&EPA
United States
Environmental Protection
Agency
Office Of Water
(WH-553)
EPA841-S-92-001
August 1992
Administrator's
Point/Nonppint Source
Trading Initiative Meeting
A Summary
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A SUMMARY
Administrator's
Point/Nonpoint Source
Trading Initiative
Meeting
April 27-28, 1992
Durham, North Carolina
SPONSORED BY
U.S. Environmental Protection Agency
HOSTED BY
North Carolina Department of Environment, Health
and Natural Resources
Recycled/Recyclable
Printed on paper that contains
at least 50% recycled fiber
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CONTENTS
INTRODUCTION 5
SUMMARY OF MEETING RESULTS 7
Key Findings 7
EPA Response 8
Suggested Next Steps 8
BREAKOUT GROUP CONCLUSIONS
Group I 9
Group II . 10
Group III II
Group JV 12
Group V 13
Group VI 13
GENERAL SESSION PRESENTATIONS 15
APPEWDZXA. AGENDA 17
APPENDIX B. LIST OF ATTENDEES 21
APPENDIX c. BREAKOUT GROUP DISCUSSIONS
Group I 27
Group II 39
Group III 49
Group IV 55
Group V 61
Group VI 67
3
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INTRODUCTION
JTie Administrator's Conference on Trading was designed to broaden general
-L understanding of point/nonpoint source pollution trading. Water quality man-
agers came together to exchange views and impressions on the utility and applica-
bility of pollution trading as a way to meet Clean Water Act goals and promote
effective use of water quality management resources.
More than 120 representatives of Federal and State regulatory agencies, ag-
ricultural producers and commodity groups, municipal governments, and industry
expressed views about the usefulness of trading. A notable element of the confer-
ence was the range and diversity of views represented by the participants and
their shared commitment to cost-effective water quality management.
Conference participants were asked to identify factors that encourage or dis-
courage trading. They were also asked to suggest ways in which trading could play
a larger part in the water program overall and become an integral component of
water quality management. Many of the regulatory, administrative, and legal as-
pects of trading were discussed, as was the need for additional information and ed-
ucation. Finally, participants were asked to suggest specific watersheds where
trading programs could be implemented on a pilot basis.
The Conference opened with a plenary session followed by six breakout
groups. The conclusions that follow are distilled from the final breakout group re-
ports. All of the actual breakout group products, including the final reports to the
plenary session, appear later in this document.
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SUMMARY OF MEETING RESULTS
Key Findings
Trading is an effective tool: Trading is a potentially valuable tool for
water quality management, but its usefulness has not been fully demonstrated.
The merits and drawbacks of various trading programs must be demonstrated and
evaluated through a number of pilot projects.
" Tradin9 is no* o. panacea: One of many "tools in the water quality tool-
box," trading cannot be uniformly applied nationwide. The applicability and utility
of any trading program depend on the water quality problems of a given area and
the surrounding institutional infrastructure. Trading is, therefore, site-specific
and local in nature.
Technical issues are real: Technical water quality issues help define the
usefulness and applicability of trading. Cause and effect water quality data, im-
proved predictive modeling, and definitive information on the effectiveness of con-
trols (particularly nonpoint source BMPs) are all crucial elements that will
ultimately determine the role of trading in the water quality program.
Point/nonpoint source dichotomies are significant: The Clean Water
Act establishes different program approaches for dealing with point and nonpoint
source pollution. Trading programs must recognize these distinctions and be de-
signed to complement the different procedures.
Education is key to any trading program: Facts about trading must be
communicated to the public to help them recognize that trading programs are
cost-effective ways of meeting existing water quality goals. Education can also be
used to promote understanding among various levels of government and demon-
strate the value of trading to potential participants.
Monitoring is essential to a trading program: Trades must be moni-
tored to ascertain the effectiveness of individual trades, the amount of load reduc-
tions in the targeted pollutant as well as others, and the operation and
maintenance of the program itself.
EPA should issue guidance: Conference participants encouraged EPA to
issue guidance clarifying the use of trading. Recommendations for this guidance
included defining:
applicability under the current Clean Water Act,
pollutant types and sources available for trade,
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issues of equity and accountability, and
the role of trading in relation to existing point and nonpoint source con-
trol authorities. ;
EPA Response
Martha Prothro, Deputy Assistant Administrator, Office of Water, U.S. EPA, pre-
sented five key points determined from the presentations:
The more progress made in overall water quality agenda, the more prog-
ress we can make in trading as well.
EPA is both an educator and facilitator in the trading process. We are
working to develop a framework that enables local and State entities to
move forward with a trading scheme. We must encourage and document
successes.
Trading is a tool and not a panacea.
There is a vital need for coalitions. The conference is a great example of
what can be accomplished when the public and private sectors join to-
gether.
There were a number of ideas such as accountability and equity that
merit further examination. EPA is willing to be a risk takeir in these
areas.
Suggested Next Steps
EPA should use the information gathered at the meeting to pursue the concept of
point/nonpoint source pollutant trading as a viable water quality management
tool. EPA should continue to analyze the benefits and implications of trading and
promote trading where and when it is appropriate. EPA should continue to collect
and share information from pilot projects and look at barriers to trading to find so-
lutions to those barriers. EPA should articulate the Agency's position on trading in
the near future.
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BREAKOUT GROUP CONCLUSIONS
Group I
The main factors addressed were
regulatory,
B legal,
information needs,
education, and
economic considerations.
Regulatory
It is important to determine what EPA's real motive is for getting involved in this
issue and to what extent its authority should be exercised. There is some concern
that the Agency might use this opportunity to expand its authority without a stat-
utory mandate. Certainly, there is widespread agreement that EPA should be in-
volved in this issue, but we must openly discuss the scope of that involvement.
Legal
After determining the nature of EPA's involvement and the role of other entities in
the discussion process, existing laws and regulations must be examined carefuUy
to determine if statutory action needs to be taken. Hopefully, such an overview
will minimize possible legal challenges.
Information Needs
To adequately assess the problems with trading, a large amount of data must be
collected. This process should involve everyone with an interest in water quality
management and trading.
Education
It is especially important that time be spent educating all parties involved. Educa-
tion is the primary ingredient in implementing any program.
Economic Considerations
The main issue here is equity between point source and nonpoint source issues in
terms of cost and control. Cost-saving measures should be a consideration, but so
should the idea of spending additional Federal dollars to help more segments of
the community move forward with their programs.
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Conclusions Group I
To become a useful water quality management tool, all aspects of a trad-
ing program must be in place. Pilots, tests, and demonstrations must be
used to assess and illustrate the applicability and usefulness of trading.
As a first step, EPA should issue guidance, not a regulation, to get the
process moving.
Group II
Major issues of concern:
credibility of BMP (best management practice) effectiveness;
inability to measure effects on water quality and establish the market
value of the trades; and
the need to separate nonpoint source control issues from trading issues.
Credibility of BMP effectiveness can be broken down into several layers:
First, readily accessible information on the fate and transport of pollu-
tants from various lancl use practices is missing and, therefore, is not
making its way to the decisionmakers.
Second, there is a great deal of uncertainty that the dollars being put
into BMPs to meet pollutant reductions are doing the intended job. Re-
sults seem to be variable, and it is very difficult to track and measure
performance.
Inability to measure effects on water quality and establish the market value of
trades.
A value system must evolve among site-specific users and benefactors as
they set quality goals and allocate those goals among point and nonpoint
source generators.
EPA is in the best position to set up broad parameters for a trading pro-
gram.
The need to separate nonpoint source control issues from trading issues.
We must be careful not to look at trading program as a panacea for solv-
ing water quality problems. Any trading program is dependent on water
quality goals that have already been articulated by Congress or through
regulations. The real question is: do we want to- create a new program
under current legislation or see what comes out of the new Clean Water
Act reauthorization?
Conclusions Group II
To specifically address the problems associated with BMP credibility, four recom-
mendations were made:
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Information from existing research needs to be compiled into a useful ref-
erence document that includes actual design elements for trading
schemes.
Additional studies must be performed to fill in gaps identified in the ref-
erence document.
A menu of BMP choices must be made available so those who must im-
plement them are given more than one option.
We need to create a water quality value system at the local level to gen-
erate a self-designed market that allows a bottom-up establishment of
what values should be used on a site-specific basis.
Group III
The two main barriers are attitudes and uncertainties con-
cerning nonpoint sources. The enabler is cost-effectiveness
of the trading tool.
Attitudes and Uncertainties
Various attitudes and uncertainties can adversely affect any trading program. Ex-
amples include
agencies that are limited in their thinking,
point sources who may think they have done enough,
agricultural interests who think they are not really the problem, and
the general public that thinks trading will not work.
Cost Effectiveness of this Tool
After examining the costs and benefits of this tool, it was agreed that an opportu-
nity to save money is an enabler to the program. However, failure to adequately
examine costs and benefits is a real barrier.
Conclusions Group III
To remove barriers, States need to improve documentation on BMPs be-
cause it is critical that they buy into their own BMP programs.
Monitoring of BMP installation is also needed for point sources to em-
phasize effectiveness and progress of the programs. Resources should
not be wasted on expensive routine monitoring; rather, using planmng-
level estimates of BMP effectiveness as a measuring rod, the watershed
should be assessed at the onset of the nonpoint source management plan
and again much later (10-15 years) after significant improvement should
be noted.
A nonpoint source control program is and will be a long-term goal.
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Group IV
Main areas addressed:
administrative;
technical/scientific; and
resource issues.
Administrative
EPA should develop a framework to facilitate trading and minimize potential bar-
riers, such as
compromise of enforcement authority to achieve reductions, and
interstate differences in water quality management programs, as well as
watersheds, that cross political boundaries.
There are two differing points of view:
trading must be achieved through local initiatives with minimum inter-
ference; and
EPA has an obligation to ensure that water quality standards are
achieved expeditiously.
A balance must be struck between these two views.
Technical / Scientific
These concerns were divided into three areas:
The need for monitoring systems and data on land use, BMPs, and other
sources on the watershed.
A need to establish cause and effect relationships by developing model
linkages based on specific watersheds and calibrated to local conditions
and data.
BMPs need to be adapted to local conditions, both evaluated and applied.
Resource Issues
EPA, as well as local and State entities, must be encouraged to maintain a level of
expertise on trading.
A framework needs to be developed to accomplish this objective and pro-
mote and guide trading. The initial framework should include a Federal
role and must contain an educational element.
Conclusions Group IV
Trading is a valid, viable concept, although it may not be generally appli-
cable in all water quality management situations.
H EPA seems to be defining a new role in nonpoint source pollution man-
agement; the discussion about point/nonpoint source trading begun at
this conference should continue.
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Group V
Six major elements were discussed:
Trading is only a tool to be used to address point and nonpoint source
pollution. It has merit and drawbacks.
