maintenance
purchases.

Prior Audit Finding This finding was previously reported in the last audit report covering
the fiscal years ended June 30, 2018, through 2020.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 22
Counsel, and Connecticut Siting Council 2021 and 2022
 Recommendation The Department of Energy and Environmental Protection should
analyze its vehicle inventory and determine the number of vehicles
it needs to operate efficiently. The department should improve its
vehicle maintenance system by acquiring software to track its vehicle
repair and maintenance costs.

Agency Response “The Department agrees with the finding and has been working
toward more modern solutions for managing its fleet. This will
provide the tools necessary for management decisions regarding
maintenance and the rightsizing of the DEEP fleet to avoid
unnecessary operating costs associated with idle vehicles.
Additionally, DEEP has begun conversations with DAS Fleet
management regarding the procurement of more vehicles through
DAS and leases back to DEEP as opposed to agency owned. It is
important to note that in certain instances an agency-owned vehicle
provides a better business decision due to DAS refresh cycles. The
initial impacts of COVID had a distinct impact on lack of utilization of
many vehicles in DEEP’s Fleet. As many staff have migrated towards
a hybrid work environment, the need for DEEP to reassess its
baseline for vehicle needs is even more apparent. The
modernization of racking tools like GPS will ensure that the
Department is able to capture its needs holistically.”

Finding 13
Controls Over Disposals

Criteria The State Property Control Manual states that all computer and
electronic equipment deemed no longer useable must be approved
for recycling by the Department of Administrative Services and
recycled in an environmentally appropriate manner per Regulations
of Connecticut State Agencies Section 22a-449(c)-113. Agencies are
instructed to contact the approved state electronics recycling
vendor.

Agencies should promptly remove disposed items from their

inventory listing to ensure accurate reporting.

Condition Our review of nine assets disposed during the audited period
disclosed the following:

• In six instances, DEEP did not promptly remove the asset

from its inventory list following disposal. The delays range
from 25 days to approximately one year.

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 • In four instances, the department could not provide support
that it contacted a recycling vendor to dispose of electronic
equipment.

During a review of firearms inventory, we noted DEEP recorded one

firearm in Core-CT as in service, when it was traded in during May
2020. We discovered that this firearm was part of 39 firearms that the
department traded in. The department did not update any of these
in Core-CT until November 2022, upon our notification.

Context DEEP disposed of 50 and 218 assets in fiscal years 2021 and 2022,
respectively. We randomly selected nine asset disposals during the
audited period.

DEEP had over 600 firearms in inventory as of June 24, 2022.

Effect The failure to promptly remove disposed assets from the inventory
list may result in inaccurate reporting.

Cause The department did not adhere to equipment disposal procedures

in the State Property Control Manual.

Prior Audit Finding This finding has been previously reported in the last audit report
covering the fiscal years ended June 30, 2018, through 2020.

Recommendation The Department of Energy and Environmental Protection should

improve internal controls over equipment disposals to ensure
compliance with the policies and procedures set forth in the State
Property Control Manual. The department should also promptly
remove disposed assets from its inventory list.

Agency Response “The Department agrees with the finding and recognizes the
importance of proper documentation for disposal of state property.
Recent staffing assignment changes with the Unit will result in
increased accountability for documentation and reporting
requirements.”

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 24
Counsel, and Connecticut Siting Council 2021 and 2022
 Finding 14

Controls Over Collection and Documentation of

Emergency Spill Cases

Background DEEP operates an emergency spill response program pursuant to

Section 22a-451 of the General Statutes. If DEEP determines there is
a potential threat to human health or the environment, the
responsible person, firm, or corporation is liable for any expenses
the department incurs investigating, containing, removing,
monitoring, or mitigating discharge, spillage, loss, seepage, or
filtration.

DEEP’s Emergency Response/Spill Prevention Unit responds 24

hours per day to emergencies that result from accidental and
deliberate discharges and uncontrolled releases of chemicals,
hazardous wastes, petroleum products, and other hazardous
materials.

Criteria Section 22a-451 of the General Statutes allows for the recovery of
costs, including the DEEP investigation.

Section 22a-451(c) of the General Statutes states that, if the

responsible person, firm, or corporation of a discharge, spill, or
seepage is unknown, the commissioner shall request the federal
government to assume the contractual obligation of cleaning up the
spill to the extent provided by the federal Water Pollution Control
Act.

DEEP is required to submit annual reports of receivables and

estimated uncollectible amounts to the Office of the State
Comptroller for incorporation in the state’s financial statements.
Accounts receivable records should be accurate and complete. An
adequate system of internal controls should include reconciliation of
receivables and timely collection attempts.

DEEP should accurately record liens as receivables in the correct

amounts.

Sound internal controls over emergency spill responses dictate that

DEEP should maintain adequate documentation for all spills,
regardless of their significance.

Condition DEEP does not recover all potential costs related to its
administration, investigation, or other related Emergency Spill
Response Unit expenses. These expenses include equipment and
personnel costs that the department could potentially recover from

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 25
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 liable parties. We found that unrecovered overtime totaled
$402,739 and $447,809 for the fiscal years ended June 30, 2021,
and 2022, respectively.

DEEP maintains a list of cases in which an unknown party was

responsible for the contamination. We identified 98 of these cases,
totaling $314,920 as of June 30, 2022. DEEP informed us it did not
request the federal government to assume the contractual
obligation of the cleanup costs.

DEEP does not appear to be actively placing liens on these

receivables. The department provided us a lien report as of June 30,
2020, with a $5,122,566 balance. The most recent lien was for a 2010
case.

Our review of GAAP Form 2, as of June 30, 2022, noted that DEEP
reported $33,156,936 in emergency spill receivables with
$8,864,257 considered uncollectible. We believe that DEEP greatly
understated its uncollectible amount. We estimate the uncollectible
amount to be closer to $19,000,000, as a significant portion of the
reported collectible balance has been inactive for many years.

DEEP lacks policies or procedures that require Emergency

Response Coordinators to document a spill that occurs during an
ongoing emergency spill response.

Context The Emergency Response/Spill Prevention Unit responds to more

than one thousand spills each year.

Our estimate of the uncollectible amount included receivables prior

to 2016 with no collections during fiscal year 2022.

Effect DEEP is missing out on the chance to recoup administrative costs

associated with spill response and recoveries from the responsible
party.

Untimely or inaccurate reporting of receivables and uncollectible

amounts may result in misstatements on the state’s financial
statements.

Without adequate documentation, DEEP cannot verify that it took

proper steps to mitigate a spill.

Cause There was a lack of management oversight and failure to implement

statutory cost recovery provisions.

DEEP does not have adequate procedures for the proper

preparation of certain GAAP forms.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 26
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 DEEP lacks formal policies and procedures to document spills. The
Emergency Response/Spill Prevention Unit generally only
documents significant spills.

Prior Audit Finding Parts of this finding have been previously reported in the last five
audit reports covering the fiscal years ended June 30, 2008, through
2020.

Recommendation The Department of Energy and Environmental Protection should

improve its oversight over financial reporting of emergency spill
receivables. The department should implement policies and
procedures pertaining to the Emergency Response/Spill Prevention
Unit’s documentation of spills.

The department should also request the federal government

assume a share of the spill response costs when an unknown party is
responsible for the contamination.

