Connecticut Release-Based Cleanup Regulations
Connecticut’s new Release-Based Cleanup Regulations (RBCRs) mark a significant shift in the state’s environmental remediation framework. Replacing the Connecticut Property Transfer Act, the new approach focuses cleanup obligations on actual releases of hazardous substances or petroleum rather than property sales or ownership changes. The goal is to streamline reporting and remediation, align Connecticut with practices used in most other states, and reduce investigation burdens in real estate transactions while continuing to protect public health and the environment.
Effective March 1, 2026, the RBCRs apply to individuals and entities that create or maintain a release to land or waters of the state. “Creators” include parties responsible for causing a release, while “maintainers” include property owners, tenants, or others in legal possession who become aware of contamination. The regulations establish reporting and remediation requirements based on risk tiers, with timelines and oversight varying by the nature and severity of the release. The program also formalizes roles for Licensed Environmental Professionals (LEPs) and introduces Permitted Environmental Professionals (PEPs) to support compliance verification and cleanup activities.
Organizations subject to the RBCRs should evaluate properties for known or potential releases, update due diligence practices to reflect release-triggered obligations, and prepare for reporting and remediation requirements that arise upon discovery of contamination. Sites currently in the Transfer Act program will continue toward closure or may transition to the RBCR framework through established mechanisms. Proactive planning with environmental professionals can help organizations navigate compliance responsibilities and regulatory timelines under the new system.