The new development down the street on the banks of my local river is discharging untreated stormwater directly into the river. This river also happens to be impaired for sediment and bacteria. This is being done in full compliance with my state’s nutrient trading regulations, even though trades are not supposed to imperil local water quality. How did this come about?
To be clear, I was an early (but cautious) advocate of nutrient trading, especially as an important tool to meet pollutant load goals of the Chesapeake Bay TMDL. With colleagues at the Center for Watershed Protection, I contributed to a couple of white papers on the topic, led the team that developed West Virginia’s off-site stormwater compliance guidance document (link at end of article), and served on the technical committee assisting Virginia with the regulations for off-site compliance.
The “cautious” part in the lead sentence is that trading is a valuable tool when guided by a regulatory framework that governs the rules of the road. Such a framework can help determine which sites are eligible for trades and how off-site pollutant reductions are verified. Among these crucial concerns is how local water quality can be protected when trades are made across a watershed.