Agency Response “DEEP agrees with the finding and has taken many steps to address
the deficiency within the Spills Cost Recovery Program. The
Department’s primary focus is to relieve the fund from incurring
costs completely by identifying responsible parties at spill incidents
and aligning clean-up costs directly with the party and their
insurance providers. Significant progress has been made reducing
the number of incidents in which the spills fund is open. As noted in
previous audits, the Department participated in multiple LEAN
exercises documenting all components of the program from initial
emergency dispatch calls through receipt processing of the
recovery to include Attorney General Referrals and/or state write-off.
Changes were made requiring emergency spill vendors to expedite
delivery of invoices so that collection attempts can begin on a timely
basis. The agency plans on using computer tablets in the field to
generate authorization for vendors to proceed with clean-up work in
accordance with terms of the state contract. This will ensure that
vendor invoices are accurate and comply with the state contract.
Incident reports will be delivered timely allowing the receivable to
be billed and improving our collection success. Most of the existing
debt is uncollectible. The Department has been working with the
Attorney General’s Office reviewing cases to decide on whether to
pursue collections. If a Responsible Party was identified and has
property or resources available, collection consideration will be
made. If the Responsible Party is unknown or there are concerns
regarding the title of property where a spill incident took place, a
recommendation to discharge the debt as uncollectible will be
made through the statutory process. Discussions with OPM have
been started to facilitate a comprehensive review of old, outstanding
balances for potential write-off. The Department is exploring using
agency resources for lien notices and additional collection services.
We will pursue a third-party collection vendor and/or services of
DAS Collections to assist with recoveries. Regarding the
reconciliation process, the agency reconciles individual spill costs on

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 27
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 a regular basis as each case has expenditure detail from Core-CT
compiled for its basis of the receivable. The fund is reconciled on an
annual basis prior to completion of the annual GAAP report.”

Finding 15

Controls Over Required Reporting

Criteria Section 4-60 of the General Statutes requires a report to the

Governor of annual activities of each budgeted agency.

Section 22a-6r of the General Statutes requires the Department of

Energy and Environmental Protection to submit an annual report on
permitting efforts by its environmental quality division from the
preceding state fiscal year.

Section 22a-133j of the General Statutes requires the Department of

Energy and Environmental Protection to file an annual report on the
activities of the program for the discovery and evaluation of
hazardous waste disposal sites determined to pose a threat to the
environment or public health. The program includes provisions for
the containment and removal of hazardous waste and the mitigation
of the effects of hazardous waste on those sites.

Section 22a-352(i) of the General Statutes requires the Water

Planning Council to submit an annual report on the status of the
development and implementation of the state water plan and any
updates to such plan to the joint standing committees of the General
Assembly having cognizance of matters relating to the environment,
public health, planning and development and energy and
technology.

Section 23-15b(c) of the General Statutes requires the

Commissioner of Energy and Environmental Protection to report to
the legislative Office of Fiscal Analysis on the state parks that
semiannually collect funds.

The Office of the State Comptroller requires each agency to annually

submit closing packages to enable the Comptroller to prepare
accurate financial statements in accordance with generally accepted
accounting principles (GAAP).

Condition We selected five statutorily required reports due during the audited
period and noted the following:

• In three instances, DEEP could not provide support that it

prepared and submitted a required annual report. This

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 28
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 included reports required under Sections 4-60, 22a-6r, and
22a-133j of the General Statutes.

• For the two reports on file, DEEP submitted one late and the
other lacked support for the submission date. DEEP did not
submit the annual report required under Section 22a-352(i),
covering 2021 and 2022, until February 17, 2023. DEEP also
could not provide support that it transmitted the semi-
annual report, required under Section 23-15b(c), to the
Office of Fiscal Analysis.

Our review of the GAAP reporting package for the fiscal year ended
June 30, 2022, noted that DEEP did not complete the package on
time. DEEP submitted most forms, due September 2, 2022, on
September 19, 2022. The department did not submit the final GAAP
2 (Emergency Spill Response) form until December 13, 2022. It did
not appear that DEEP requested or received an extension from the
Office of the State Comptroller.

Context DEEP has at least 40 reporting requirements. Many reports are due
annually, however, some are due semi-annually or every two to three
years. We judgmentally selected five reports, as well as the fiscal year
2022 GAAP reporting package for review.

Effect Intended recipients did not receive statutorily required reports,

which impacts their ability to make informed and timely decisions.

Cause DEEP lacks an adequate centralized tracking system for required

reports.

In our prior audit, DEEP informed us the report required by Section

22a-133j is no longer useful. However, DEEP did not seek to
eliminate that statute.

Prior Audit Finding This finding was previously reported in the last audit report covering
the fiscal years ended June 30, 2018, through 2020.

Recommendation The Department of Energy and Environmental Protection should

comply with all applicable statutory and GAAP reporting
requirements. If information required by the statutes is no longer
relevant or useful, the department should seek legislation to
eliminate the requirement.

Agency Response “The Department agrees with the finding and recognizes the
importance of the reporting requirement. DEEP will review policies
to ensure that reports are published as required by statute and will
request statutory changes to reporting when reports are no longer
valid.”

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 29
Counsel, and Connecticut Siting Council 2021 and 2022
 Finding 16

Lack of Disaster Recovery Plan

Background A comprehensive disaster recovery plan is an essential part of an

organization’s plan for the continuity of operations in the event of a
disaster or other interruption in information technology (IT) systems.

Criteria A disaster recovery plan should include detailed specifications to

ensure the recovery of essential hardware and software. It should
also incorporate systematic procedures for carrying out the recovery
process that prioritizes the tasks to be performed and identifies the
people to perform them. A disaster recovery plan must be tested
regularly. Otherwise, it could fail to execute as expected.

Condition DEEP has an All-Hazards Continuity of Operations Plan. However,

the plan does not include a detailed description of essential
hardware and software to be recovered, and the steps for
performing the recovery process.

Context DEEP relies on its IT systems to perform various agency

administration and reporting.

Effect The absence of a comprehensive disaster recovery plan could

seriously hamper DEEP’s ability to promptly restore information
technology functionality when a disaster strikes.

Cause DEEP believes its All-Hazard Continuity of Operations Plan also

serves as its disaster recovery plan.

Prior Audit Finding This finding has not been previously reported.

Recommendation The Department of Energy and Environmental Protection should

develop a comprehensive information technology disaster recovery
plan. The department should routinely test its plan.

Agency Response “The Department recognizes the importance of protecting its data
and has utilized backup servers for years. Most of DEEP’s servers
have been migrated to the State’s enterprise data centers in
Springfield and Groton. DAS-BITS manages a statewide disaster
recovery plan which includes DEEP data. It is anticipated that all of
DEEP’s servers will be fully migrated in the near future.”

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 30
Counsel, and Connecticut Siting Council 2021 and 2022
 Finding 17

Lack of Segregation of Duties for the Database

Administrator

Background The Department of Energy and Environmental Protection’s Site

Information Management System (SIMS) is a database that manages
several key areas, including accounts receivable (detail of assessed
fees and receipts), permitting and enforcement, and document
management. DEEP considers SIMS to be the subsidiary ledger to
Core-CT and reconciles SIMS to Core-CT monthly.

Criteria Separation of duties is a best practice that requires one person not
be in control of all parts of a transaction or business process.
Information technology duties and areas of responsibilities should
be segregated to reduce the opportunities for unauthorized
modification or misuse of information or services. The most basic
segregation of duties of the information technology function is
separation from user departments. The user department should not
perform its own information technology duties.

Database administrators (DBA) should only design and manage

databases and monitor their usage and performance.

Condition DEEP has two database administrators. We found inadequate

segregation of duties, as both database administrators had user
roles for the same system. One performs several tasks and has full
access to other IT functions such as various SIMS applications,
including permits applications and enforcement, accounts
receivable, common authentication and authorization, and
document management. There were other user roles, including
ambient water quality, stream flow diversion, and underground
storage tank registration. The other database administrator had user
department roles for SIMS applications and permits systems.

Context As of June 30, 2022, there were over 340 users in SIMS, each with
access to at least one of 61 divisions within SIMS.

Effect The database administrators have significant control over the

management and use of critical DEEP systems. There is increased
risk when a DBA has a user role and can also create users.

Cause DEEP does not have enough staff to be able to allow for resources
dedicated solely to database administration tasks. The DEEP
database administrators also support other IT functions including

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 31
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 application support that require them to be able to access
applications to troubleshoot user reported issues.

Prior Audit Finding This finding has been previously reported in the last audit report
covering the fiscal years ended June 30, 2018, through 2020.

Recommendation The Department of Energy and Environmental Protection should

maintain segregation of duties between its database administrators
and user roles.