Will trading work? Before implementing a national policy, pilot projects
should be undertaken and evaluated.
A trading program would be a long-term commitment and must have ad-
equate funding upfront and throughout the program to assure that data
necessary to demonstrate the effectiveness of trading are collected.
Communication between interested parties is critical.
Federal agencies must coordinate with the State agencies to share
databases and information.
Accountability is key to ensuring that BMPs are implemented and truly
successful.
Conclusions Group V
The implementation of BMPs should be left up to the local conservation
districts and the publicly owned treatment works (POTW).
Loading reductions should be the responsibility of the POTW. Action
taken should focus on placing the burden on the point source.
Requirements should be put in the permit that outline steps to be taken
if loading reductions or goals are not reached.
Group VI
Four main areas were addressed:
legal;
administrative policy;
technical; and
education/public relations
Legal
Establishment of a regulatory baseline is essential for starting a successful trad-
ing program. The question is: when a new control technology is developed, what is
the responsibility of the point source system to apply that new technology when
they currently have a trading program underway? Rules are needed to establish
trading regions.
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Administrative Policy
Trading opportunities should continue to be explored as a policy option, and EPA
should encourage States to develop programs by offering technical assistance and
cost-sharing options. More funds should be directed to nonpoint sources.
Technical
Specific information is needed on the effectiveness of BMPs and when and where
to employ them. A technically defensible ratio should be developed to make sure
that point sources are getting their money's worth.
Education/Public Relations
The emphasis should be on local involvementgetting the communities and
States in the program. A policy statement from State water quality agencies and
EPA supporting the concept of trading is key to ensuring that point and nonpoint
sources support this new structure.
Conclusions Group VI
More funding needs to be available for modeling and research efforts re-
lated to BMP effectiveness. Without good information on their
effectiveness, BMPs will be a weak link in any trading scheme.
EPA should publish guidance to help States and smaller units deal with
the different aspects of a trading program. Such guidance is critical to
continuing the program.
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GENERAL SESSION PRESENTATIONS
The Administrator's Point/Nonpoint Source Trading Initiative was intended to
begin the process of forging a new national agenda on trading and the use of
economic forces and incentives to abate water pollution. To this end, speakers in
the opening General Session addressed the trading issue from practical, and
again, multiple points of view. They represented the farms and the cities, the envi-
ronmental advocates, and the Federal, State, and local governments.
Geoffrey H. Grubbs, Director of the Assessment and Watershed Pro-
tection Division, Office of Water, U.S. EPA, emphasized that this conference
represented the deep, personal investment of EPA Administrator William K. Reilly
in the belief that economic forces and incentives bear great potential for long-term
pollution abatement and cleanup. The linchpin of the Clean Air Act, trading offers
a whole set of new approaches and devices that offer opportunities for the Clean
Water Act.
William W. Cobey, Jr., Secretary, North Carolina Department of Envi-
ronment, Health, and Natural Resources, citing the relatively new experience
of his own State with trading, described three major benefits of the Tar-Pamlico
project: (1) it brought together many diverse groups; (2) it has produced significant
economic benefits, including funds that may be used to cost-share agricultural
BMPs; and (3) the project has highlighted the significance of nonpoint source pol-
lution and its control.
Robert H. Wayland, III, Director, Office of Wetlands, Oceans and Wa-
tersheds, U.S. EPA, discussed the three pillars central to EPA management: stra-
tegic planning, quality management, and pollution prevention. He drew upon
EPA's water pollution statistics to illustrate that trading has the potential to be-
come a pollution prevention mechanism. And he pointed out that, as EPA enters
its third decade, the myriad of environmental needs must be met even more effec-
tively and efficiently.
Steve Tedder, Water Quality Section Chief, Division of Environmental
Management, North Carolina Department of Environment, Health, and
Natural Resources, described the Tar-Pamlico Experiment in trading from the
water quality/BMP standpoint. An implementation strategy to address nutrient-
stressed waters, Tar-Pamlico represents an evolution from the regulatory stance
to an innovative market-based approach.
Malcolm Green, General Manager, Greenville Utilities Commission,
North Carolina, gave the commission's perspective on how trading worked in the
Tar-Pamlico project. Pointing out the State's basin-oriented approach to water
quality management, he expressed the concept of trading as an innovative, cost-ef-
fective approach that can be applied to both air and water.
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Steve Levitas, Director North Carolina Environmental Defense Fund,
explained how coalitions can be built to contribute to such projects as the Tar-
Pamlico scenario. In describing the process of diverse groups coming together in
what has become an efficient, economic water quality management process, he
said the divergent points of view contributed to the evolving strategy for solving
the basin's pollution problems.
Mark Luttner, Special Assistant to the Deputy Assistant Administra-
tor, Office of Water, U.S. EPA, discussed how trading has worked in various na-
tional models, citing statistics from projects in various basins. He emphasized
several factors that must be present to make trading work: (1) clear and signifi-
cant savings for point sources; (2) consensus among all the parties affected; (3)
self-sufficiency for the project; (4) flexibility to adapt to changing conditions; and
(5) implementation mechanisms in place.
To encourage open exchange within the discussion groups, widely varying
viewpoints were presented by panelists exploring the barriers and opportunities to
trading. They included:
John Burt, Associate Deputy Chief, USDA Soil Conservation Service,
cautioned that agricultural interests should be involved early in the trading pro-
cess. The agricultural community will be interested in the concept, particularly
when the incentives are appropriate, the technology is practical and cost-effective,
and the uncertainties are settled by involving the agricultural interests.
Diane Cameron, Natural Resources Defense Council, reiterated the
need to involve all stakeholders early especially the farming community be-
fore initiating the trading process. The trading concept can work and be cost-effec-
tive if managed properly by informed participants on a consensus basis.
Judy Olson, Secretary, National Association of Wheat Growers, spoke
of reasonable approaches to the shared goal of protecting water quality. She con-
curred with the concept of involving all concerned in the initial stages and empha-
sized the value of trading as a market-based alternative to regulation.
Ken Kirk, Executive Director, Association of Metropolitan Sewerage
Agencies, brought the point source viewpoint to this panel. Representing a highly
regulated segment of society, he spoke to the point of taking great care to make
trading work to measure its progress and establish its value step by step.
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APPENDIX A
NATIONAL MEETING:
Administrator's Point/Nonpoint
Source Trading Initiative
April 27 - 28,1992
Sheraton Inn University Center
Durham, North Carolina
Sponsored by
U.S. Environmental Protection Agency
Hosted by
North Carolina Department of Environment, Health
and Natural Resources
FINAL AGENDA
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Conference Goal and Objectives
GOAL
To broaden a general understanding of point I nonpoint source pollution trading and
promote its acceptance as an integral component of water quality protection.
OBJECTIVES
1. Identify programmatic, technical and legislative factors that facilitate or discourage
trading;
2. Develop cooperative action plans to address technical, legislative and programmatic barriers;
3. Develop recommendations for supportive activities by EPA, including guidance, policies,
regulations and legislative proposals; and
4. Identify, if possible, specific waterbodies that could serve as pilot opportunities for trading.
Sunday evening, April 26
3-8 p.m. Registration Foyer ofThe Greenbrier Ballroom
6 8 p.m. Informal welcoming reception The Greenbrier Ballroom C and D
Monday, April 27
7:30 - 8:30 a.m. Continental Break fast 2nd Floor Balcony
8-8:30 a.m. Registration Foyer of The Greenbrier Ballroom
GENERAL SESSION
The Greenbrier Ballroom AB-C
8:30 - 8:45 a.m. Call to Order Geoffrey H. Grubbs, Director, Assessment and Watershed Protection
Division, Office of Water, U.S. EPA
8:45 - 9:00 a.m. Welcome William W. Cobey, Jr., Secretary, North Carolina Department of
Environment, Health and Natural Resources
9:00 - 9:30 a.m. The Entrepreneurial Spirit Robert H. Wayland III, Director, Office of Wetlands,
Oceans and Watersheds, U.S. EPA
9:30 -10:30 a.m. The Tar-Pamlico Experiment
« Approach and design. Steve Tedder, Water Quality Section Chief, Division of
Environmental Management, North Carolina Department of Environment, Health and
Natural Resources
Practical consequences. Malcolm Green, General Manager, Greenville Utilities
Commission, North Carolina
10:30 -10:45 a.m. Break
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10:45 - 11:45 a.m. A National Approach
Effective coalition building. Steve Levitas, Director, North Carolina Environmental
Defense Fund
Alternative national models. Mark Luttner, Special Assistant to the Deputy
Administrator, Office of Water, U.S. EPA
11:45 - 1:00 p.m. LU2VCHEOJV The Brightleaf Ballroom E-F
Welcome. E. Stallings Howell, Jr., Chief, Wetlands, Oceans and Watersheds,
U.S. EPA Region IV, Atlanta
1:00 - 2:45 p.m. Barriers and Opportunities
Incentives for agriculture. Gary Margheim, Deputy Chief for Programs, Soil
Conservation Service, USDA
Can the environment benefit? Diane Cameron, Senior Research Associate, Natural
Resources Defense Council
Can farmers benefit? Judy Olson, Secretary, National Association of Wheat Growers
Can POTWs benefit? Ken Kirk, Executive Director, Association of Metropolitan
Sewerage Agencies
2:45 - 3:00 p.m. Break
3:00 - 5:00 p.m. BREAKOUT SESSIONS
Breakout Session #1 Conference Room 2002
Breakout Session #2 Conference Room 2003
Breakout Session #3 Conference Room 2004
» Breakout Session #4 Conference Room 2005
Breakout Session #5 The Brightleaf Ballroom G
Breakout Session #6 The Brightleaf Ballroom H
5:00 - 5:30 p.m. Interim Status Reports The Greenbrier Ballroom A-B-C
5:30 p.m. Adjourn
6:00 p.m. Social hour Poolside - Atrium
Tuesday, April 28
7:00 8:00 a.m. Continental Breakfast 2nd Floor Balcony
8:00 - 10 a.m. Breakout groups reconvene (same rooms as listed above for Monday)
10:00 - 10:15 a.m. Break
GENERAL SESSION The Greenbrier Ballroom A-B-C
10:15 a.m. - Noon Breakout group presentations and discussion
CHAIRPERSON: Martha G. Prothro, Deputy Assistant Administrator, Office of Water, U.S. EPA
Noon 1:00 p.m. Synthesis, commitments and closing remarks
CHAIRPERSON: Martha G. Prothro, Deputy Assistant Administrator, Office of Water, U.S. EPA
1:00 p.m. Adjourn
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ACKNOWLEDGMENTS
This group of people deserve special recognition for their instrumental
role in developing this conference:
Robert H. Wayland III, Director, Office of Wetlands, Oceans and Watersheds, U.S. EPA
Geoffrey H. Grubbs, Director, Assessment and Watershed Protection Division, U.S. EPA
Donald J. Brady, Chief, Water Management Section, U.S. EPA
Mark Luttner, Special Assistant to the Deputy Assistant Administrator, U.S. EPA
Steve Bugbee, Environmental Scientist, Permits Division, U.S. EPA
Peggy Michell, Program Analyst, Assessment and Watershed Protection Division, U.S EPA
Amy Sosin, Environmental Scientist, Assessment and Watershed Protection Division, U.S. EPA
Karen Guglielmone, Environmental Engineer, Tetra Tech, Inc.
