Conn. Gen. Stat. » Title 22a — ENVIRONMENTAL PROTECTION · Chapter 439 — Department of Energy and Environmental Protection. State Policy
Connecticut General Statutes

Conn. Gen. Stat. § 22a-19 (2026)

Administrative proceedings

✓ current as of May 2026
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(a)(1) In any administrative, licensing or other proceeding, and in any judicial review thereof made available by law, the Attorney General, any political subdivision of the state, any instrumentality or agency of the state or of a political subdivision thereof, any person, partnership, corporation, association, organization or other legal entity may intervene as a party on the filing of a verified pleading asserting that the proceeding or action for judicial review involves conduct which has, or which is reasonably likely to have, the effect of unreasonably polluting, impairing or destroying the public trust in the air, water or other natural resources of the state.

(2) The verified pleading shall contain specific factual allegations setting forth the nature of the alleged unreasonable pollution, impairment or destruction of the public trust in air, water or other natural resources of the state and should be sufficient to allow the reviewing authority to determine from the verified pleading whether the intervention implicates an issue within the reviewing authority's jurisdiction. For purposes of this section, “reviewing authority” means the board, commission or other decision-making authority in any administrative, licensing or other proceeding or the court in any judicial review.

(b) In any administrative, licensing or other proceeding, the agency shall consider the alleged unreasonable pollution, impairment or destruction of the public trust in the air, water or other natural resources of the state and no conduct shall be authorized or approved which does, or is reasonably likely to, have such effect as long as, considering all relevant surrounding circumstances and factors, there is a feasible and prudent alternative consistent with the reasonable requirements of the public health, safety and welfare.

(1971, P.A. 96, S. 6; P.A. 06-196, S. 256; P.A. 13-186, S. 1.)

History: P.A. 06-196 made a technical change in Subsec. (b), effective June 7, 2006; P.A. 13-186 amended Subsec. (a) by designating existing provisions as Subdiv. (1) and adding Subdiv. (2) re verified pleadings.

Could not have been invoked in a manner so as to enable the trial court to determine whether P.U.C. acted illegally or exceeded or abused its powers. 165 C. 687. Cited. 170 C. 47; 175 C. 483; 184 C. 51; 188 C. 141. Statute is not intended to expand jurisdictional authority of an administrative body whenever an intervenor raises environmental issues. 192 C. 247. Cited. Id., 591; 204 C. 38; Id., 212; 209 C. 609; 212 C. 157; Id., 710. Agricultural land is not a natural resource protected under statute. Id., 727. Cited. 215 C. 474; 218 C. 580; 220 C. 54; 222 C. 98; 225 C. 1; 226 C. 205; Id., 579; Id., 792; 231 C. 934; 234 C. 488. Judgment of Appellate Court in 35 CA 646 reversed; case remanded for determination of whether commission properly applied provisions of section. 235 C. 448. Cited. 237 C. 135; 239 C. 124; Id., 786. Legislature intended that, under Sec. 8-30g(c), planning and zoning commission bears burden of proving that public interest cannot be protected by reasonable changes to applicant's proposed development and such burden is not inconsistent with section. 256 C. 674. Section, as well as other provisions of Environmental Protection Act, reveals no language that suggests legislature intended to give environmental intervenors under section the right to appeal from administrative matters not otherwise appealable; section does not create an independent right of appeal, but only allows intervention in an appeal otherwise allowed by statute. 266 C. 338. Section's plain and unambiguous language provides town with right to intervene for environmental protection purposes in the judicial review of decisions of its wetlands agency and zoning commission and does not conflict with Secs. 8-1 and 22a-42, which delegate municipal authority to such agencies. 280 C. 405. Intervenors before inland wetlands commission were entitled to appeal to trial court from commission's decision pursuant to Sec. 22a-43; an intervenor can prevail on appeal not only by proving that proposed development likely would cause harm to wetlands, but also by proving an inland wetlands commission's decision was not based on a determination, supported by substantial evidence, that the development complied with governing statutes and regulations and would not cause such harm. 289 C. 12.

Cited. 12 CA 47; 13 CA 400; 17 CA 320; 23 CA 188; 26 CA 599; Id., 942; 27 CA 479; 30 CA 204; 32 CA 340; 35 CA 646; judgment reversed, see 235 C. 448; 41 CA 89; Id., 120. Statute does not permit a nonparty to appeal if no party from the underlying proceeding is engaged in an appeal. 57 CA 589. Environmental intervenor abdicated right to approve settlement between plaintiff and defendant by failing to attend hearing and present evidence. 127 CA 634. Plaintiff forfeited right to consent to settlement agreement by failing to raise environmental issues as an intervenor at remand hearing. 133 CA 173. Public hearing on environmental impact evaluation in which the plaintiff sought to intervene was not a “proceeding” under section and department had discretion to reject plaintiff's petition; further, if department had wrongfully denied plaintiff's petition, such action would not constitute a violation of plaintiff's constitutional rights because section does not create a constitutional right of intervention. 203 CA 419.

