Rain Check: Many Connecticut Schools May Now Be Subject to Requirements Regarding Stormwater Management

Connecticut has long required certain commercial and retail entities to comply with environmental requirements governing the discharge of stormwater on their properties.  These requirements and rules are set forth under the General Permit for the Discharge of Stormwater Associated with Commercial Activities (“CSGP”), issued by the Connecticut Department of Energy and Environmental Protection (“DEEP”).

On December 1, 2025, DEEP issued a revised CSGP that significantly expands the scope of this permit in a way that is directly relevant to schools and educational service providers in Connecticut, including both public and private schools. As a result, many school campuses that were not previously subject to the CSGP may now be required to obtain coverage and comply with new stormwater management obligations.

Expanded Applicability to Schools

The revised CSGP continues to apply to owners or operators of sites with five or more acres of contiguous impervious surface (such as rooftops, parking lots, driveways, and walkways). What has changed is the list of land uses that are now regulated.

Under the revised permit, educational services (defined to include public and private, elementary, secondary schools as well as colleges, universities and professional schools) are expressly included within the covered categories that must comply with the CSGP. This means that school properties that have sufficiently large impervious areas must now evaluate whether their campuses are subject to the CSGP, even if they were not previously regulated.  If they are subject to the CSGP, they will need to take immediate steps to ensure compliance.

In addition, the revised permit includes expanded provisions addressing responsibility where a site is occupied by multiple users or tenants. Schools that lease space to third parties, share facilities, or operate on multi-tenant properties should pay close attention to how compliance responsibilities are allocated between property owners and occupants.

Core Compliance Requirements

Entities covered under the CSGP must prepare and implement a site-specific Stormwater Management Plan (“SMP”). The SMP must identify potential sources of stormwater contamination and include best management practices designed to minimize pollutant runoff.

For school campuses, these practices may include regular sweeping of parking areas and other paved surfaces, routine maintenance of catch basins and drainage systems, spill prevention and response procedures, and staff training related to stormwater protection.

Any school subject to the CSGP must also prepare a detailed site plan showing impervious surfaces, drainage features, and outfalls, and conduct annual stormwater sampling along with quarterly inspections, monitoring, and reporting. DEEP has published a Fact Sheet and an FAQ that provide additional detail on these requirements.

Registration Timing and Fees

Schools who are subject to the CSGP must first register with DEEP. Registration under the revised CSGP opened on December 1, 2025, through DEEP’s online permitting system. The registration fee is $625, with a reduced fee available for municipalities.

Key compliance deadlines include:

• April 1, 2026: Deadline for facilities that were already covered under the prior version of the CSGP.
• December 1, 2026: Deadline for existing sites that were not previously required to obtain CSGP coverage but are now subject to the expanded permit scope.

School districts and educational institutions should not assume that these deadlines are distant. The steps required to determine applicability and prepare for compliance are often site-specific and can require significant lead time.

Next Steps for Schools and Educational Institutions

Schools and educational service providers with large campuses should begin evaluating their properties now to determine whether their properties meet the CSGP applicability thresholds. This entails careful assessment of whether the school meets the threshold criteria of having five or more acres of contiguous impervious surface (such as rooftops, parking lots, driveways, and walkways).  Early coordination with experienced legal counsel and qualified environmental consultants can help institutions understand their obligations, manage compliance efficiently, and reduce enforcement risk.

Conversely, if a school determines that its property is not subject to the CSGP—most commonly because it has less than five acres of contiguous impervious surface—it is important to document that determination and retain it in institutional records in the event of future regulatory inquiry.

The revised CSGP represents a meaningful shift in Connecticut’s stormwater permitting framework, and schools should take proactive steps to ensure they are prepared.

Interested in More Information?

Join Shipman environmental attorney Alfredo Fernandez at the Connecticut Association of Independent Schools’ Annual Conference on January 27, 2026 at Waters Edge in Westbrook for a robust presentation on this topic!