Connecticut Energy Marketers Association v. Department of Energy and Environmental Protection

Summary

The court held that the department's energy strategy and the authority's approval of a natural-gas expansion plan were not actions requiring an environmental impact evaluation because the construction and funding would be undertaken by private gas companies. It interpreted the governing statute to require that covered activities be undertaken or funded by state actors and affirmed dismissal of the complaint. EVELEIGH, J., dissenting, would have held that the agencies' discretionary proposal, approval, and implementation of the plan constituted covered actions and would have remanded for further proceedings.