Cited. 35 CS 145; 41 CS 184; 42 CS 57. Nonprofit environmental advocacy corporation that properly filed notice of intervention at a zoning commission hearing in accordance with Subsec. (a) has standing to appeal environmental issues related to zoning commission's decision; the fact that, if as alleged, defendant failed to act on the application to intervene cannot deprive the corporation of right to intervene and the concomitant right thereby to appeal on environmental issues. 48 CS 594.

Subsec. (a):

Cited. 206 C. 554; 218 C. 821; 220 C. 476; 233 C. 486. Does not authorize an intervenor to raise environmental issues that are outside jurisdiction of the agency conducting the proceeding into which the party seeks to intervene; intervenor is limited to raising environmental issues that are within jurisdiction of the agency in question; section not intended to expand jurisdictional authority of an administrative body whenever an intervenor raises environmental issues; intervention petitions filed under statute must contain specific factual allegations setting forth the environmental issue intervenor intends to raise. 259 C. 131.

Cited. 26 CA 185; 28 CA 780; 37 CA 166; 40 CA 75; 41 CA 39. Trial court finding re lack of standing reversed because plaintiff who lived down river from proposed wastewater treatment plant filed notice of intervention in accordance with section and therefore had standing. 62 CA 600. Trial court decision striking verified pleading filed by town council as proposed intervenor in matters where zoning commission and inland wetlands and watercourse agency were named defendants reversed; court declines to find exception to citizen intervention provision of Environmental Protection Act, finding no legislative intent that would support a rule barring municipalities from utilizing provisions of Subsec. to intervene in appeals from decisions of their land use agencies. 87 CA 537. Without accurate notice of date the motion to open and modify the stipulated judgment was to be heard, intervenors were deprived of right to file motions to intervene in a pending action; public nature of hearing was not adequate for purposes of section if any person or other legal entity did not have notice that modified judgment was being presented for judicial review. 177 CA 779; judgment affirmed, see 331 C. 701.

Subsec. (b):

Trial court properly held that dispositive issue before planning and zoning commission was whether the proposal would cause unreasonable impairment of natural resources so as to require commission to consider alternatives; once commission made no finding of unreasonable impairment of natural resources, it no longer had an obligation to consider alternative plans. 73 CA 647. No substantial evidence to support denial of application on grounds that wetlands would be negatively impacted by sediment and siltation, by changes to hydrology of site, total loss of certain wetland or negative impact from acid generation from exposed rock. 130 CA 69.

Cited. 43 CS 386.

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Notes of Decisions
Cited in 142 cases (10 in the last 5 years), 1974–2026 · leading case: Nizzardo v. State Traffic Comm'n, 788 A.2d 1158 (Conn. 2002).
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Nizzardo v. State Traffic Comm'n, 788 A.2d 1158 (Conn. 2002). · cites it 192× “The issues in this certified appeal are whether: (1) the denial of a notice of intervention filed in an administrative proceeding pursuant to General Statutes § 22a-19, 2 is a “final decision,” within the *134 meaning of General Statutes § 4-183 (a), 3 for purposes of filing an…”
Avalonbay Communities, Inc. v. Zoning Comm'n, 908 A.2d 1033 (Conn. 2006). · cites it 165× “The issue presented in these certified appeals is whether a municipality, acting through its town council, can intervene in appeals to the Superior Court from decisions of the municipality's inland wetlands and watercourses agency and its zoning commission pursuant to General…”
Finley v. Inland Wetlands Com'n of Town of Orange, 959 A.2d 569 (Conn. 2008). · cites it 92× “[4] General Statutes § 22a-19 provides: "(a) In any administrative, licensing or other proceeding, and in any judicial review thereof made available by law, the Attorney General, any political subdivision of the state, any instrumentality or agency of the state or of a political…”
Quarry Knoll II Corp. v. Plan. & Zoning Comm'n, 780 A.2d 1 (Conn. 2001). · cites it 39× “(individual defendants), had intervened in the administrative proceedings before the commission to raise environmental issues pursuant to General Statutes § 22a-19. 2 *678 The plaintiffs appealed from the denial of each application to the Superior Court, pursuant to General…”
Avalonbay Communities, Inc. v. Zoning Comm'n, 867 A.2d 37 (Conn. App. Ct. 2005). · cites it 69× “At that time, the town of Stratford through its legislative body, the town council (town), filed in each case a verified pleading pursuant to General Statutes § 22a-19 (a), the citizen intervention provision of the EPA, claiming, in essence, that the plaintiff's proposed…”
Red Hill Coalition, Inc. v. Town Plan & Zoning Comm'n, 563 A.2d 1347 (Conn. 1989). · cites it 43× “3 The plaintiffs claim on appeal that the trial court erred in concluding that the TPZ was not required to consider alternatives that would prevent or reduce the impairment or destruction of agricultural land pursuant to General Statutes § 22a-19 (b). 4 Further, the coalition,…”
Paige v. Town Plan & Zoning Comm'n, 646 A.2d 277 (Conn. App. Ct. 1994). · cites it 71× “2 On appeal, the plaintiffs claim that the trial court improperly (1) found that trees and wildlife are not natural resources pursuant to General Statutes § 22a-19, (2) found that the proposed subdivision was not a cul-de-sac as defined in § 2.”
Fort Trumbull Conservancy, LLC v. Alves, 815 A.2d 1188 (Conn. 2003). · cites it 20× “’ General Statutes § 22a-16. Second, any person or other entity, without first having to establish aggrievement, may intervene in any administrative proceeding challenging ‘conduct which has, or which is reasonably likely to have, the effect of unreasonably polluting, impairing…”
City of Waterbury v. Town of Washington, 800 A.2d 1102 (Conn. 2002). · cites it 17× “General Statutes § 22a-19 provides: “(a) In any administrative, licensing or other proceeding, and in any judicial review thereof made available by law, the Attorney General, any political subdivision of the state, any instrumentality or agency of the state or of a political…”
River Bend Assocs., Inc. v. Conservation & Inland Wetlands Comm'n, 848 A.2d 395 (Conn. 2004). · cites it 25× “(coalition); see footnote 1 of this opinion; intervened in the proceedings to oppose the application, pursuant to General Statutes § 22a-19 (a). 11 The coalition’s intervention was acknowledged by the defendant and the coalition was made a party to the administrative proceedings.”
Zoning Comm'n v. Fairfield Resources Mgmt., Inc., 674 A.2d 1335 (Conn. App. Ct. 1996). · cites it 40× “” 6 Upon learning of this modification of the injunction, which the association maintained permitted the resumption of unlicensed water diversion and stone and rock processing in the absence of a zoning permit, Richard Gereg, who was president and spokesman of the association,…”
Pond View, LLC v. Plan. & Zoning Comm'n, 953 A.2d 1 (Conn. 2008). · cites it 36× “The defendants Elizabeth Murphy and Sally Lundy, environmental intervenors (intervenors) 1 pursuant to General Statutes § 22a-19 (a), 2 appeal, following the Appellate Court’s grant of certification, from the judgment of the trial court sustaining the appeal of the plaintiff,…”
Show all 142 citing cases →
— Conn. Gen. Stat. § 22a-19(a) — 4 cases
Finley v. Inland Wetlands Com'n of Town of Orange, 959 A.2d 569 (Conn. 2008). “[4] General Statutes § 22a-19 provides: "(a) In any administrative, licensing or other proceeding, and in any judicial review thereof made available by law, the Attorney General, any political subdivision of the state, any instrumentality or agency of the state or of a political…”
Avalonbay Communities, Inc. v. Zoning Comm'n, 867 A.2d 37 (Conn. App. Ct. 2005). “At that time, the town of Stratford through its legislative body, the town council (town), filed in each case a verified pleading pursuant to General Statutes § 22a-19 (a), the citizen intervention provision of the EPA, claiming, in essence, that the plaintiff's proposed…”
Avalonbay Communities, Inc. v. Zoning Comm'n, 908 A.2d 1033 (Conn. 2006). “The issue presented in these certified appeals is whether a municipality, acting through its town council, can intervene in appeals to the Superior Court from decisions of the municipality's inland wetlands and watercourses agency and its zoning commission pursuant to General…”
Lawrence v. Dept. of Energy & Env't Prot., 176 A.3d 608 (Conn. App. Ct. 2017).
— Conn. Gen. Stat. § 22a-19(a)(1) — 1 case
Lawrence v. Dept. of Energy & Env't Prot., 176 A.3d 608 (Conn. App. Ct. 2017).
— Conn. Gen. Stat. § 22a-19(a)(2) — 1 case
Lawrence v. Dept. of Energy & Env't Prot., 176 A.3d 608 (Conn. App. Ct. 2017).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.