Agency Response “The Department agrees with the finding and has taken steps to
mitigate the weakness with additional hirings. As indicated in the
finding, access to critical data should be limited to maintain the
integrity of the data. This limitation to access creates a single point
of failure when staffing changes and timely replacements are not
always possible. The Department expects to make significant
improvements in this area, maximizing security design controls that
the Department created when developing its enterprise software.”

Finding 18

DEEP Administered Trust Funds

Background The Department of Energy and Environmental Protection is the

beneficiary of eleven trust funds with a combined balance of
$37,010,127 as of June 30, 2022. DEEP administers eight of the trust
funds, and three are managed by outside sources that periodically
distribute funds to the department.

Criteria Section 3-32 of the General Statutes allows the State Treasurer to
accept any bequest to the state of cash or securities. The Treasurer’s
investment department, established under Section 3-13a of the
General Statues, has investment professionals who can evaluate risk,
invest funds, monitor performance, maintain controls, and oversee
contracts with investment advisors, among other responsibilities.

Bequests include provisions relating to the management and

administration of funds. These funds should be monitored and
reviewed regularly to ensure they are being properly utilized.

Condition In 2013, DEEP an outside investment management bank notified the

department that it no longer intended to service its DEEP accounts.
The Office of State Treasurer requested that the bank continue to
manage these funds until the Treasurer could choose a successor.
However, throughout our audited period, the outside bank
continued to manage the accounts. The accounts were finally

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 migrated to a new bank, under guidance of the Office of the State
Treasurer, effective March 13, 2023.

Our review of the balance in each trustee fund as of June 30, 2022,
disclosed the following investments appeared inactive:

• A $21,808 balance is held in trust to benefit the Shakespeare

Theater State Park. DEEP transferred the related property to
the Town of Stratford in 2005, and the theater burned down
in June 2019. The purpose of the trust is to employ
personnel for the facility’s repairs and restoration.

• A $4,327,293 balance of is held for the development of

Hopemead State Park. However, in the 1970s, the state
decided against developing the park due to streams and
wetlands in the area. It appears that there have been no
withdrawals from this fund in nearly 40 years.

Context There was a $17,092,731 balance in the eight DEEP administered

trust funds as of June 30, 2022.

Effect DEEP does not regularly monitor trust accounts to ensure the
effective use of funds.

Cause DEEP lacks the resources to adequately monitor and administer

investment funds.

Prior Audit Finding This finding was previously reported in the last audit report covering
the fiscal years ended June 30, 2018, through 2020.

Recommendation The Department of Energy and Environmental Protection should

seek advice from the Office of Attorney General regarding the
disposition of Shakespeare Theatre funds and the use of Hopemead
State Park funds.

Agency Response “The Department disagrees with the findings related to

expenditures and continued oversight and monitoring of
investment funds. Reports are reconciled routinely, and progress
has been made to migrate trust assets to a State Treasurer
recommended investment resource. In regard to funding, while
more funding may be available for operational expenditure on a
periodic basis than what has been spent during this audit cycle,
there are periods where higher level of spending is necessary to
properly maintain the infrastructure associated with these sites.
Overspending on routine operations could compromise the
required capital investments in these historic structures and will
impact the future income produced by the corpus of the trust. The
Department will seek advice from the Attorney General on use of the
Hopemead Trust account, which is managed directly by the Office

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 33
Counsel, and Connecticut Siting Council 2021 and 2022
 of the State Treasurer and will continue to work with the Office of the
Attorney General on liquidating the funding for the former
Shakespeare Theatre.”

Auditors’ Concluding While we agree reports seem to be regularly reviewed, it does not
Comments appear DEEP is actively pursuing ways to use these funds.
Hopemead State Park funds have not been spent in over 40 years.

Finding 19
Foundation Designation and Lack of Agreements

Background The Department of Energy and Environmental Protection benefits

from the existence of several “Friends of” organizations that are
associated with various state parks or other facilities. The size and
legal makeup of these organizations varies. Some actively fundraise,
while others exist primarily to provide contributions of time by
members. These organizations generally operate outside of state
control and are governed by their own boards. State employees
sometimes sit on these boards.

By their nature, these organizations often can be operated informally

with weak internal controls and a high turnover of officers. In similar
environments, these conditions have led to misappropriations or the
squandering of assets. In such cases, DEEP may be subject to
criticism and a tarnished reputation. The result can be reduced
participation by other members and difficulty in raising funds. This
translates to a reduction in assistance to DEEP.

The RecycleCT Foundation was established by Section 22a-228a of

the General Statutes. The foundation targets and promotes the
coordination and support of research and education activities and
public information programs aimed at increasing the rate of
recycling and reuse in the state. RecycleCT administers programs in
partnership with DEEP. Most of the funds it received since inception
were from DEEP Supplemental Environmental Penalty funds. The
commissioner of DEEP serves on the board and department staff
provides some administrative support.

Criteria Sections 4-37e through 4-37k of the General Statutes specify

requirements applicable to organizations that meet the definition of
a foundation. These requirements include audit provisions,
whistleblower policies, resource sharing agreements, and related
state agency filing requirements.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 34
Counsel, and Connecticut Siting Council 2021 and 2022
 Reports listing fundraising and other activities by organizations for
the benefit of DEEP parks should be prepared periodically to
provide a true picture of the assistance provided.

Good internal controls require the establishment of written

agreements between DEEP and “Friends of” organizations not
considered foundations to coordinate their activities at state parks
with agency goals. A written agreement also should be established
between RecycleCT Foundation and DEEP for the use of the
department’s staff and resources.

Condition DEEP does not consider any of the “Friends of” organizations to be
foundations. However, based on a review of their websites and tax
forms, these organizations claim to support primarily state parks or
forests.

We also noted that several of the “Friends of” organizations have

access to areas of state parks that are not available to the public or
hold fundraisers when the park is not available to the public. DEEP
staff must be at the park during these events, and the department is
not reimbursed for their hours. In addition, some “Friends of”
organizations operate gift stores at state parks without written
agreements. This includes the Friends of Dinosaur State Park,
Hammonasset, Gillette Castle, and Harkness. However, DEEP did
not provide us with any reports documenting the extent to which the
profits from sales at these stores are used at the parks.

RecycleCT Foundation provides DEEP with annual audit reports.

However, the foundation does not have an agreement with DEEP for
the use of its staff or resources. Our review of board minutes
revealed that a DEEP staff member took and maintained the minutes
for the meetings, was asked to prepare the budget, provided
program updates, reviewed proposals for the school grant program,
and prepared an annual report for the past fiscal year.

Context There are more than 20organizations that could be impacted by one
or more of the above conditions, because they appear to meet the
statutory definition of a foundation.

Effect There is a reduced assurance that DEEP is complying with Sections

4-37e through 4-37k of the General Statutes.

The type of assistance provided by the “Friends of” organizations to

the parks is not formally documented; therefore, we could not
determine how DEEP benefits from these organizations.

DEEP staff dedicated an undetermined number of uncompensated

hours to the RecycleCT Foundation.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 35
Counsel, and Connecticut Siting Council 2021 and 2022
 Cause DEEP does not consider these organizations to be foundations
under the statutory definition and has not entered into written
agreements with them. DEEP informed us it does not believe these
organizations mainly support DEEP, but rather partner with the
department.

Prior Audit Finding This finding has been previously reported in the last three audit
reports covering the fiscal years ended June 30, 2012, through
2020.

Recommendation The Department of Energy and Environmental Protection should

pursue an Attorney General opinion concerning the applicability of
laws governing foundations in relation to “Friends of” organizations.

The department should enter into written agreements with the

“Friends of” organizations detailing their roles and activities and how
they would benefit the state park or forest. The agreements should
require reports from “Friends of” organizations detailing how they
should prepare and provide funds and activities to support the park.
The department also should enter into a written agreement with the
RecycleCT Foundation.