Judy Taggart, President, JT&A, inc.
1
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APPENDIX B
NATIONAL MEETING:
Administrator's Point/Nonpoint Source
Trading Initiative
April 27-28, 1992
Sheraton Inn University Center Durham, North Carolina
Sponsored by the
U.S. Environmental Protection Agency
Hosted by the
North Carolina Department of Environment, Health
and Natural Resources
LIST OF ATTENDEES
FINAL LIST
Deborah Allen
Nonpoint Source Unit Chief
Michigan Department of Natural
Resources
P.O. Box 30028
Lansing, Ml 48909
Phone:(517)335-4102
Fax: (517)373-9958
Robert Alpern
Senior Advisor to the Commissioner
New York City Department of
Environmental Protection
59-17 Junction Boulevard, 19th Floor
Elmhurst, NY 11372
Phone:(718)595-6569
Fax: (718)595-6563
Arthur Ashendorff
Director of Water Quality
Bureau of Water Supply
New York City Department of
Environmental Protection
59-17 Junction Boulevard, 19th Floor
Elmhurst, NY 11372
Phone:(718)595-5340
Fax: (718) 595-6563
Tom Augspurger
Fish and Wildlife Biologist
U.S. Fish and Wildlife Service
551 F. Pylon Drive
Raleigh, NC 27602
Phone: (919) 856-4520
Fax: (919)856-4556
Elise Bacon
Financial Analyst
Apogee Research, Inc.
4350 East-West Highway
Suite 600
Bethesda, MD 20814
Phone: (301) 652-8444
Fax: (301) 654-9355
Sharon Bailey
Ontario Ministry of the Environment
135 St. Clair Avenue, West
11th Floor
Toronto, Ontario Canada M4V1P5
Phone:(416)323-4578
Fax: (416)323-4322
John Baker
Agricultural Advisor to Administrator
U.S. EPA
510 Phoenix
Temple, TX 76504
Phone:(817)771-1438
Fax: (817)983-5171
Rick Balla
Chief, Water Quality Management
Section
U.S. EPA Region II
26 Federal Plaza
Room 813 (2WM-SWQB)
New York, NY 10278
Phone:(212)264-5671
Fax: (212) 264-2194
D. Randall Benn
Attorney Advisor
Office of Water, U.S. EPA
401 M Street, S.W.
Mail Code WH-556
Room 1039-A East Tower
Washington, DC 20460
Phone: (202) 260-5700
Fax: (202) 260-5711
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Victoria P. Binetti
Program Support Branch
Water Management Division
U.S. EPA Region III
841 Chestnut Building/Mail Code 3WM1O
Philadelphia, PA 19107
Phone: (215) 597-6511
Fax: (215) 597-3359
Don Blackburn
U.S. Forest Service
210 Franklin Road, S.W.
Caller Service 2900
Roanoke, VA 24001
Phone: (703) 982-6085
Fax: (703) 982-4656
Ron Boatner
Northwest Associates
1312 Falrlane Road
Yreka, CA 96097
Phone:(916)842-2962
Scott Boettcher
Efficiency Commission Coordination
Washington State Department of Ecology
P.O. Box 47600
Olympla, WA 98504-7600
Phone: (206) 493-2686
Donald J. Brady
Chief, Water Management Section
U.S. EPA
401 M Street, S.W.
Mail Code WH-553
Washington, DC 20460
Phone: (202) 260-5368
Fax: (202) 260-7024
Steve Bugbee
Environmental Scientist
Permits Division
U.S. EPA
401 M Street, S.W.
Mall Code EN-336
Washington, DC 20460
Phone:(202)260-5816
Fax: (202)260-1460
John Burt
Associate Deputy Chief for Programs
SoH Conservation Service
U.S. Department of Agriculture
P.O. Box2890
Washington, DC 20013
Phone: (202) 690-2500
Fax: (202) 720-7690
Diane Cameron
Research Associate
Natural Resources Defense Council
1350 Now York Avenue, N.W.
Suite 300
Washington, DC 20005
Phone: (202) 783-7800
Fax: (202) 783-5917
Ralph Cantral
Senior Policy Analyst
National Oceanpgraphic and
Atmospheric Administration
Office of Coastal Resource Management
1825 Connecticut Avenue, N.W.
Suite 701
Washington, DC 20235
Phone:(202)606-4100
Fax: (202) 606-4329
Margie Carriger
Vice President, Public Affairs
National Association of Wheat Growers
415 Second Street, N.E.
Suite 300
Washington, DC 20002
Phone: (202) 547-7800
Fax: (202) 546-2638
Callie Childress
Water Quality Specialist
The Geological Survey
Department of Ipterior
3916 Sunset Road
Raleigh, NC 27608
Phone:(919)571-4000
Fax: (919)571-4041
Trevor Clements
North Carolina Department of
Environment, Health and Natural
Resources
P.O. Box 27687
Raleigh, NC 27611-7687
Phone:(919)733-4984
Fax: (919)733-0513
Anne Coan
North Carolina Farm Bureau Federation
P.O. Box 27766
Raleigh, NC 27611
Phone:(919)782-1705
Fax: (919) 783-3593
William W. Cobey, Jr.
Secretary
North Carolina Department of
Environment, Health and Natural
Resources
P.O. Box 27687
Raleigh, NC 27611-7687
Phone:(919)733-4984
Fax: (919)733-0513
James W. Cox
Manager, Technical Services Bureau
Virginia Division of Soil and Water
Conservation
203 Governor Street
Suite 206
Richmond, VA 23219
Phone: (804) 786-3957
Fax: (804) 786-1798
Jim Cumminjjs
NPS Section Chief
Division of Soil and Water Conservation
North Carolina Department of
Environment, Health and Natural
Resources
P.O. Box 27687
Raleigh, NC 27611-7687
Phone:(919)733-2302
Fax: (919)733-2622
Corbin Darling
Environmental Engineer
U.S. EPA, National Enforcement
Investigations Center
Building 53, Box 25227
Denver Federal Center
Denver, CO 8022I5
Phone: (303) 236-S5139
Fax: (303) 236-2395
Randy Dodd
Research Triangle Institute
3040 Cornwallis Road
Research Triangle Park, NC 27709
Phone:(919)541-6491
Fax: (919)541-7155
Cynthia Dougherty
Director, Permits Division
U.S. EPA
401 M Street, S.W.
Mail Code EN-336
Washington, DC £0460
Phone: (202) 260-9545
Fax: (202)260-1460
Mitch Dubensky
Manager, Timberlands and Water Quality
American Paper Institute
National Forest Products Association
1250 Connecticut Avenue, N.W.
2nd Floor
Washington, DC 120036
Phone: (202) 463-2434
Fax: (202) 463-2423
Russell Dutnell
Environmental Engineer
State Department of Health
1000 Northeast 10th Street
Oklahoma City, OK 73117-1299
Phone:(405)271-7333
Fax: (405)271-7339
Steve Eldredge
Chief of Planning and Special Program
Section
Michigan Department of Natural
Resources
P.O. Box 30028
Lansing, Ml 48909
Phone:(517)335-4177
Fax: (517) 373-9958
22
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James M. Ferguson
President
North Carolina Association of Soil and
Water Conservation Districts
Route 3, Box 43
Clyde, N^C 28721
Phone: (704) 627-6458
Karen K. Fidler
Associate Director of Water and
Grpundwater Programs
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, DC 20037
Phone:(202)887-1176
Fax: (202) 887-1237
Stuart Freudberg
Director of Environmental Programs
Metropolitan Washington Council of
Governments
777 North Capitol, N.E.
Suite 300
Washington, DC 20002
Phone: (202) 962-3340
Fax: (202) 962-3208
Adrian P. Freund
State of Connecticut
Department of Environmental Protection
Bureau of Water Management
122 Washington Street
Hartford, CT 06106
Phone: (203) 566-2689
Fax: (203) 566-8473
Maryann Froelich
Acting Director
Office of Policy Analysis
U.S. EPA
401 M Street, S.W.
Mail Code PM-221
Washington, DC 20460
Phone: (202) 260-4034
Fax: (202) 260-0780
Bill Funderburk
Attorney
Collier, Shannon and Scott
3050 K Street, N.W.
Suite 400
Washington, DC 20007
Phone: (202) 342-8837
Fax: (202) 338-5534
James Gardner
Loaned Executive
Edison Electric Institute
701 Pennsylvania Avenue, N.W.
Washington, DC 20004
Phone:(202)508-5925
Fax: (202) 508-5403
Roland Geddes
Natural Resources Consultant
National Association of
State Conservation Agencies
Route 3, Box 304
Tappahannok, VA 22560
Phone: (804) 443-2484
Fax: (804) 443-4534
Maryann S. Gerber
Nonpoint Source Coordinator
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Phone: (404) 347-2126
Fax: (404) 347-3269
Sandy Germann
Environmental Engineer
U.S. EPA
401 M Street. S.W.
Mail Code WH-556F
Washington, DC 20460
Phone:(202)260-6418
Fax: (202) 260-6294
Malcolm Green
General Manager
Greenville Utilities Commission
P.O. Box1847
Greenville, NC 27835-8668
Phone:(919)551-1500
Fax: (919)551-1597
Jim Greenfield
TMDL Coordinator
Water Division
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Phone:(404)347-2126
Fax: (404) 347-3269
Mitchell Griffin
Water Resource Engineer
CH2M HILL
P.O. Box147009
Gainesville, FL 32614
Phone:(904)331-2442
Fax: (904)331-5320
Bill Griffith
Eastern Director
Potash and Phosphate Institute
865 Seneca Road
Great Falls, VA 22066
Phone: (703) 450-4835
Fax: (703) 450-4835
Geoffrey H. Grubbs
Director
Assessment and Watershed Protection
Division
U.S. EPA
401 M Street, S.W. / Mail Code WH-553
Washington, DC 20460
Phone:(202)260-7040
Fax: (202) 260-7024
John Hall
Attorney
Kilpatrick and Cody
70013th Street, N.W, Suite 800
Washington, DC 20005
Phone: (202) 508-5859
Fax: (202) 508-5858
Terry Hammond
Raleigh Staff Correspondent
BNA Daily Environmental Report
P.O. Box51244
Raleigh, NC 27609-0244
Phone: (919) 876-7378
Fax: (919) 876-2016
Carlton Haywood
Associate Director for Technical Services
Interstate Commission on the Potomac
River Basin
6110 Executive Boulevard, SuiteSOO
Rockville, MD 20852-3903
Phone:(301)984-1908
Fax: (301)984-5841
Patricia HiU
Director, Water Quality & Waste Disposal
Program
American Paper Institute
1250 Connecticut Avenue, N.W.
Suite 210
Washington, DC 20036
Phone:(202)463-2420
Fax: (202) 463-2423
John K. Hosemann
Chief Economist
American Farm Bureau Federation
225 Touhy Avenue
Park Ridge, IL 60068
Phone: (312) 399-5746
Fax: (312) 399-5896
E. Stallings Howell
Chief, Wetlands, Oceans and
Watersheds Branch
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Phone: (404) 347-2126
Fax: (404) 347-5204
Linda Hubbard
Environmental Scientist
Bechtel National, Inc.
