As previously reported on Conduit Street, the Water Quality Trading Advisory Committee has been working on a draft practices manual that will cover how nutrient credit trading will work in Maryland. A subset of Advisory Committee members met on October 5 to specifically review Section II of the draft manual, which covers point source trading (primarily trades from wastewater treatment plants (WTTPs) for stormwater management requirements). MACo Legal and Policy Counsel Les Knapp attended the meeting.
Several stakeholders raised concerns about making sure that the credit system established by the Advisory Committee synchronized with assumptions contained in a county’s 10-year water and sewer plan. While most of the envisioned trades would be short term/non-permanent, WTTP advocates stressed the importance of maintaining flexibility for permanent trades as future municipal separate storm sewer system (MS4) permit requirements remain unknown.
Maryland Department of the Environment (MDE) representatives also discussed how point source credits would be measured and tracked, noting that WWTPs will be subject to both a waste load allocation (based on nutrient flow) and a floating cap (based on nutrient concentration). The derived credits could either be capacity or performance-based. Tracking tools will include two interconnected Environmental Protection Agency programs: (1) Enforcement Compliance History Online (ECHO); and (2) the Integrated Compliance Information System (ICIS).
Other concerns raised during the meeting dealt with the appropriate percentage of credits that should be “retired” during each trade (a safety factor), expressing MS4 permit targets by nutrient loads as opposed to impervious surface reduction and retrofit, allowing point source credits into the same market with nonpoint source (agricultural) credits, and how to allow trading under an MS4 permit.
Final comments on the Section II draft are due October 13. The Advisory Committee plans on finalizing the entire trading practices manual by the end of the year. For further information or questions, contact Les Knapp at 410.269.0043 or email@example.com.