Agency Response “The Department will continue to conduct reviews to ensure that its
relationship with our “Friends of State Parks” groups are done in
accordance with the law. The Department will enter into written
agreements with a “Friends of” group that uses state space in a way
that differs from what the general public is permitted to do,
including operations of gift stores.

The Department has concluded that the “Friends of” groups are not
foundations based on a close review and analysis of the statutes and
a detailed review of prior opinions of the Attorney General on this
subject. That legal analysis and its conclusions and supporting
documents were provided to the Auditors by email dated
12/11/2018.

The Department disagrees with the Auditor’s finding that there is

“no assurance that the funds would go to the state park or forest” if
a “Friends of” group were to cease to exist. The Friends groups are
independent charitable organizations governed, as all charities are,
by the provisions of §3-124, §45a-514 and §47-2 which require that
all gifts given for charitable purposes by used exclusively for the
purposes for which they were raised, and empowers the
Commissioner of Consumer Protection and the Attorney General’s
office with enforcing such requirements.”

Auditors’ Concluding The finding did not state that there is “no assurance that the funds
Comments would go to the state park or forest” if a “Friends of” organization
were to cease to exist.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 36
Counsel, and Connecticut Siting Council 2021 and 2022
 We believe that these “Friends of” organizations meet the definition
of a foundation, as they have provided principally financial and in-
kind (volunteers) support to the department throughout the years. It
would seem reasonable that a donor supporting a particular
“Friends of” organization would believe that the funds would be
used to support or improve a particular park.

The Attorney General’s opinions referenced by DEEP discuss the

establishment of the entity for the principal purpose of receiving or
using private funds that support or improve the state agency. The
opinions also add that determinations of foundation status involve
case-by-case analyses. In its response to us on December 11, 2018,
DEEP noted that it did not believe the Friends of Harkness or any of
its “Friends of” organizations mainly support DEEP but work with
DEEP as a partner.

If DEEP were to refuse the support of these groups, they would need
to revise their bylaws and missions.

Finding 20

Lack of Central Database for Complaints

Background The Department of Energy and Environmental Protection has

several ways for the public to report environmental concerns and
complaints on its website, depending on the type of complaint. The
commissioner’s office also receives daily phones calls, which it
directs to a related DEEP division.

Criteria State agencies that regularly receive citizen complaints should have
a process to ensure that the division logging the complaint
independently investigated and accurately reported the results to
the commissioner and the public. The process should track all
complaints from the date of receipt to resolution.

Condition DEEP does not maintain a central database of all complaints and
their status. DEEP divisions log complaints in various locations and
the department does not have an adequate centralize tracking
system.

Context There are at least five divisions that accept and investigate citizen
complaints.

Effect Without a central, transparent database of all complaints, we do not

know whether the division satisfactorily resolved the complaints in a
timely manner or performed a proper investigation. The failure to

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 37
Counsel, and Connecticut Siting Council 2021 and 2022
 report complaint resolutions to senior management prevents the
independent assessment of the conclusions reached, the suggested
impact to agency procedures, the reconciliation of assessment, and
collection of recommended penalties.

Cause It appears that a lack of management oversight contributed to this

condition.

Prior Audit Finding This finding has been previously reported in the last two audit
reports covering the fiscal years 2015 through 2020.

Recommendation The Department of Energy and Environmental Protection should

implement a centralized tracking system for citizen complaints that
identifies the date received, investigator, and date of resolution.

Agency Response “The Department acknowledges the finding and the importance of
reviewing and responding to citizen complaints and will explore the
potential for the implementation of software for managing such
information.”

Finding 21

Mattress Recycling Audit Report Not Obtained

Background The Mattress Recycling Council administers a mattress recycling

program for Connecticut.

Criteria Section 22a-905a(k) states that, two years after the implementation
of the mattress recycling program and every three years thereafter,
or upon the request of the Commissioner of DEEP, but not more
frequently than once a year, the Mattress Recycling Council shall
have an audit of the program. The audit shall review the accuracy of
the council’s data concerning the program and provide any other
information requested by the commissioner.

Condition DEEP could not provide the required audit reports of the Mattress
Recycling Council. The last report on file was for financial statements
as of December 31, 2016. The council should have audit reports for
2019 and 2022.

Context The most recent audit report for the Mattress Recycling Council
indicated total net assets of $2,408,181 as of December 31, 2016.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 38
Counsel, and Connecticut Siting Council 2021 and 2022
 Effect The Mattress Recycling Council did not comply with the statutes. An
audit could reveal problems with the program.

Cause It appears there was a lack of management oversight concerning

statutory compliance.

Prior Audit Finding This finding was previously reported in the last audit report covering
the fiscal years ended June 30, 2018, through 2020.

Recommendation The Department of Energy and Environmental Protection should

comply with the General Statutes and require that the Mattress
Recycling Council promptly provide the department with the
required audit of the program in accordance with Section 22a-
905a(k) of the General Statutes.

Agency Response “The Department agrees with the finding and recognizes the
importance of the requirement. DEEP will review policies to ensure
that audits are received and available as required by statute.”

Finding 22

Inactive Councils and Committees

Criteria Section 22a-241(c) of the General Statutes establishes an advisory

council to advise the DEEP commissioner on implementation of the
municipal solid waste recycling program. The advisory council also
may study issues related to recycling, including composting and
packaging, and recommend materials that should be banned in the
state.

Section 26-157f establishes a Lobster Restoration Advisory

Committee to advise the DEEP commissioner on matters related to
the development of a lobster conservation program in Long Island
Sound.

Section 22a-65 requires the commissioner to establish a Pesticide

Advisory Council that must meet at least annually.

Condition In our review of five DEEP statutory advisory groups, we noted that
these three were inactive and may no longer be necessary. The
department has not pursued legislation to amend or repeal the
related statutes.

Context DEEP is associated with at least 50 councils, committee, boards, or

commissions. We judgmentally selected five for review.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 39
Counsel, and Connecticut Siting Council 2021 and 2022
 Effect The General Statues include advisory committees that are inactive
and may no longer be necessary.

Cause The Municipal Solid Waste Recycling Program Advisory Council

appears to have been disbanded following the implementation of
the Statewide Solid Waste Management Plan in 2006.

The Lobster V-notch Conservation Program was discontinued in

2014. Therefore, there does not appear to be a need for the
committee.

The Pesticide Advisory Council has been inactive since the early
1990s. DEEP regularly consults with the council’s stakeholders about
related matters.

We could not determine why DEEP has not sought legislative

changes to the related statutes.

Prior Audit Finding This finding has been previously reported in the last two audit
reports covering the fiscal years ended June 30, 2015, through
2020.

Recommendation The Department of Energy and Environmental Protection should

pursue legislation to update or repeal General Statutes which
include related councils or committees that are inactive and may no
longer be necessary.

Agency Response “The Department agrees with the finding and is developing
technical revisions to statutes requiring any boards or committees
that no longer serve a business purpose be repealed.”

Finding 23
Improper Time Reporting

Background The Environmental Conservation (EnCon) Police is a part of the

Department of Energy and Environmental Protection’s Bureau of
Outdoor Recreation. Its mission is to provide natural resource
protection and public safety through education, outreach and
enforcement in the areas of fish and game, boating, commercial
fishing, wildlife management, parks, and forests. EnCon Police have
statewide conservation law enforcement responsibilities and work in
three geographical districts each managed by a district captain and
overseen by a colonel. They are responsible for over 255,000 acres
of agency owned land and water that includes state forests, state
parks, wildlife management areas and boating access areas.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 40
Counsel, and Connecticut Siting Council 2021 and 2022
 EnCon utilizes a computer-aided dispatch (CAD) log to document
when an officer is on duty or responding to a call. The officer radios
into the dispatcher who updates the CAD log to track the officer’s
status.

Most EnCon officers are assigned a state-owned vehicle. These

vehicles are fixed with a GPS device, which is monitored and tracked
by Department of Administrative Services (DAS) software.

Criteria Adequate internal controls dictate that time reporting be accurate,

supported, and reflect hours worked.