P.O. Box 350
Oak Ridge, TN 37831-0350
Phone:(615)574-3736
Fax: (615) 576-4898
Frank Humenik
Biological and Agricultural Engineering
Department
North Carolina State University
Box 7625
Raleigh, NC 27695-7625
Phone:(919)515-6767
Fax: (919)515-6772
23
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Marcella R. Jansen
Technical Assistance and Hazards
Coordinator
NOM, Office of Ocean and Coastal
Resource Management
1825 Connecticut Avenue, N.W.
Room 724
Washington, DC 20235
Phone: (202) 606-4181
Fax: (202) 606-4329
Richard N. Jarman
Director, Technical Regulatory Affairs,
EPA
National Food Processors Association
1401 New York Avenue, N.W.
Suite 400
Washington, DC 20005
Phone: (202) 639-5925
Fax: (202) 639-5932
Greg Jennings
Biological and Agricultural Engineering
Department
North Carolina State University
P.O. Box 7625
Raleigh, NC 27695-7625
Phone: (919) 515-6795
Fax: (919) 515-6772
Bobbye J. Jones
State Conservationist
U.S. Department of Agriculture
Soil Conservation Service
4405 Bland Road, Suite 205
Raleigh, NC 27609
Phone: (919) 790-2888
Fax: (919) 790-2881
James Jones
Associate Editor
Inside EPA Weekly Report
1225 Jefferson Davis Highway
Suite 1400
Arlington, VA 22202
Phone:(703)892-1011
Fax: (703) 685-2606
Richard M. Kashmanian
Senior Economist
Office of Policy, Planning and Evaluation
U.S. EPA
401 M Street, S.W.
Mail Code PM-221
Washington, DC 20460
Phone: (202) 260-5363
Fax: (202) 260-7884
Jeannine Kenney
Legislative Assistant
National Milk Producers Federation
1840 Wilson Boulevard
Arlington, VA 22201
Phone:(703)243-6111
Fax: (703) 841-9328
Amy King
Associate Editor
Inside EPA Environmental Policy Alert
1225 Jefferson Davis Highway
Suite 1400
Arlington, VA 22202
Phone:(703)892-8518
Fax: (703) 685-2606
Joel King
Siskiyou National Forest
200 Northeast Greenfield
Grants Pass, OR 97526
Phone: (503) 479-5301
Fax: (503) 474-3032
Ken Kirk
Executive Director
Association of Metropolitan Sewerage
Agencies
1000 Connecticut Avenue, N.W.
Suite 1006
Washington, DC 20036
Phone: (202) 833-2672
Fax: (202) 833-4657
Greg Kosaxin
Evaluator
General Accounting Office
411 G Street, N.W.
Techworld Plaza, Suite 200
Washington, DC 20548
Phone:(202)512-6526
Fax: (202) 336-6501
Randy Kramer
Associate Professor
Duke University
School of the Environment
Durham, NC 27706
Phone:(919)684-6090
Fax: (919) 684-8741
Eugene Lamb
Program Analyst
National Association of Conservation
Districts
509 Capitol Court, N.E.
Washington, DC 20002
Phone:(202)547-6223
Fax: (202) 547-6450
David Letson
Economic Research Service
U.S. Department of Agriculture
1301 New York Avenue, NW
Room 438
Washington, DC 20005-4788
Phone:(202)219-0446
Fax: (202)219-0477
Steve Levitas
Director, North Carolina Defense Fund
128 East Hargett Street
Suite 202
Raleigh, NC 27601
Phone:(919)821-7793
Mark Luttner
Special Assistant to the Deputy Assistant
Administrator
U.S. EPA, Office of Water
401 M Street, S.W.
Mail Code WH-558
Washington, DC 20460
Phone: (202) 260-9454
Fax: (202)260-5711
Leigh Ann Magee
Conference Coordinator
JT&A, inc.
1000 Connecticut Avenue, N.W.
Suite 802
Washington, DC 20036
Phone: (202) 833-3380
Fax: (202) 466-S554
Les Mahagan.
Evaluator
Government Accounting Office
10 Causeway Street
Room 575
Boston, MA 02222
Phone:(617)565-7515
Fax: (617)565-5909
Mark A. Maslyn
Assistant Director, National Affairs
Division
American Farm Bureau Federation
600 Maryland Avenue, S.W., Suite 800
Washington, DC 20024
Phone:(202)484-3615
Fax: (202) 484-3604
Ron McCormick
R. J. McCormick and Associates
160 Grouse Creek Road
Grants Pass, OR 97526
Phone: (503) 474-3041
Beth McGhee
North Carolina Department of
Environment, Health and Natural
Resources
P.O. Box27687
Raleigh, NC 27611-7687
Phone:(919)733-4984
Fax: (919) 733-0513
David McNaught
Executive Director
Pamlico-Tar Rivor Foundation
P.O. Box1854
Washington, NC 27889
Phone:(919)946-7211
Jim Meek
U.S. EPA Liaison to USDA
U.S. Department of Agriculture
Department of Science and Education
217-W Administration Building
Washington, DC 20250
Phone: (202) 720-4751
Fax: (202) 690-2842
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Peggy Michell
Program Analyst
Assessment and Watershed Protection
Division
U.S. EPA
401 M Street, S.W.
Mail Code WH-553
Washington, DC 20460
Phone:(202)260-5378
Fax: (202) 260-7024
Christopher A. Novak
Director, Environmental Programs
National Pork Producers Council
P.O. Box10383
Des Moines, IA 50306
Phone: (515) 223-2600
Fax: (515) 223-2646
Connie Oldham
Environmental Engineer
Office of Air Quality, Planning and
Standards
U.S. EPA
Mail Code 12
Research Triangle Park, NC 27711
Phone:(919)541-7774
Fax: (919)541-0237
Judy Olson
Secretary
National Association of Wheat Growers
Route #1, Box 93
Garfield.WA 99130
Phone:(509)635-1448
Fax: (509) 635-1396
Dana B. Ott
Office of General Counsel
U.S. EPA
401 M Street, S.W.
Mail Code LE-132L
Washington, DC 20460
Phone: (202) 260-5466
Fax: (202) 260-8046
Daniel S. Palmer
U.S. EPA
401 M Street, S.W.
Room3109MLE-134W
Washington, DC 20460
Phone:(202)260-8177
Fax: (202) 260-4201
Ray Pahnquist
Professor
Department of Economics
North Carolina State University
Raleigh, NC 27695-8109
Phone:(919)515-3274
Fax: (919) 515-7873
Lynn E. Parseghian
Attorney
O'Melveny & Myers
555 13th Street, N.W.
Washington, DC 20004
Phone: (202) 383-5320
Fax: (202)383-5414
Bruce Pewitt
Northwest Associates
2709 West Highway 3
Yreka, CA 96097
Phone:(916)842-3704
Mark Pfefferle
Environmental Economist
Science Application International Corp.
7600ALeesburgPike
Falls Church, VA 22043
Phone:(703)821-4755
Fax: (703) 821-4721
Mahesh Podar
Senior Analyst Economist
Water and Agriculture Policy Division
U.S. EPA
401 M Street, S.W., Mail Code PM-221
Washington, DC 20460
Phone:(202)260-2756
Fax: (202) 260-2300
Martha G. Prothro
Deputy Assistant Administrator
U.S. EPA, Office of Water
Mail Code WH-556
401 M Street, S.W.
Washington, DC 20460
Phone:(202)260-5700
Doug Rader
North Carolina Defense Fund
128 East Hargett Street
Suite 202
Raleigh, NC 27601
Phone: (919) 821-7793
Cindy Ricks
Westside Engineering Zone
93976 Ocean Way
Gold Beach, OR 97444
Phone: (503) 247-7026
Loreen Robinson
Amoco Corporation
200 East Randolph, M
Chicago, IL 60601
Phone:(312)856-6053
Fax: (312) 616-0152
A. T. Rolan
Director
Department of Water Resources
101 City Hall Plaza
Durham, NC 27701
Phone:(919)560-4381
Fax: (919) 687-0896
Julie Rome
Attorney
Hopping Boyd Green and Sams
123 South Calhoun Street
Tallahassee, FL 32301
Phone: (904) 222-7500
Fax: (904) 224-8551
Greg Ruehle
Policy Analyst
National Cattlemen's Association
1301 Pennsylvania Avenue, N.W.
Suite 300
Washington, DC 20004
Phone:(202)347-0228
Fax: (202) 638-0607
Roger N. Schecter
Director
North Carolina Division of Coastal
Management
225 North McDowell Street
Raleigh, NC 27602
Phone:(919)733-2293
Fax: (919) 733-0490
Stuart Schwartz
Assistant Director for Water Resources
Interstate Commission on the Potomac
River Basin
6110 Executive Boulevard, Suite 300
Rockville, MD 20852-3903
Phone:(301)984-1908
Fax: (301)984-5841
James W. Shell, Jr.
Manager of Water Resources Planning
Metropolitan Washington Council of
Governments
777 North Capitol, N.E.
Suite 300
Washington, DC 20002
Phone:(202)962-3342
Fax: (202) 962-3203
Carol Ann Siciliano
Attorney-Advisor
Office of General Counsel
U.S. EPA
401 M Street, S.W.
Mail Code LE-132W
Washington, DC 20460
Phone:(202)260-8653
Fax: (202) 260-7702
Ellen Siegler
Attorney
American Petroleum Institute
1220 L Street, N.W.
Washington, DC 20005
Phone:(202)682-8271
Fax: (202) 682-8033
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David Smith
TMDL Coordinator
Water Management Division
U.S. EPA Region IX
75 Hawthorne Street
Mail Code (W-3«2)
San Francisco, CA 94105
Phone:(415)744-2019
Fax: (415)744-1078
Amy Sosin
Environmental Scientist
Assessment and Watershed Protection
Division
U.S. EPA
401 M Street, S.W.
Mail Code WH-553
Washington, DC 20460
Phone: (202) 260-7058
Fax: (202) 260-7024
Jean Spooner
Biological and Agricultural Engineering
Department
North Carolina State University
P.O. Box7637
Raleigh, NC 27695-7637
Phone:(919)515-3723
Fax: (919) 515-6772
Dave Stawick
Assistant Vice President
National Corn Growers Association
201 Massachusetts Avenue, N.E.
Suite C-4
Washington, DC 20002
Phone:(202)546-7611
Fax: (202) 544-5142
Judy Taggart
President
JT&A, inc.
