NACWA urges EPA to review, update 2003 Water Quality Trading Policy

The National Association of Clean Water Agencies (NACWA) has sent a letter to the Environmental Protection Agency (EPA) requesting that the agency review and update its 2003 Water Quality Trading Policy. In the letter, NACWA recommends a series of changes to the policy that would encourage greater market formation and broader market participation that includes nonpoint sources.

Washington, DC, July 20, 2012 – The National Association of Clean Water Agencies (NACWA) has sent a letter to the Environmental Protection Agency (EPA) requesting that the agency review and update its 2003 Water Quality Trading Policy. In the letter, NACWA recommends a series of changes to the policy that would encourage greater market formation and broader market participation that includes nonpoint sources.

Most notably, NACWA cites concerns it has that EPA’s policy appears to focus primarily on linking water quality trading to implementation of total maximum daily loads. As the letter states, a waterbody impairment should not have to be declared for trading to be used.

“While NACWA is encouraged that EPA recognizes water quality trading as an approach to achieve water quality goals more efficiently, we are concerned that, as currently written, EPA’s Water Quality Trading Policy could limit trading and the broader establishment of regional water quality trading programs,” NACWA wrote. “NACWA believes that EPA should embrace water quality trading as a more holistic approach to reducing the load and impact of pollutants irrespective of a waterbody’s status as impaired under §303(d) of the CWA.”

This effort comes out of NACWA’s newly formed Water Quality Trading Working Group, which was created to promote the use of water quality trading and think strategically about how to overcome some of trading’s main barriers.

The complete letter may be viewed at http://www.nacwa.org/images/stories/public/2012-07-19ltr.pdf.

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