Condition We reviewed time reporting by 13 EnCon officers during 32 pay

periods and compared the information to their vehicle GPS data and
noted the following:

• In 70 instances, involving nine officers, the shift start or end

time on the CAD log differed by more than 30 minutes from
the GPS vehicles start/stop time. The CAD log is used
whenever an officer is on duty, whether on a normal shift or
responding to a call. The officer radios in at the beginning
and end of each shift and the CAD log is updated. In 33 of
these instances, involving five officers, the start/stop time
differed by more than one hour.

• In 11 instances, involving three officers, the vehicle stopped

at the officer’s home for greater than one hour during their
shift.

Context As of June 30, 2022, there were approximately 69 vehicles assigned

to 57 EnCon employees. We judgmentally selected 13 officers for
review.

Effect Unsupported or inaccurate time reporting could result in employees

being paid for time they did not work.

Cause EnCon Police do not have adequate controls to prevent these

conditions.

Prior Audit Finding This finding has not been previously reported.

Recommendation The Department of Energy and Environmental Protection should

improve internal controls over its monitoring of Environmental
Conservation Police to ensure the time reported by its officers is
accurate and supported.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 41
Counsel, and Connecticut Siting Council 2021 and 2022
 Agency Response “The Department recognizes the importance of ensuring that time
reporting for all employees reflect hours worked. The Department
does not believe there are any instances of officers being paid for
time they did not work.

Neither the CAD nor GPS logs are the primary tools used to record
worked hours. Timekeeping is handled through scheduling and
reporting time in the Core-CT Time and Labor Module. Staff enter
their time into Core-CT Self Service, and it is reviewed and approved
by their supervisors on a bi-weekly basis. Managerial review is also
conducted on a regular basis. This system is the official time
management system of the agency.

EnCon has additional tools to record service time as noted above.

Officers manage on duty time in CAD through network login or
dispatch service duty call in. The Department acknowledges room
for improvement on CAD reporting. Dispatch handles a myriad of
EnCon calls and officers respond frequently to emergency
situations. Dispatch also manages wildlife, radiation, spills, and other
emergency related calls. This sometimes results in a delay between
an officer radioing into dispatch, and dispatch logging them as on
duty within the software. As noted, CAD is not the primary system for
tracking time, this responsibility rests with supervisors in the chain of
command. Any discrepancies in time are addressed at the
supervisory level. Both CAD and GPS are important tools for
enhancing officer safety and tracking vehicle usage, primarily to
assess maintenance needs; they are not designed to be used for
tracking work hours.

EnCon officers are field based and begin duty from their residence.
Officers are available to respond to emergencies 24 hours a day.
Though their duties are primarily patrol, officers have various other
responsibilities including responding to emails, maintaining
equipment, writing reports, case research, and other administrative
tasks. These duties are generally completed using the officers’ home
or vehicle as an office. Differences between GPS location of the
vehicle and officer’s worked time are expected when officers are
completing these tasks.

The Department believes officer work time is accurately reported in

Core-CT and will continue to seek further time reporting efficiencies
in other existing and new tools available to EnCon officers.”

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 42
Counsel, and Connecticut Siting Council 2021 and 2022
 Finding 24

Improper Paid Administrative Leave

Criteria Section 5-240-5a of the Regulations of Connecticut State Agencies

allow an employee to request a voluntary leave of absence without
pay pending disposition of criminal charges. The agency may place
an employee on a paid leave of absence for up to thirty days,
provided written notice be provided to the employee detailing the
reason, the effective date of the leave, and the duration of the leave.

Condition Our review of two employees on paid leave during the audited
period disclosed the following:

• DEEP placed one employee on paid administrative leave,

pending criminal charges, for more than the allowable 30
days. The employee received $114,983 in paid
administrative leave over 19 months. Of this amount,
$109,239 should not have been allowed because it
exceeded 30 days.

• DEEP placed one employee on paid administrative leave for

11 days but lacked supporting documentation.

Context Two employees received paid administrative leave during the

audited period. We reviewed the circumstances for each employee.

Effect DEEP paid $109,239 in salary and fringe benefit costs for an
employee beyond the 30-day limit in the regulations. The
department did not properly document another employee’s paid
leave.

Cause DEEP waited for the criminal matter to be adjudicated. In the other
instance, the department did not formally document its justification
and approval.

Prior Audit Finding This finding has been previously reported in the last audit report
covering the fiscal years 2018 through 2020.

Recommendation The Department of Energy and Environmental Protection should

comply with requirements concerning employees placed on paid
leave as provided for under Section 5-240-5a of the State
Regulations.

Agency Response “The Department acknowledges the importance of complying with

state agency regulations regarding paid administrative leave. In the

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 43
Counsel, and Connecticut Siting Council 2021 and 2022
 first instance mentioned, the employee was placed on
administrative leave pending criminal charges. This happened
during the COVID19 pandemic when courts were hearing cases at
an extraordinarily slow rate. This led to the employee remaining on
leave for an extended period as management felt it inappropriate
and possibly unsafe to allow the employee to return to work pending
charges. Ultimately the charges were nulled, and the employee
returned to work. In the second instance, the employee resigned
and, due to derogatory comments made by said employee,
management, in concurrence with the Office of Labor relations,
decided the employee should be placed on administrative leave
with pay for the two weeks until his last day. In future, the agency will
seek extension from the appropriate regulatory authorities should
we encounter other extraordinary circumstances such as these.”

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 44
Counsel, and Connecticut Siting Council 2021 and 2022
 STATUS OF PRIOR AUDIT
RECOMMENDATIONS
Our prior audit report on the Department of Energy and Environmental Protection, the Council on
Environmental Quality, the Office of Consumer Counsel, and the Connecticut Siting Council contained
24 recommendations. Four have been implemented or otherwise resolved and 20 have been repeated
or restated with modifications during the current audit.

Prior Current
Recommendation Status

The Department of Energy and Environmental Protection should

improve segregation of duties between payroll and personnel
functions by eliminating conflicting roles. Supervisors should promptly
approve their employees’ timesheets each pay period. If a supervisor is
not available, an appropriate designee with knowledge of the
employee’s attendance should approve the timesheets.

The Department of Energy and Environmental Protection should revise

its overtime and compensatory time policy to document the
preapproval of overtime and compensatory time. The documentation
should include the reason for the time and the justification as to why the
Recommendation 1
work cannot be performed during regular hours.

The Department of Energy and Environmental Protection should

comply with requirements concerning employees on paid leave as
provided under Section 5-240-5a(f) of the State Regulations to
minimize the amount of wages paid to employees on administrative Recommendation 24
leave during an investigation.

The Department of Energy and Environmental Protection should

comply with the Office of the State Comptroller memorandums
concerning the taxable benefit of employees’ non-business use of state
vehicles.

The Department of Energy and Environmental Protection should

ensure that all required forms for seasonal employees are in their
personnel files and that they are signed when necessary. The
department should clarify its policies related to when seasonal
Recommendation 2
employees are entitled to overtime.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 45
Counsel, and Connecticut Siting Council 2021 and 2022
 Prior Current
Recommendation Status

The Department of Energy and Environmental Protection should

strengthen internal controls over inventory to comply fully with the
requirements of the State Property Control Manual and the State
Comptroller’s reporting instructions. Recommendation 9

The Department of Energy and Environmental Protection should

analyze its owned vehicle inventory and determine the number of
vehicles it needs to operate efficiently. The department should improve
its vehicle maintenance system by utilizing software to track its vehicle
Recommendation 12
repair and maintenance purchases.

The Department of Energy and Environmental Protection should inform

the Auditors of Public Accounts and the Office of the State Comptroller
of any losses and irregular handling of funds in accordance with Section
4-33a of the General Statutes. Recommendation 10

The Department of Energy and Environmental Protection should

determine the applicability of laws governing foundations in relation to
“Friends of” organizations.