1000 Connecticut Avenue, N.W.
Suite 802
Washington, DC 20036
Phone: (202) 833-3380
Fax: (202) 466-8554
Alison Taylor
Davis, Graham & Stubbs
120019th Street, NW
Suite 500
Washington, DC 20036
Phone:(202)822-1026
Fax: (202) 293-4794
Steve W. Tedder
Water Quality Section Chief
Division of Environmental Management
North Carolina Department of
Environment, Health and Natural
Resources
P.O. Box 27687
Raleigh, NC 27611-7687
Phone:(919)733-5083
Fax: (919) 733-9919
Jim Turner
Water Resources Division District Chief
The Geological Survey
Department of Interior
3916 Sunset Road
Raleigh, NC 27607
Phone:(919)571-4000
Fax: (919) 571-4041
Frank Tursi
Winston-Salem Journal
418 North Marshall Street
Winston-Salem, NC 27012
Phone:(919)727-7267
Fax: (919)727-7315
John Veil
Environmental Engineer
Argonne National Laboratory
370 L'Enfant Promenade, S.W.
Suite 702
Washington, DC 20024
Phone:(202)488-2450
Fax: (202)488-2413
Christine Wallace
Atlantic Division
Naval Facilities Engineering Command
Commander, Code 1812
Norfolk, VA 23511-6287
Phone: (804) 445-6982
Fax: (804) 445-6662
Robert H. Wayland III
Director, Office of Wetlands, Oceans and
Watersheds
U.S. EPA
401 M Street, S.W.
Mail Code WH-556-F
Washington, DC 20460
Phone: (202) 260-7166
Fax: (202) 260-6294
Cam Wheeler
Carolina Power & Light Co.
411 Fayetteville Street
Raleigh, NC 27602
Phone:(919)546-6725
Fax: (919) 546-4171
Debra Whitall
U.S. Forest Service
Rogue River National Forest
P.O. Box 520
Medford, OR 97501
Phone: (503) 776-3600
Greg Wilkins
Environmental Engineer
Ashland Petroleum
P.O. Box 391
Ashland, KY 41114
Phone: (606) 329-3457
Fax: (606) 329-3920
Louise Wise
Director, Policy and Communications
Staff
U.S. EPA
401 M Street, S.W.
Mail Code WH-556F
Washington, DC 20460
Phone: (202) 260-7166
Fax: (202) 260-6294
Bruce A. Zander
Environmental Engineer
Office of Water Quality
U.S. EPA Region VIII
99918th Street
Suite 500
Denver, CO 80202-2405
Phone:(303)293-1580
Fax: (303)294-1386
Everett Zilliinger
Director, Legislative Affairs
The Fertilizer Institute
501 Second Street, N.E.
Washington, DC 20002
Phone: (202) 675-8250
Fax: (202) 544-8123
Robert J. Zimmerman
Program Administrator
Delaware Department of Natural
Resources and Environmental Control
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
Phone: (302) 739-5726
Fax: (302) 739-3491
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APPENDIX C
BREAKOUT GROUP I DISCUSSION
GROUP MEMBERS
Joel King, facilitator
Maryann Froelich
Robert Wayland, III
Amy Sosin
Patricia Hill
Mark Maslyn
Greg Ruehle
Richard Jarman
Scott Bpettcher
Rick Balla
Elise Bacon
Russell Dutnell
Deborah Allen
Greg Wilkins
Jean Spooner
Connie Oldham
William. Cobey, Jr.
Worst Outcomes
m Show how little I know about water.
Won't have open communication between point source and nonpoint source
contributors.
Won't answer questions.
Ken Kirk's prediction about paperwork would come true.
Plane crash situation; we won't learn.
If everyone doesn't speak up.
If the agenda developed here does not reflect all opinions.
If we discover contracting errors.
If recommendations have no practical applications.
No recommendations for market incentives in water program.
If EPA uses this agenda exclusively in making decisions.
27
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Private industry excluded from market-based programs.
Won't be able to say what I'm supposed to say.
Won't know the answer to "Why are we here?"
If Inside EPA quotes me while I'm wearing two hats.
If group fails in its task.
Best Outcomes
We find trading can be a win/win situation for all parties.
We realize the promise that point/nonpoint trading holds and its benefits
for agriculture.
We learn more about trading so we can better relate to constituents.
We broaden trading to be a permitting option in the future.
All parties will get a better understanding of the concept.
We increase understanding of the power of trading for environmental
protection and find risk-takers to advance and demonstrate market
incentives.
We will work cooperatively with agricultural agencies to maintain long-term
conservation practices.
We will have an open and honest exchange of views and be able to translate
them into a new consensus in meeting environmental challenges.
We will explore administrative and institutional issues associated with
trading is it worth the administrative risks?
We will be able to administer trading to the satisfaction of the States,
POTWs, and other affected parties.
We will learn enough about procedures and process to implement, the
concept.
We will gain enough knowledge to educate constituents and begin
cooperative actions.
Participating in the group is an outcome if we get reactions to the report.
We will continue to identify management tools and efficient mechanisms to
achieve water quality goals.
H We will gain new, transferable insights.
Barriers/Opportunities
Brainstorm List
Suspicion of hidden agenda.
Questions about accuracy of identified sources of pollution.
28
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Questions about data reliability.
Complexity or size of watershed.
Ability to measure success that is technically and politically acceptable.
Improve water quality.
Education process required for cooperation.
Adequate enforcement mechanisms.
Need to periodically evaluate progress.
Potential expansion of enforcement and compliance actions without
statutory authority.
Complexity of technical issues.
Identification of water quality problems and sources may be incomplete.
Potential for cost savings.
Liability associated with nonattainment.
Different goals of various parties involved.
Absentee landlords.
Lack of clarity of different parties.
Long-term reliability of nonstructured BMPs..
l Point source dischargers unwilling to pay for nonpoint source controls.
i Institutional resistance to innovative tools.
i Inflexibility of existing laws and regulations legal.
i Need for site-specific information on BMP effectiveness.
I Inability of point sources to meet water quality goals by themselves.
i Political climate.
i Need to involve all parties.
i Chance for everyone to obtain mutual objectives.
i Is there a lack of government resources to oversee.
i Inability of parties to accept responsibility.
i Accurate data needs.
i Economic climate that would encourage more cost savings.
i Lack of incentives for nonpoint sources to participate.
i Reauthorization of CWA that precludes trading.
i Need to address intermediate transfers.
i Potential freeing up resources for other societal needs.
i How to address need for continued economic growth.
i Rate payer support.
29
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Creation of unstable market.
Limited focus on trading.
Questions about private property rights.
Real or perceived inequities of bearing the cost.
Existing command control mentality that we are working with/under law.
Opportunity to focus on costs and benefits.
Need to have a tool to address a large number of various discharges.
Nonpoint source dischargers unwilling to pay for nonpoint source control.
Annual variability in loads.
Absence of success stories.
Land use controls.
Legal challenges.
Risk of a perceived subsidization.
Education.
SUBGROUP 1: Regulatory/Legal Issues
Regarding Implementation
ACTION PLAN
1. Address suspicion of "hidden agendas."
Agree that overall objective is improvement of water quality and meeting
water quality standards.
B Without abdication of private property rights and/or excessive land use
controls.
2. Once above is accomplished, identify barriers/inconsistencies in. existing
laws/regulations, then
amend statute and revise regulations to
remove barriers,
clarify objective to promote or encourage implementation of trading,
and
clarify enforcement and compliance mechanisms (i.e., document
chain of responsibility for contracts, agreements, penalties,
sanctions).
3. If above are successfully accomplished, legal challenges could be
minimized.
4. Determine who will be responsible for implementing, regulating, and
monitoring these programs. The question, "who?" should be linked to each
stage of the action plan.
30
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EPA, States, national trade associations, locals, public/environmental
interest groups through public education, working groups, and public
meetings.
All of the above.
Regulatory agencies and legislators.
Regulatory agencies.
All parties or no parties.
LIST OF ISSUES
Inflexibility of existing laws and regulations.
Suspicion of hidden agendas.
Adequate enforcement mechanisms.
Potential expansion of enforcement and compliance actions without
statutory authorization.
Reauthorization of CWA that precludes/promotes trading.
Questions about private property rights.
Liability associated with nonattainment.
Land use controls.
Legal challenges.
GROUP FEEDBACK ON ACTION PLAN
As part of clarifying enforcement mechanisms: add innovative
enforcement/sanctions; not traditional penalties.
Question: What are the hidden agendas? Hard to argue with goal of
improving water quality. Hidden agenda may be related to who is
responsible for improving water quality.
Hidden agendas potentially in transfers of responsibility. Many think
there are hidden agendas.
Address hidden agendas through open process.
Agendas not hidden goal is geared toward improving water quality; just
finding a different way of getting there.
But is there authority now in CWA?
Is this approach unique?
There are two existing programs, and two that will begin.
All parties in above programs have agreed to trade. If trading is required,
people will be wary.
Is role of Agency to say this is what we should do
opportunity, possible tool?
When does guidance become GUIDANCE?
or to present it as an
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SUBGROUP 2: Information Needs
ACTION PLAN
A. What needs to be done?
B. To develop opportunities
C. Who?
State
Federal
Point Source
1. Problem Assessment
*3
*4
*7
*10
*12
A. Collect data
B. Share existing information
C. State, Federal, private, local sector
2. Implementation
* 5 *10 A. Demonstration pilot projects
B. Information/education process
C. Private sector and State/local, Federal overview
(targeting B., B. reflecting on A)
*1*13
*2
*8
*2
3. Evaluation
* 5 * 10 A. Monitor experimental design
* 1 * 13 B. All parties agree on goals (water quality, land treatments)
* 2 C. Large State role, but all parties, local government
*4
*6
*7
ISSUES
1. Long-term reliability of structural BMPs.
2. Need for site-specific information on BMP effectiveness.
3. Questions about accuracy of identified sources of pollution.
4. Questions about data reliability.
5. Complexity or size of watershed.
6. Need to periodically evaluate progress.
7. Accurate data needs.
8. Opportunity to focus on costs and benefits. !
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9. Need to have a tool to address a large number of various discharges.
10. Annual variability in loads.
11. Identification of water quality-based problems and sources may be incomplete.
12. Absence of success stories.
GROUP FEEDBACK
Was there any discussion on the need for more fundamental research? Are
the tools and technology that exist adequate?
