Water Quality Trading in the Lower Delaware River Basin: A ...

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example, the University of Delaware has done extensive work and has been involved in many partnerships on both the Delaware River and the Christina Basin (www.wr.udel.edu/cb). • Foundations—these organizations have traditionally provided vision and leadership with environmental problems in the LDR Basin. They can continue to be catalysts for change by promoting innovative management solutions. For example, foundations could provide seed money to initiate the first trades in the LDR Basin/Christina River Basin. In summary, there are many organizations who have expressed an interest in water quality trading programs and many others that may also be interested in playing a role. The DRBC and the states have special standing in this regard. DRBC has a unique role in the LDR Basin as a convener and a consensus builder, and is recognized as a leader on interstate issues, such as the development of the initial low-flow TMDL for the Christina River (http://www.epa.gov/reg3wapd/christina/pdf/execsumm.pdf). Therefore it is recommended that DRBC, working with the states and EPA, take a lead in promoting WQT in the region. Summary of Chapter 4 The following conclusions can be reached regarding the administrative and management aspects of establishing water quality trading programs in the LDR Basin and the Christina River Basin: • The LDR region is fortunate to have progressive leadership among government officials and NGOs. Many of these leaders have expressed interest in innovative environmental management and specifically in the concepts of trading. • Governmental organizations in the environmental field have a history of cooperation and team-building in the basins. The Delaware River Basin Commission plays a unique role as a consensus builder in the Delaware River Basin. NGOs and municipal and industrial leaders have, in the past, been willing and capable of adopting cost-effective solutions to environmental problems. • There do not appear to be any major legal or administrative impediments to establishing a water quality trading program in the LDR • Water quality trading can be one innovative way to reach water quality goals in a cost-effective way. It is not a panacea and may be appropriate in only a limited number of situations. It should be viewed as one “tool” in the toolbox of the water quality manager. The tool may not be used as often as others but, under the appropriate conditions (eg, environmental, economic, political), it may result in both significant cost savings and water quality improvements. • The establishment of a trading program should be expected to take several years, especially in a large basin like the LDR Basin. Those interested in promoting a trading program should plan to be involved in a long term process. There could be significant “transaction costs” in establishing a program. These costs include organizing meetings with key stakeholders to discuss the concepts, educating the interested parties, and conducting initial technical evaluations to identify the best 76
opportunities for trading. Existing staff and funding should be used in the early stages of establishing a trading program. As the feasibility and size of the program is understood, specific needs can be identified. The following specific recommendations are made in order to take the next steps in determining the feasibility of establishing a water quality trading program: • Building on the existing interests of the organizations involved, EPA (Regions 2 and 3), DRBC, the states of Delaware, Pennsylvania, and New Jersey should sign an agreement to promote water quality training in the LDR Basin and issue a press release telling of their intent to promote these ideas. A nationallyrecognized NGO, with trading experience, should also be invited to sign this agreement. The agreement should announce the intent of these organizations to work together to identify priority opportunities for trading throughout the LDR Basin within 18 months. • Use existing governmental organizations, processes, staffing, and funding and the capabilities of others (eg. local watershed associations, academia, foundations, and industry) to take the next steps. DRBC and the states should chair a meeting of key stakeholders to delineate responsibilities of major organizations using the proposal set forth in this report as a starting point for those discussions • Using the technical findings of this report, the state officials, DRBC, EPA, and the local stakeholders should decide the degree to which trading is appropriate at this time in the Christina River Basin . This will give some of the key players experience in the trading deliberations and will inform their decisions on future efforts. These deliberations should be documented in a way that can be used to train others on trading issues. The development of workbooks and video documentation should be considered. • The states, DRBC, and EPA should continue to find opportunities to educate potential stakeholders in the concepts of trading. The “train the trainer” concept should be used with national and local experts training the key stakeholders. Of particular importance is the training of state/federal planners, watershed managers, and permit writers and key NGOs from the LDR Basin and the Christina River Basin. Interested university and college professors should also be included and utilized to provide training to larger audiences and their students. This training should also be documented by video for broader dissemination. • To the extent possible, the first trades should be as simple. They should not be implemented until needed TMDLs are approved. They should be PS to PS or perhaps one PS to one NPS. They should also be limited to one pollutant (nutrients are suggested as the first priority). Trading decisions should be memorialized by including the conditions in the NPDES permit, if possible, and the NPDES program should be used to monitor compliance. 77
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Water Quality Trading in the Lower
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wide pollutant reductions to meet T
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Chapter 4. Administration and Manag
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Historical Development of Water Qua
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mechanisms to achieve the cap. The
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Figure 1-1: Schematic of the develo
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other discharges. The resulting tra
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Existing Water Quality Trading Syst
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Strengths and Weaknesses of Existin
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participants ensure that the market
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Nash, Jonathon Remy and Richard L.
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Chapter 2 Technical Aspects of Wate
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Page 85 and 86: References PRedICT User Guide, 2003
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