The department should enter into written agreements with the “Friends
of” organizations detailing their roles and activities and how they would
benefit the state park or forest. The agreements should include reports Recommendation 19
from “Friends of” organizations detailing how they would prepare and
provide funds and activities to support the park. The department also
should enter into a written agreement with the RecycleCT Foundation.

The Department of Energy and Environmental Protection should work

to issue water discharge permits on time. The department should
immediately address permit applications that have been pending for
more than ten years. Recommendation 7

The Department of Energy and Environmental Protection should

recover all potential costs related to the Emergency Spill Response
Unit, improve its collection efforts, and comply with Sections 3-7(a) and
(b) of the General Statutes for the proper write-off of those receivables
Recommendation 14
deemed uncollectible.

The Department of Energy and Environmental Protection should

consider the balance in the nuclear safety preparedness account prior
to calculating assessments.
Recommendation 8

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 46
Counsel, and Connecticut Siting Council 2021 and 2022
 Prior Current
Recommendation Status

The Department of Energy and Environmental Protection should

upgrade its fueling stations to better account for fuel distributed at
pumps used by employees, or close the stations and require
employees to use Department of Transportation facilities. The
department should ensure that employees accurately complete
prepared sheets for fueling stations and show all entries recorded by
equipment number. All employees should complete monthly mileage Recommendation 11
reports accurately and thoroughly on a daily basis. The department
should perform reconciliations between fuel usage on mileage reports
and fuel obtained from various sources.

The Department of Energy and Environmental Protection should

improve internal controls over purchasing card use by complying with
state purchasing card policies.
Recommendation 5

The Public Utility Regulatory Authority should make payments to

consultants from the DPUC/Consumer Counsel Fund. The authority
should then bill the appropriate company for the amount due.
Recommendation 6

The Department of Energy and Environmental Protection should

enhance its process to review and track citizens’ complaints by
recording all complaints in a central database by the date received,
investigator, and the date of resolution. Recommendation 20

The Department of Energy and Environmental Protection should review

the operations of its store for cost-effectiveness. The department
should establish procedures for discarding and writing off obsolete
merchandise and managing inventory items to reduce outdated
inventory. The department should consider making some of its
publications available for online for viewing if they are not selling well.

The Department of Energy and Environmental Protection should

administer trust funds in accordance with the General Statutes, legal
provisions, and good business practice. The department should
consider using more of the funds with significant balances instead of
state funds. The department also should seek advice from the Office of
Recommendation 18
Attorney General regarding the disposition of Shakespeare Theater
funds.

The Department of Energy and Environmental Protection should have

segregation of duties between its database administrators and user
roles.
Recommendation 17

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 47
Counsel, and Connecticut Siting Council 2021 and 2022
 Prior Current
Recommendation Status

The Department of Energy and Environmental Protection should

improve its oversight over GAAP reporting.

Recommendation 14

The Department of Energy and Environmental Protection should

comply with all applicable statutory reporting requirements. If
information required by the statutes is no longer relevant or useful, then
the department should seek legislation to eliminate the requirement. Recommendation 15

The Department of Energy and Environmental Protection should

determine whether there is still a need for the Municipal Solid Waste
Recycling Program Advisory Council, the Lobster Restoration Advisory
Committee, the Pesticide Advisory Council, and other similar groups.
The department should pursue legislation to remove any groups that Recommendation 22
are no longer necessary.

The Department of Energy and Environmental Protection should

comply with the General Statutes and require that the Mattress
Recycling Council promptly provide the department with the required
audit of the program in accordance with Section 22a-905a(k) of the
Recommendation 21
General Statutes.

The Department of Energy and Environmental Protection should

improve controls over equipment disposals and recycling by
complying with statutory requirements and the policies and procedures
set forth in the State Property Control Manual. Recommendation 13

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 48
Counsel, and Connecticut Siting Council 2021 and 2022
 OBJECTIVES, SCOPE, AND
METHODOLOGY
We have audited certain operations of the Department of Energy and Environmental Protection, the
Council on Environmental Quality, the Office of Consumer Counsel, and the Connecticut Siting Council
in fulfillment of our duties under Section 2-90 of the Connecticut General Statutes. The scope of our audit
included, but was not necessarily limited to, the fiscal years ended June 30, 2021 and 2022. The
objectives of our audit were to evaluate the:

1. Department’s internal controls over significant management and financial functions;

2. Department's compliance with policies and procedures internal to the department or

promulgated by other state agencies, as well as certain legal provisions; and

3. Effectiveness, economy, and efficiency of certain management practices and operations,

including certain financial transactions.

Our methodology included reviewing written policies and procedures, financial records, minutes of
meetings, and other pertinent documents; interviewing various personnel of the department, as well as
certain external parties; and testing selected transactions. Our testing was not designed to project to a
population unless specifically stated. We obtained an understanding of internal controls that we deemed
significant within the context of the audit objectives and assessed whether such controls have been
properly designed and placed in operation. We tested certain of those controls to obtain evidence
regarding the effectiveness of their design and operation. We also obtained an understanding of legal
provisions that are significant within the context of the audit objectives, and we assessed the risk that
illegal acts, including fraud, and violations of contracts, grant agreements, or other legal provisions could
occur. Based on that risk assessment, we designed and performed procedures to provide reasonable
assurance of detecting instances of noncompliance significant to those provisions.

We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 49
Counsel, and Connecticut Siting Council 2021 and 2022
The accompanying financial information is presented for informational purposes. This information was
obtained from various available sources including, but not limited to, the department's management and
the state’s information systems, and was not subjected to the procedures applied in our audit of the
department. For the areas audited, we identified:

1. Deficiencies in internal controls;

2. Apparent noncompliance with laws, regulations, contracts and grant agreements, policies, and
procedures; and

3. A need for improvement in management practices and procedures that we deemed to be

reportable.

The State Auditors’ Findings and Recommendations section of this report presents findings arising from
our audit of the Department of Energy and Environmental Protection, Council on Environmental Quality,
Office of Consumer Counsel, and Connecticut Siting Council.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 50
Counsel, and Connecticut Siting Council 2021 and 2022
 ABOUT THE AGENCY
Overview
The Department of Energy and Environmental Protection (DEEP) operates under the provisions of Titles
15 Chapters 263 and 268, 16, 16a, 22a, 23, 25 and 26 of the General Statutes. DEEP has jurisdiction over
all matters relating to the preservation and protection of the air, water, and other natural resources of the
State of Connecticut. The principal areas of operation, stated in terms of broad purpose, are as follows:
conservation of land and water resources, parks and recreation, fish and wildlife, water resource
management, solid waste management, air and water pollution, geological survey, and energy efficiency.

Organizational Structure
DEEP has three divisions: Energy, Environmental Conservation, and Environmental Quality. The Energy
Division includes the Public Utilities Regulatory Authority (PURA), which reviews utility rates and the
Bureau of Energy and Technology Policy, which develops energy efficiency, infrastructure, and alternative
power programs. The Environmental Conservation Division is concerned primarily with natural resources
represented by open spaces and underdeveloped land areas; fish life; streams and coastal areas; and
state-owned parks and forests. The Environmental Quality Division maintains and improves the quality of
the air, land, and water resources of the state by preventing pollution or mismanagement thereof by
private, public, or business interests. Katie Dykes was appointed commissioner effective January 9, 2019
and continued to serve in that capacity during the audited period.

Within the energy division, PURA operates under the provisions of Title 16, Chapter 277, Section 16-1 to
16-50f of the General Statutes. PURA regulates the rates and services of Connecticut’s investor-owned
electricity, natural gas, water, and telecommunications companies and is the franchising authority for the
state’s cable television companies. PURA is responsible for balancing the public’s right to safe, adequate,
and reliable utility service at reasonable rates with the provider’s right to a reasonable return on
investment. PURA monitors utility companies to promote equity among competitors, while customers
benefit from competition and are protected from unfair business practices. As of June 30, 2022, PURA
consisted of three commissioners appointed by the Governor: Chair Marissa Paslick Gillett, Vice-Chair
John W. Betkoski III, and Commissioner Michael Caron.