There always needs to be more research on data collection methods.
Costs/benefits: if we want a basinwide effort, we need to break out goals and
set priorities (limitations on resources); then we can look more carefully at
costs/benefits. This requirement results in ranking alternatives (i.e.,
costs/benefits analysis goes beyond data).
Are there any requirements for nonpoint sources?
There are no Federal regulation requirements, but some State requirements.
There are regulatory programs under USDA. There are incentives in the
Farm Bill.
There are some State regulatory programs States have authority.
There is threat/fear for agricultural community. Agricultural community
needs to take advantage of existing programs.
Ranchers and fanners have tremendous incentive to put BMPs and other
management ideas in place. Programs are very well received. But there are
cost restraints. Need to overcome economic barriers.
Need to include cost of not doing BMPs and other management techniques
in cost/benefit analysis.
A lot of this is education.
n The audience is receptive. Farmers want to do what is right for the
environment, but they also want demonstration of nonpoint problem.
Want proof of benefits proof that a difference will be made. This
requirement implies education and demonstration.
How can we get parties to commit if don't have absolute demonstrations
(e.g., Boulder Creek cost savings)?
Need increased transfer of information and information on relationships
between activities and environmental results.
How long does it take to educate the farmer? Why do nonpoint sources need
special treatment and special education?
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SUBGKOUP 3: Economic
Considerations
ACTION PLAN
Ensure equity between point sources and nonpoint sources in controls and
costs.
National/State laws/regulations.
Education and economic analysis to show cost savings.
State - analysis.
Locals education.
LIST OF ISSUES ECONOMIC CONSIDERATIONS
Creation of unstable markets.
How to address need for continued economic growth.
Potential freeing up of resources for other societal needs.
Potential for cost savings.
Land use.
Economic climate that encourages cost savings.
Lack of incentives for nonpoint sources to participate.
ADDITIONAL ISSUES EQUITY/RESPONSIBILITIES
Inability of point source to meet water quality goals by themselves.
Real or perceived inequities of bearing costs.
Nonpoint source dischargers unwilling to pay for nonpoint source controls.
Economic climate that would encourage more cost savings.
Lack of incentives for nonpoint sources to participate.
Rate payee support. :
Absentee landlords. ;
Point source dischargers unwilling to pay for nonpoint source controls.
GROUP FEEDBACK ECONOMIC CONSIDERATIONS
I ~~
Are the players always POTWs (point source) and agricultural (nonpoint
sources)? The community can be broader; it depends on location a.nd
problems.
There are industries (and food) that are tied into POTWs some dealt with
through pretreatment (not trading).
Scope gets complicated with more players economic analyses and other
issues become more complex.
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Discussions in group have applied to broader approach that brings in other
entities. (What about abandoned mines?)
Is there anything to be said about the fact that a lot of money was
transferred from government to State to contract point source dischargers
(e.g., in 1970s)?
Point source community highly regulated local governments now expend
great amounts of resources.
Nonpoint source dischargers are now regulated, but are not getting the
same level of assistance.
Add incentives to national/State regulations.
How important is equity compared to overall cost savings? Costs eventually
get passed on to public in all cases. Is least cost more important than equity?
SUBGROUP 4: Institutional Issues
ACTION PLAN
EPA TO DO
1. Law
Guidance
Legislative initiatives
Legal analysis Clean Water Act issues
Empowerment
Policy statements regarding expectations
2. Organizational role of EPA articulate structure/culture of watershed
protection approval step up
Pilots
Basin organization
Education "resistance to change"
Success stories
3. Implementation
Promote risk taking
Promote consensus/collaborate negotiations
Guidance/publications
National regulations
Pilots
MODELS (USA, Europe)
Momentum/trends
Federal/State/local/regulated
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4. Education buy-in
National associations educate/involve
"Tool kits" for locals
Put expectations in check/establish
5. Win-win
Promote consensus-building skills
Change of approach
LIST OF ISSUES INSTITUTIONAL
Institutional resistance to innovating tools:
Inflexibility of existing laws and regulations.
Suspicion of "hidden agendas."
Complexity or size of watershed.
Ability to measure success (technically and politically).
Cooperative education is required.
Need to periodically evaluate progress.
Need to address intermediate transfers.
Chance for parties to attain mutual objectives. ',
Limited focus on trading (with nutrients).
Complexity of technical issues.
Goals of involved parties.
Tool to address large number of discharges.
Lack of clarity regarding roles.
Political climate.
Need to involve all parties,
M Lack of government resources for oversight.
Existing command and control climate.
GROUP FEEDBACK
Everyone needs to be involved in all action items (not just the EPA).
Basin organization includes all parties and institutional structures.
Coordination among agencies and parties is implicit "Basin Culture."
Oversight/Enforcement this approach requires cultural change. Need
institutional changes. How will this be enforced?
Guidance should address above issue of enforcement and also needs to
clarify the role of the EPA.
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Enforcement: program is driven by economics. If approach doesn't work on
basin-by-basin basis, at least cost, then old ways will emerge. This is
enforcement mechanism cost savings.
For farmers penalty could be paying money with interest.
CONCLUSIONS
Potential to be a viable tool:
Needs further assessment
Pilot studies, tests, demonstrations
Not to be mandated yet if so how?
n Cautious optimism
IMPROVE WATER QUALITY
Inability of point sources to meet water quality by themselves.
Opportunity to focus on cost and benefits.
Annual variability in loads.
Complexity in technical issues.
Limited focus on trading (nutrients).
Complexity or size of watershed.
Improve water quality (topic not covered in detail).
SOCIAL/POLITICAL ACCEPTANCE
Narrow-focused.
Suspicion of hidden agenda.
Land use controls.
Different goals of various parties.
Political climate.
Chance for different parties to achieve mutual objectives.
Inability of parties to accept responsibility.
Risk of perceived subsidization (topic not covered in detail).
POTENTIAL PILOT WATERBODIES/CONTACTS
Gushing, OK (Cottonwood Creek) Russ Dutnell
McAlester, OK (West Plant) Russ Dutnell
Chehalis, WA Scott Boettcher
Spokane River, WA Scott Boettcher
Puyallup, WA Scott Boettcher
Westchester County Drainage of Long Island Sound Rick Balla
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GROUP FEEDBACK
Good identified barriers and concerns that need to be addressed.
Fleshed out questions will find answers to communicate back.
Going well.
Hopeful that what we've done will help EPA come up with alternative
permitting option.
Progress going well; fleshed out questions, concerns, and opportunities.
Good backdrop for moving forward.
Starting to see agenda for further action; group members are positive about
process.
Good about process; on way to developing "what to do" solutions.
Nothing new here.
Consensus-building process makes us feel good, but it remains to be seen if
questions will be answered.
A lot of work ahead (for EPA), but there's a structure in place for it.
Anxious to hear what group accomplished.
Different perspectives are interesting.
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BREAKOUT GROUP II DISCUSSION
GROUP MEMBERS
Debra Whitall, facilitator
Robert Alpern
Diane Cameron
James Cox
Steve Eldredge
John Hosemann
Roger Schecter
Greg Jennings
Greg Kosarian
Judy Olson
Mark Pfefferle
Dave Stawick
Geoff Grubbs
Trevor Clements
Peggy Michell
Bill Punderburk
Jim Greenfield
Frank Tursi
Worst Outcomes
We don't listen to each other and process falls apart.
We can get a real good idea or concept for pollution trading (PT) but have
too many controls (in setup). Don't think we should regulate first.
We won't successfully understand.
I fear we won't get beyond the surface rhetoric.
People with good ideas won't get a chance to express them.
This could be another good idea to put on the shelf if it doesn't get
integrated.
It won't take place.
People will walk away from the meeting not knowing about PT.
We'll develop a Cadillac version of a trading policy applicable to a few places
but not to all showcase watersheds that won't get translated to all the
watersheds that need work. Need more dialog and meshing of our goals.
We won't address ourselves to the common themes on trading.
We'll have great ideas but neglect finances.
Have to keep in mind there are a lot of policy issues.
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We may not be smart enough or strong enough to think through financial,
political, and technical stuff to get where we want to go.
People won't speak candidly about whether it's a good or bad idea because
EPA seems to be going down this road already.
A potentially good idea may be turned against major urban centers because
they're easy to control and easy targets.
I fear that higher ups will decide rather than those doing the polluting
for example, farmers own the property they are polluting.
Best Outcomes
m All participants speak out regarding trading.
Set priorities.
Identify options for trading systems.
Everyone will speak freely and everyone will listen regardless of who
we represent.
Set up a network and schedule for resolution of key issues.
We come away with the first two steps accomplished we can all agree we
have a set of watersheds that need to be addressed point/nonpoint
trading might be a good idea; no one source of pollution takes responsibility
but all sources take responsibility.
A clear understanding of where the agreements and disagreements lie. Not
get all jumbled together.
Candid, open discussion.
A clear idea of what trading is.
Identifying all the players and their roles and how to keep people involved
in positive role.
Walk away with more open minds than we had when we came in.
How to convince point source dischargers that this is valuable to them.
Develop demonstration project.
Need something ongoing agree to nonpoint question answer scientific
questions ownership - discipline and trading.
Need solid science on who's polluting what.
We need some science about site pollution.
Barriers and Opportunities
Brainstorm List
Barrier what is trading?
Problems are multiparameter single parameter concerns me.
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Effective means for point source cooperation.
Blending of the different technical roles.
A lack of public involvement people may feel they're being worked on
rather than being worked with.
Concept is very broad get a handle on what it is and what's been done
with it.
Nonpoint and point sources are contributing definition of point and
nonpoint who's got ownership?
i How do you bring both parties to table and fairness/equity?
I Trading will end up masking the effects of urbanization and, if not done in a
sensitive way, enabling urbanization and its effects.
i Issue of credibility point and nonpoint runoff predictable effectiveness.
I Great opportunity to move to cost-effective program.
i Liquidity best done on watershed basis. Are there enough participants in
that watershed?
i Real need to find additional capital to pay for water.
i Present mindset.
i Inappropriate focus on point sources.
i Problem of moving standards, data, qualities need standards for these
and technology.
Atmospheric vs. hydrologic sources.
Habitat restoration needs to be recognized.
Differentiate between sources (problems) and what's a trading issue.
Is suet
i Trading schemes ignore upland and upstream effects in favor of
management in the very end (estuaries) Chesapeake Bay protected at
cost to wetlands, uplands habitat, and other issues. Am against it if trading
is at this cost.
i What's the best way we can protect and restore this watershed?
i Market and values will eventually work this out broaden to include all
values.
i What do we mean by a basinwide plan? Need a better definition.
We may be defining trading through too narrow a focus.
Today we have a worldwide context and trading around the clock.
Identify objectives are we forgetting about this aspect have
opportunity of using basinwide plan to get at these priorities and goals.
Can the market give us more habitat protection yes, if broadly defined
no, if narrowly defined.
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If we ever got to a discussion of water-trading values, we'd have made a big
step.
The integrative process will eventually deal with these things.
Stormwater runoff trade-offs in Maryland very difficult.
Agriculture last remaining hastion of pollution need to think about
nonpoint source.
If we purify the sector, we make progress.
The broader the base at the bottom, the better chance this lias to
work.
Agriculture needs to ask "are they harming anyone killing
anyone?"
i Nonpoint and point trading the ability to measure contribution is a real
problem.
I Establishing the value of what you're trading.
Giardia cysts and cryptocysts on the farm. Data, standards are not there
yet. Chlorine doesn't even get at them. We're just at the beginning of
understanding.
Recreation, mining, and other sources of pollution
Summarizing
Equity and getting runoff polluters to the table.
How do you create value, market create priorities and hierarchies?
Appropriateness of the trading process.
Once you have this list, then you have subquestions.
If I have a value, but I don't know how to market that value, that's
inappropriate.
We're here to hear what differing views are and how to mesh them.
What's been done and what it really is? Track record.
Trading as a concept is a value if it will solve more environmental problems
at lower costs.
What about getting the same kind of gains under current regulatory laws at
lower cost?
Current gains only recognized in better water quality.
The issues are broader than water quality.
Urban area wetlands need to be considered, too, in relation to water quality.
Should we limit to water quality?
$40 billion in source treatment?
Regulating freshwater at lower costs.
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Should we talk [about] public health.
Chemistry is not a good substitute.
Problem: are living resources important in Chesapeake Bay and chemical
resources?
If you have a multiparameter basin plan and a fuzzy chemical plan,
numerical goals win out fuzzy values lose.
If you maintain the health standard of the water but improve water for the
fish, those resources will come back.
No longer see or make a connection between water quality and living system.
Most important thing we can do is to define the problem. Until we've done
that, we're just giving in to majority vote.
Do we want to go back to the group saying these are the problems we see or
do we want to say this is what we see as what to do about these problems?
What are values and how do we create a market?
Not only what waterbodies but also what kind of pollutants should be
considered?
Is there a need for statutory change?
Key issues are 10, 18, 22, and 24.
How to determine what has a value?
Credibility of BMP effectiveness
Separate trading from nonpoint source control issues.
How to create value and market ability to measure.
Brainstorming Writeouts
(Please note: asterisks (*) denote number of votes given to each topic.)
Define trading: lay/politician.
Multiparameter problem.
Effective means for point source cooperative.
Reconcile technical and regulatory Issues. *
Lack of public involvement.
No track record.
Define ownership of point and nonpoint source. *
Equity and getting nonpoint source people to trade. *
Enabling urbanization and masking its effects. ***
Credibility of BMP effectiveness. ******* #1
Move to use more cost-effective BMPs.
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Liquidity: enough participant facilitation.
Need for additional capital to finance BMPs. **
Mindset. *
Changing standards. **
Atmospheric vs. hydrologic sources. **
Habitat restoration has to be recognized. *
Separate trading from nonpoint source control issues. ***** #2
Minimizes upland effects.
Opportunity for basin planning. ***
NP/NP trading on narrower base this is the worse case, the problem.
Inability to measure establish the value of what you are trading. ********
#3 combined with (24)
Other contributors recreation silviculture chronological water
quality gains under current regulatory framework at lower cost.
How to create value? Market? *** #3 combined with (22)
B Kind of pollutants considered for trading. *
B Need for statutory change. ***
SUBGROUP 1 Discussion
Claim credibility menu of choices don't force options.
B Begin at local level let locals identify problems take first shot at
options for correction.
B State and local pick up on finances feed down to local level partnership
for implementation.
B Waterbodies more of a generic need.
B What about resources needed to do evaluation?
a State source of evaluation along with EPA and others.
B Should some of the trading money be traded off for this?
B I don't think so. Real reductions are your ultimate goal.
B Could post-reduction be part of the trading process?
B Maybe they have to document that they made their claims in trading
process.
B What size watershed?
The larger the watershed deal with urbanization look to controlled
watersheds' small to moderate watersheds so you can track them.
B Forest Service has rules of thumb.
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8 to 10 thousand acres.
Can test beyond edge-of-field but not so far that we lose control.
Looking at ways to improve our modeling capabilities.
Work done at North Carolina State and at Wisconsin.
As a group we don't know what has been done and what hasn't. Need to get
the word out (on what's already been done).
Need to know why results in different areas and States are different from
one another.
Each watershed unique.
Will modeling help? Yes, we think so.
Deal with what data you have, consider what you need, and begin to work
from there.
Coastal plain of Piedmont extrapolate.
SUBGROUP 2 Discussion
m Still some problems between source issues and trading issues.
Generic, nonpoint issues vs. trading issues.
Someone at center needs to be in touch with wide variety.
Facilitate change go talk to these people to see how they handled problem
largely informational to get trading off the dime.
We need a two-step approach.
Identify regulatory goals must be understood
Then you can begin putting together market values and setting up
structures trading not panacea to problem.
SUBGROUP 3 Discussion
Been working on trading for as long as I've been in water quality.
Create a value system that evolves from trading generate on-site among
the users and benefactors privatization.
Quality goal of some kind allocate goal among point and nonpoint
coalitions.
Consider impact of both on- and off-site pollution.
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GROUP 1 Issue 10
Barrier: Credibility of BMP effectiveness
Lack of readily accessible information on the fate and transport of pollutants
from various land use practices, particularly on a watershed scale as
opposed to edge-of-field.
Uncertainty that dollars put into BMPs to meet equivalent pollutant
reductions will actually result in targeted reductions. :
Others: Feasibility "one-size-does-not-fit-all" administrative effectiveness
to ensure that BMPs are in place and length of tune BMPs are effective.
What needs to be accomplished to remove barriers?
a) Need to aggregate information from existing research and compile
into useful reference. If already done, then need to get thes word out.
b) Perform additional studies to fill gaps identified during the
compilation of existing information, particularly "before and after"
studies on the watershed scale (warning: be sure to account for all
land use activities during study, not just on BMP implementation
areas).
c) To maintain credibility with those having to implement BMPs,
provide for a menu of BMP choices; try not to force one option.
Who needs to do it?
a) Needs to be a partnership of local conservation districts with State
and Federal agencies:
ROLES:
Local district: Opportunity to identify known problems or discuss
those presented to them from outside agencies and take first shot at
which direction needs to be taken to address the problems (i.e., types
of BMPs, feasibility). Input and shape direction.
State and Federal: Fund and perform additional studies as needed
. to develop technical information base. Mechanism for technology
transfer, feed information back down to local level.
Technical research and information transfer. ,
Partnership in implementation: equal say in strategies.
Pilot waterbodies? Generic need; apply to any waterbody that meets
other trading criteria.
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GROUP 2 Issue 18
m Confusion between problems that are inherent in addressing nonpoint
source pollution (regardless of approach), e.g., establishing goals, monitoring
enforcement, and those limited to trading, e.g., institutions to facilitate
trades.
n EPA to provide guidance to those considering trades:
More specific guidance needed to clarify distinctions.
A clearing house function.
Facilitate exchange between those who have done trades and those
interested in trade networking.
GROUP 3 Issues 22 and 24
Have been working in environment trading for 50 years. What we want to
do is create a value system to allow bartering and generate a self-designed
market. Privatization.
Need to define a water quality goal.
Need to allocate per watershed point vs. nonpoint on-site vs. off-site
benefits.
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BREAKOUT GROUP III DISCUSSION
GROUP MEMBERS:
Ron Boatner, facilitator
Dave Leston
Randall Benn
Louise Wise
Richard M. Kashmanian
Dana B. Ott
James Gardner
Eugene Lamb
Ralph Cantral
Stuart Schwartz
Robert Zimmerman
Arthur Ashendorff
Mitchell Griffin
Beth McGhee
Jim Cummings
Bobbye J. Jones
Worst and Best Outcomes
Too much disagreement about trading initiative/spill over into point source
area.
Total chaos/more cost sharing.
Point source focus thinking: too strong/more decentralized focus nonpoint
focus.
Waste of time; no listening/good answers to questions.
Oversimplified outcome; rosy picture/source tradeoff.
Miss benefits of big picture/Get view of big picture.
Big report gets put on the shelf/ideas of widespread application.
Too rosy impression/identification of shortfalls in ultimate report.
Polarization/questions get answered especially about watersheds.
Additional delay/new ideas; moving forward even without all the answers.
EPA gets too rosy picture/clarification of meaning.
Thinking that this will work everywhere/accept concept.
Disincentives/arrival at least cost solutions.
Conference waste of time/productive.
Layers of bureaucracy.
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Barriers and Opportunities
Brainstorm List
(Key: B for barrier; E for enabler; asterisks indicate priority to group)
Proving BMPs difficult; lack of quantification of BMPs. *** (B)
Initiative allows people to pollute. (B)
Water quality problem is one that people identify with. (E)
NPS lack of positive communication. (B)
Historical attitudes. (B)
Perception that point source has footed bill for too long. (B)
Technical data on the table for everyone to see. (E)
Contradictory objectives. (B)
Without total maximum daily load (TMDL), the process set-up cost is too
high and borne by point source. (B)
Scientific certainty of TMDL. (B)
Absence of loading limits (TMDL). (B)
Funding. (B)
TMDL process itself. (B)
Traditional attitudes of agriculture. *** (B)
Changing attitudes. (E)
Opportunity to quantify BMP benefits. (E)
Dual management tool (protect water quality and promote growth). (E)
Inappropriate standards for point source. (B)
Variability in water quality standards. (B)
Potential for saving money means voluntary interest. *** (E)
Elevate public knowledge of existing NPS management options and
programs,
***
(E)
We have reached the point where the amount we spend on point source
doesn't make the difference it used to now it's time for nonpoint to take
over a bit; it will be beneficial to spend money now on nonpoint.
Greater gain environmentally for dollars spent. *** (E)
Cooperation. (E)
Cooperation. (B)
Lack of variability in water quality strides for NPS. *** (B)
Suspicion of innovation. (B)
Something different than regulations. (E)
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Flexibility. *** (E)
Changing attitudes (agencies and locals). (E)
Uncertainty /controllability of NFS. *** (B)
Existing statutes; what is the baseline? (B)
Facilitates BMP implementation. (E)
Organize, Summarize Data, and
Set Priorities
(Based on participant vote)
Attitudes = most important.
Flexibility = Barriers and Enablers.
Cost/Benefit.
NFS uncertainty.
Group Work Assignment:
Four Questions
What needs to be done to remove the barrier or enhance the enabler?
Who needs to do it?
List pilot waterbodies.
Prepare five-minute report for presentation.
SUBGROUP 1 Discussion
ATTITUDES
Barriers:
Agricultural attitude "We're not the problem."
Agency attitude:
Thinking only it can fairly deal with problems.
Refusal to let go of traditional programs.
Point source attitudes feel they've done their share.
General public attitudes:
Suspicions
Lack of knowledge
Unsure it will work
Perception of agriculture
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Solutions:
Foster cooperation Who: everyone
Use Watershed management to bring all stakeholders together . .. then use
stakeholders to sell peer to peer the trading concepts *(on pilot basis)
Who: EPA, USDA, shared participation, constituent groups, NACD, AS &
WPCA, NASDA, and others.
Educate and promote watershed trading to national constituencies by
building on national watershed committees (e.g., EPA and interagency
group) as appropriate; don't be too rosy Who: national local levels.
Provide knowledge.
Educate public about trading concepts from national level:
Develop education program.
Distribute public education document on information in Mark
Lutner's report.
Put articles into newspapers (e.g., Washington Post).
m Training workshop use hypothetical situations to teach.
SUBGROUP 2 Discussion
NONPOINT SOURCE POLLUTION UNCERTAINTY
Barrier:
Nonpoint sources of pollution are inherently variable: spatially, temporally,
and in magnitude. This makes regulating NFS and quantifying the control
of NPS more difficult. In turn, this lessens the confidence of both the
regulators and the public in the ability to formulate effective NPS
management plans.
Solution:
Educational opportunities exist by improving documentation about available
and accepted BMP performance. This documentation should address
targeting BMPs to the right problem; for example, parameters that are
controlled and effective placement (locating BMPs in the watershed).
Who: This documentation needs to be developed on a State basis,
although some "grouping" of States could occur. Need the States to
"buy in" to a set of BMPs.
EXAMPLES:
319 Programs listed BMPs need to be revisited by States,
CZMA guidance too general and uneven. '
Florida just published a nice document, but it lacked performance data.
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Barrier:
n Extensive routine compliance monitoring drains resources that could be
more effectively used in implementing NFS controls. The high variability of
NFS loadings makes routine monitoring less useful than for point sources.
Solutions:
Use planning-level estimates of BMP effectiveness as a "measuring rod."
Carefully assess the watershed at the onset of a focused NFS management
plan, but don't do it again until after a significant improvement has been
noted. See lessons learned from the Rural Clean Water Program. This
strategy would be more successful if the State will "buy in" on BMPs.
States need to keep a geographic database of BMP installations to be able to
track compliance and compute benefits. Followups are needed by the
regulators to ensure that the BMPs are implemented.
WATER BODIES POSSIBILITIES FOR PILOT TRADING;
Simplicity
Lakes phosphorus.
Lakes that have a history of good data.
Existing infrastructure.
Point source.
Nonpoint source.
Impaired.
Smaller watershed (+) or (-).
Historical data.
Willingness to proceed (decision that all this will be presented to the large
group by one member of each subgroup).
SUBGROUP 3 Discussion
COST/BENEFIT
Barrier:
Identifying specific water quality problems
Solutions:
Inventory current point and nonpoint source pollution Who: sources;
States/basin management.
Identify control strategies.
Quantify costs of control for each Who: consortium of sources.
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Quantify nutrient (pollutant) reduction Who: consortium; State/regulators.
Quantify/qualify ancillary benefits and control methods Who: consortium.
Develop matrix of comparative costs/benefits Who: consortium;
State/regulators.
Offer matrix to point sources (Menu) Who: State/EPA approval.
Track effectiveness of costs/improvements Who: consortium;
State/regulators.
CONCERNS
Is this conference giving us just another watershed planning guide? Is this any
different from what we've done in the past? What's new?
We have new people and groups involved this time.
EPA is taking new approach here; now concentrating on watershed and
targeting solutions.
Focusing on point source and nonpoint source now rather just point source.
New Source of funding.
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BREAKOUT GROUP IV DISCUSSION
GROUP MEMBERS:
Ron McCormick, facilitator
Steve Bugbee
Mahesh Podar
Daniel Palmer
Donald Brady
Allison Taylor
James Gardner
Margie Carriger
Jim Meek
Karen Fidler
James Shell, Jr.
Corbin Darling
Loreen Robinson
Linda Hubbard
Bill Griffith
James Jones
Roland Geddes
Jim Turner '
Tom Augspurger
Worst Outcomes
i Hurt the profit of the farmer.
I Poor communication .
i Problem that isn't solvable.
i Substituting trade for direct involvement.
Trading that might result in a degradation of water quality.
Miss practical solutions.
Innovative idea that does not fly.
Opportunity lost.
Localized water quality impacts being traded off so that overall degradation
increases.
Local regulations not capturing local concerns.
People from different institutions not being able to think without
institutional barriers.
Premature criticism before anything is done.
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Best Outcomes
Let the flowers bloom.
Identify overall objective. !
Realization of many sources of degradation.
EPA provide adequate resources both financial and manpower to help
it along:
Farmers be included.
Provide momentum for non-command and control program.
Learn from each other.
Advantages and Limitations
What is the best choice? Trading becomes the acceptable tool to meet State
and local goals.
Meet water quality objectives at cost-saving approach.
Concrete ways to let the flower bloom.
Getting agricultural community and other nonpoint source people plugged
in.
n Make wise decisions; come up with better ways to measure nonp'oint source
pollution progress.
Products
List of factors barriers/opportunities recommendations for supporting
activities.
Action plans.
List of pilot waterbodies.
Barriers and Opportunities
Brainstorm List
BARRIERS;
Perception of increased workload for programs.
Lack of accurate predictive models.
Demonstrated ability to show results to the public.
Lack of sensitive monitoring data and interpretation to public.
Narrow limits, enforcement, and legislative barriers.
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In the absence of TMDL, permit must achieve water quality standards
without mechanism for enforcing nonpoint source controls under CWA.
Insufficient financial resources.
Making process too complex and considering it an art.
Liability to point source industry; lack of incentive for point source to pay
the bill; amend Clean Water Act to allow equitable distribution of cost-
both nonpoint and point.
Coordinate across State laws.
Inadequate technical assistance/BMPs in place farmers can support.
Enhanced difficulty hi determining compliance.
Lack of data; impact on the land; system to manage it; money to buy and
use system. J y
m Lack of resources to manage personnel and money.
History is a barrier/we may not need a nationally managed program but to
encourage local projects such as Pamlico; think small as well as big.
Lack of trust by people being regulated.
Determining cause and effect.
Not addressing agronomic practices.
OPPORTUNITIES;
Enabling legislation to get the nonpoint sources on board.
Who contributes/ diminishing returns on point source controls.
Flexibility to State and local governments.
Focus on watershed/basin approach.
Potential for win-win for nonpoint and point sources.
Flexibility for industry.
Address all sources.
Opportunity for equitable solutions.
Coalition builder bottom-up.
Added benefit of soil and water conservation.
Increase of habitat conservation.
Historic inability to conserve water quality; now it is time to try something
new trading is a new approach.
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SUBGROUP 1 Discussion
TECHNICAL/SCIENTIFIC BARRIERS;
Lack of monitoring data on which to make trading decisions and drive
models.
B Lack of predictive models to demonstrate cause and effect relationships.
B BMPs must be locally tailored to be effective.
B Needs GIS system/data tracking system.
OPPORTUNITIES
B Budget should include price of education of system.
B Better localized models (watershed models) calibrated with local data.
B Research is needed (local universities).
B Model needs to consider all elements.
B Watershed-specific modeling.
B Local agricultural extension people work on development of models.
SUBGROUP 2 Discussion
ADMINISTRATIVE;
B Promote nonpoint/point trading.
B Coordinate involvement across State lines; extent to which top-down
approach is taken will be the extent to which trading does not happen.
Federal government involvement is needed, so we can come to an agreement.
B EPA come up with framework to minimize barriers; top-down sipproach and
down-top approach balance; enforcement mechanism is needed to result in
improved water quality.
B Mechanism to make sure that trading does occur; increase controls.
SUBGROUP 3 Discussion
RESOURCES;
B Lack of trust in community.
B Framework to work a system.
B Expertise from EPA and State.
B Public acceptance and involvement.
B Unrealistic expectations.
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Federal presence that needs to back off later.
Federal role to be a catalyst for cooperative effort.
EPA and State level contacts where information can be retrieved.
COMMON TERMS FOR ALL GROUPS;
Framework.
Minimum requirements.
EPA guidelines.
Facilitator.
Enabler.
EPA catalyst.
Technical assistance.
MEETING OF BOTTOM UP AND TOP DOWN:
Pilot suggestions.
Potomac river basin.
3 States involvement.
40% nutrient reduction.
Disadvantage large complex system.
Susquehana River Basin.
James River Basin.
Chesapeake Bay.
Transparencies.
Rearrange order.
Administrative.
Technical/scientific resource.
ADMINISTRATIVE;
EPA should develop framework to facilitate trading, minimize potential barriers
such as '
compromise of enforcement authority to achieve load reductions,
interstate differences in WQ management programs, and
inflexible command control approach.
Need to find a balance between:
Trading achieved through local and State initiative with minimal Federal
role. The greater the Federal role, the less trading.
EPA obligated to ensure WQS achieved: minimum requirements, oversee
implementation.
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TECHNICAL/SCIENTIFIC ISSUES;
I
Monitoring systems and data:
Need intensive upfront basin specific monitoring.
Land use data for all sources.
Postimplementation monitoring.
Establish accurate cause and effect relationships.
Develop model linkages.
Watershed-specific models.
Calibrate with local conditions.
Adapt BMPs to local conditions.
Research at the local level.
RESOURCES THEME;
To encourage local/State to work with EPA to create a level of e:q?ertise.
Develop framework to promote and guide trading.
FRAMEWORK
Initial red role as a catalyst and resource.
Need for education of regulated community and public at large for
acceptance of trading. ,
Continuing level of expertise and resources local/State/Federal.
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BREAKOUT GROUP V DISCUSSION
GROUP MEMBERS:
Bruce Pewitt, facilitator
Cynthia Dougherty
Carol Ann Siciliano
John Veil
Everett Zillinger
Stuart Freudberg
Maryann Gerber
David Smith
Sharon Bailey
Les Mahagan
Jeannine Kenny
Don Blackburn
Frank Humenik
Ray Palmquist
Randy Dodd
Callie Childress
Randy Kramer
A.T. Rolan
Doug Rader
Terry Hammond
Best and Worst Outcomes
Best outcome would focus on trading; Worst would polarize the group.
Best would be that trading would be useful; Worst would be to think trading
not useful at all.
Best would accomplish objectives and gain national perspective; Worst
would not accomplish anything.
Best would be an open, honest discussion; Worst would be to not be open.
Best would understand how trading applies to nonpoint; Worst would limit
trading to nontoxic pollution.
Best outcomes would apply to permits, e.g., learning how to apply in
DC/Metro area and for nonpoint and point source programs; