Yesterday, the Chesapeake Bay Commission released a study showing that implementation of a nutrient trading system would dramatically reduce the cost to achieve nutrient reductions in Chesapeake Bay.
Pardon me if I seem to be posting a lot of dog bites man stories recently.
Although it should not come as a surprise that a trading system would permit nutrient reductions to be attained most cost-effectively, the scope of the benefit is worth noting. If trading were allowed basin-wide, and among both point and agricultural non-point sources, costs are projected to decrease by about 50% of the non-trading compliance costs.
Since I have faced this issue in Massachusetts, I found it even more noteworthy that, if trading were expanded to include regulated urban stormwater sources, compliance costs are expected to be reduced by about 80% over the non-trading scenario. The report’s explanation is both simple and cogent:
Implementing urban stormwater BMPs tends to be a much less cost-effective way of reducing nutrient loads than agricultural BMPs.
To which I say, you could have knocked me over with a feather. I just hope that EPA does not limit its review of this report to the Chesapeake Bay itself, but considers its implications more broadly in the context of stormwater regulation in other areas.
Perhaps this message also needs to reach those within MA DEP who are developing water withdrawal regulations based in large part on the state-led Sustainable Water Management Initiative (SWMI). The presently proposed SWMI Framework penalizes applicants based on stream flow status and a single water quality “proxy”–“Percent Impervious Cover”, i.e., extent of “urbanization”. Notwithstanding the various limitations of this oversimplified approach by SWMI, the Framework would benefit from explicit acknowledgement of demonstrably effective BMP trading (case-by-case) as an element of the endorsed mitigation toolbox.
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