The Office of Consumer Counsel (OCC) operates under the provisions of Title 16, Chapter 277, Section
16-2a of the General Statutes and is within DEEP for administrative purposes only. OCC advocates for
consumer interests in matters that may affect Connecticut consumers related to public service companies,
electric suppliers, and certified telecommunication providers. OCC participates in regulatory and judicial
proceedings in which interests of Connecticut consumers may be involved, or in which matters affecting
utility services rendered may be involved. OCC is a party to each contested case before PURA and may
appeal decisions in any such proceeding. OCC is under the direction of a consumer counsel, appointed
by the Governor with the advice and consent of either house of the General Assembly. The expenses of
OCC are assessed in accordance with the provisions of Section 16-49. The Governor nominated Claire E.
Coleman to serve as consumer counsel, effective December 3, 2021. She continues to serve in this role.

The Connecticut Siting Council (CSC) established under Title 16, Chapter 277a, Section 16-50j, is within
DEEP for administrative purposes only. The council’s primary mission is to provide a regulatory process
for balancing the need for adequate and reliable public utility services with the need to protect the
environment and ecology of the state. The council, in conjunction with DEEP, reviews and acts on
applications for approval of sites for construction, operations, and maintenance of facilities for certain
electric and fuel transmission lines, electric generating or storage facilities using any fuel, electric

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 51
Counsel, and Connecticut Siting Council 2021 and 2022
substations or switchyards, community antenna television towers and head-end structures,
telecommunication towers and hazardous waste facilities. The CSC chairperson position, a Governor’s
appointment, was vacant as of June 30, 2022.

The Council on Environmental Quality (CEQ), established under Section 22a-11 of the General Statutes,
is within DEEP for administrative purposes only. The nine-member council can receive and investigate
citizen complaints and refer such matters to the appropriate regulatory agency for action. Annual
reporting to the Governor is required. The CEQ chairperson position, a Governor’s appointment, was
vacant as of June 30, 2022.

Significant Legislative Changes

• Public Act 20-9 (September Special Session), effective October 2, 2020, required DEEP to adopt
regulations for reporting and remediating releases of oil, petroleum, chemical liquids or solids,
liquid or gaseous products, or hazardous waste to the land or waters of the state. The regulations
must address remediation supervision, verification, auditing, and any required fees. Furthermore,
starting two years after the adoption of regulations, the commissioner must annually report to the
Governor and the Environment and Commerce committees on the verification audits and post
the report on the DEEP website.

• Public Act 21-2 (June Special Session), effective June 23, 2021, required DEEP to implement a
beverage container recycling grant program to provide forgivable grants for new beverage
container redemption centers in urban centers and environmental justice communities lacking
access to redemption locations. It established a beverage container recycling grant program
account. DEEP must use all the account’s funds for the program. The act required the DEEP
commissioner to issue a grant application process by December 1, 2021. It caps the amount of
an awarded grant at $150,000 in any fiscal year and limits the use of grant funds to infrastructure,
technology, and other costs associated with establishing a redemption center.

• Public Act 21-48, effective September 1, 2021, required DEEP to establish an energy efficiency
retrofit grant program using available federal or other funds. It authorizes the DEEP commissioner
to receive funds from the federal government, corporations, associations, or individuals to fund
the program.

• Public Act 21-159, effective January 1, 2022, required the DEEP commissioner to establish and
administer a grant program, subject to the availability of federal funding, to support the
deployment of broadband service. It allows the commissioner to employ outside consultants to
develop and implement the program. The act also required DEEP, by December 1, 2022, to
submit a biennial report to the Governor on broadband deployment.

Financial Information
During the fiscal years ended June 30, 2021, and 2022, DEEP activity was accounted for in the General
Fund, Special Revenue Funds, Capital Project Funds, Enterprise Funds, and Fiduciary/Trust Funds. A
summary of these amounts is presented below.

GENERAL FUND
The General Fund accounts for general operations not required to be accounted for in another fund.
Revenues and expenditures during the audited period, and preceding year, are summarized below.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 52
Counsel, and Connecticut Siting Council 2021 and 2022
 Fiscal Year Ended June 30,

Receipts 2020 2021 2022

Licenses and Sales/Use Tax $ 11,669,895 $ 12,495,283 $ 11,185,037
Fees 12,277,408 16,380,937 13,742,650
Permits 5,912,642 8,904,758 7,643,508
Sales – Commodities and Services 49,000 61,558 36,610
Rents, Fines and Escheats 2,667,255 2,510,920 1,237,793
Refunds and Miscellaneous (454,055) (855,875) (625,444)
Total $ 32,122,145 $ 39,497,581 $ 33,220,154

The increase in revenue from fiscal year 2020 to 2021 was largely due to an extension of annual fees due
in fiscal year 2020 to fiscal year 2021 because of COVID-19. The return to the standard fee schedule,
coupled with a decline in the number of sportsman licenses contributed to the reduction from fiscal year
2021 to 2022.

Fiscal Year Ended June 30,

Expenditures 2020 2021 2022

Personal Services & Benefits $ 41,709,287 $ 44,263,567 $ 46,005,827
Premises and Property Expenses 2,095,916 1,222,114 1,251,940
Purchases & Contracted Services 3,266,942 4,281,780 5,055,787
Information Technology 1,774,017 1,897,210 1,978,403
Motor Vehicle Costs 551,074 431,106 609,357
Purchased Commodities 926,457 1,088,515 1,198,761
Capital Outlays 221,694 475,063 401,984
Fixed Charges 291,635 246,215 129,360
Employee Expenses 215,106 195,706 154,375
Other Charges 8,145 (86,658) 50,020
Total $ 51,060,273 $ 54,014,618 $ 56,835,814

The increase in expenditures throughout the audited period was primarily due to approved wage
increases.

SPECIAL REVENUE FUNDS

DEEP utilizes special revenue funds to account for receipts and expenditures for specific programs. The
most significant receipts and expenditures were for the Federal and Other Restricted Accounts,
Consumer Counsel/DPUC Fund, and Small Town Economic Assistance Program (STEAP) Grants to Local
Government funds.

Federal and Other Restricted Accounts Fund

The Federal and Other Restricted Accounts Fund accounts for federal and other revenue that is restricted
from general use. The department manages numerous federal programs, and the largest were the
Performance Partnership Grant and the Title VI Clean Water Fund Cap Grant. The Regional Green House
Gas Initiative (RGGI) and the Passport to the Parks account had the largest impact on non-federal aid.
Revenues and expenditures during the audited period, and preceding year, are summarized as follows.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 53
Counsel, and Connecticut Siting Council 2021 and 2022
 Fiscal Year Ended June 30,

Revenue 2020 2021 2022

Non-Federal Aid-Restricted $ 55,843,249 $ 74,822,981 $ 102,297,219
Federal Aid-Restricted 54,852,310 33,379,788 61,196,368
Community Investment Account 2,670,721 4,122,364 4,052,539
Grant Transfers and Other 718,185 1,306,301 (32,635)
Total $ 114,084,465 $ 113,631,434 $ 167,513,491

The fluctuations in federal aid from fiscal year 2020 through 2022 is primarily due to the timing of
drawdowns. The increase in non-federal aid is the result of several factors, mainly the deferments of fiscal
year 2020 fees to 2021, because of COVID-19, and aid carried forward in fiscal year 2022 for the newly
established solid waste and t passport to the parks accounts.

Fiscal Year Ended June 30,

Expenditures 2020 2021 2022

Personal Services & Benefits $ 42,808,332 $ 45,938,760 $ 46,806,189
Fixed Charges – Grants 31,411,662 16,636,446 31,463,768
Other Charges – Includes RGGI 14,592,333 23,899,910 46,586,173
Purchases & Contracted Services 8,272,616 -2,260,864 5,161,197
Capital Outlays 3,636,503 3,036,025 2,091,002
Premises and Property Expenses 3,153,451 7,985,789 -890,111
Capital Outlays – Equipment 1,409,800 757,968 332,894
Information Technology 1,517,211 3,046,169 1,339,956
Motor Vehicle Costs 1,516,355 1,682,016 1,931,699
Purchased Commodities 1,327,297 1,307,318 1,357,108
Employee Expenses 258,123 167,423 197,240
Capital Outlays-Building 2,074 40,860 529,179
Total $ 109,905,757 $ 102,237,820 $ 136,906,294

The decrease in expenditures from fiscal year 2020 to 2021 was primarily due to a significant reduction
in fixed charges. This was mainly due to the timing of a significant increase in federal grants from fiscal
year 2021 to 2022. In addition, coding corrections in fiscal year 2021 and 2022 impacted the increase to
the other charges category.

Consumer Counsel/DPUC Fund

This fund includes receipts and expenditures for the Public Utilities Regulatory Authority, formerly known
as the Department of Public Utility Control, and the Office of Consumer Counsel (OCC). PURA is part of
the energy branch of DEEP, and OCC is part of DEEP for administrative purposes only. PURA expenses
and revenue are accounted for in this fund, a special revenue fund in accordance with Section 16-48a of
the General Statutes. Amounts in this fund may be expended only pursuant to appropriation by the
General Assembly, and any balance remaining in the fund at the end of any fiscal year is to be carried
forward to the succeeding fiscal year. Receipts consist primarily of assessments on utility companies.
Revenues and expenditures during the audited period, and preceding year, are summarized below.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 54
Counsel, and Connecticut Siting Council 2021 and 2022
 Fiscal Year Ended June 30,

Revenue 2020 2021 2022

Recoveries of Expenses $ 24,796,529 $ 26,661,761 $ 33,263,852
Fees for Examination 14,500 19,500 15,900
Other Fees and Refunds 50 30 90
Total $ 24,811,079 $ 26,681,291 $ 33,279,842

Fiscal Year Ended June 30,

Expenditures 2020 2021 2022

Personal Services & Benefits $ 22,449,163 $ 25,444,571 $ 26,755,339
Premises and Property Expenses 618,216 693,464 763,762
Indirect Overhead – Federal - (990,993) (246,441)
All Other Expenditures 1,091,837 1,175,895 967,846
Total $ 24,159,216 $ 26,322,937 $ 28,240,506

Revenues and expenditures remained relatively flat from fiscal years 2020 through 2022, with the only
significant increase related to revenue from fiscal year 2021 to 2022. This was attributable a $6 million
increase to the public utility company base assessment.

Grants to Local Governments and Other Funds

The Grants to Local Governments and Others Fund is used by various state departments to account for
bond authorizations for grants to local governments, organizations, and individuals. Expenditures totaled
$7,438,027 and $16,283,476 during the 2021 and 2022 fiscal years, respectively. Most of the
expenditures were for remediation at hazardous waste disposal sites, land acquisition grants, and the
Connecticut Bikeway.

ENTERPRISE FUNDS
Clean Water Fund

The Clean Water Fund (CWF) operates under the provisions of Section 22a-475 through 22a-483 of the
General Statutes. Within the fund, there is a water pollution controls state account and a water pollution
control federal loan account. The fund provides for financial assistance to municipalities and others for
the planning, design, and construction of water quality projects and improvements. Revenues are derived
from federal grants and can fluctuate depending on timing of drawdowns. Revenues totaled $8,839,539
and $8,262,716 during fiscal years 2021 and 2022, respectively. Expenditures during the audited period,
and preceding year, are summarized below.

Fiscal Year Ended June 30,

Expenditures 2020 2021 2022

State Account $ 81,713,258 $ 68,380,033 $ 45,822,092
Federal Account 130,906,697 118,372,602 108,993,923
Total $ 212,619,955 $ 186,752,635 $ 154,816,015

Expenditures represent DEEP expenditures only and were primarily for grants and administrative
expenses from the state account and loans from the federal account.

Independent public accountants audited the Clean Water Fund for the period under review.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 55
Counsel, and Connecticut Siting Council 2021 and 2022
CAPITAL AND NON-CAPITAL PROJECT FUNDS
Expenditures from capital and non-capital project funds totaled $21,335,947 and $26,332,396 during the
2021 and 2022 fiscal years, respectively. These were primarily for community conservation and
development, energy projects, and state park renovations. There were no revenues recorded for the
Capital and Non-Capital Project Funds.

TRUST FUNDS
DEEP is responsible for maintaining administrative control over eight accounts, with other trustees
responsible for three other accounts. There was a $37,010,128 in balance of all these accounts as of June
30, 2022.

COUNCIL ON ENVIRONMENTAL QUALITY

The Council on Environmental Quality (CEQ) is within DEEP for administrative purposes only. The
accounting of operations is reported in the Federal and Other Restricted Accounts Fund. CEQ assesses
and reports on Connecticut’s environment and advises state agencies on environmental impacts of
proposed construction projects. CEQ also investigates citizen complaints and allegations of violations of
environmental laws. There were no significant revenues for CEQ during the audited period. CEQ
expenditures were $300,804 and $357,584 during the 2021 and 2022 fiscal years, respectively.

OFFICE OF CONSUMER COUNSEL

The Office of Consumer Counsel (OCC) advocates for consumer interests in matters that may affect
Connecticut consumers related to public service companies, electric suppliers, and certified
telecommunication providers. The accounting of operations is reported in the Consumer Counsel/DPUC
Fund. There were no significant revenues for OCC during the audited period. OCC expenditures during
the audited period, and preceding year, are summarized below.

Fiscal Year Ended June 30,

Expenditures 2020 2021 2022

Personal Services & Benefits $ 1,738,428 $ 1,936,993 $ 2,368,727
Premises & Property Expenses 91,990 104,650 116,290
Purchases & Contracted Services 61,821 81,158 32,653
Indirect Expenses - 55,553 33,590
Employee Expenses & Allowances 43,184 29,633 29,175
Other 12,126 13,731 41,491
Total $ 1,947,549 $ 2,221,718 $ 2,621,926

The increase in expenditures throughout the audited period was primarily due to approved wage
increases.

CONNECTICUT SITTING COUNCIL

The Connecticut Sitting Council (CSC) is with DEEP for administrative purposes only. The accounting of
operations of the council are within the Siting Council Fund. Receipts consisted primarily of assessments
on applicable energy and telecommunications services, and recoveries of expenditures from applicants
for costs incurred for conducting hearings and proceedings, in accordance with Section 16-50v of the

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 56
Counsel, and Connecticut Siting Council 2021 and 2022
General Statutes. Revenues and expenditures during the audited period, and preceding year, are
summarized below.

Fiscal Year Ended June 30,

Revenues 2020 2021 2022

Expense Recovered by Public Service $ 887,743 $ 1,333,064 $ 1,937,457
Expense Recovered by Electric Power 722,580 886,543 785,692
Environmental Certification Fees 633,518 747,118 897,569
Other Miscellaneous Fees 2,114 732 201
Recoveries - General (735,579) (756,382) (748,460)
Total $ 1,510,376 $ 2,211,075 $ 2,872,459

Revenue fluctuates based on the number of dockets and petitions filed by each industry and the actual
expenses and corresponding reimbursements related to each case.

Fiscal Year Ended June 30,

Expenditures 2020 2021 2022

Personal Services & Benefits $ 1,277,242 $ 1,377,696 $ 1,499,657
Other Charges – Indirect Overhead (48,634) 40,504 122,745
Purchases & Contracted Services 48,127 131,503 99,893
Premises and Property Expenses 55,920 63,670 70,573
Purchased Commodities 1,170 125 1,613
Information Technology 1,095 9,366 12,665
Employee Expenses & Allowances 2,018 550 550
Motor Vehicle Costs 5,097 5,058 4,889
Total $ 1,342,035 $ 1,628,472 $ 1,812,585

Expenditures increased throughout the audited period primarily due to approved wage increases.

Department of Energy and Environmental Protection, Council on Environmental Quality, Office of Consumer 57
Counsel, and Connecticut Siting Council 2021 and 2022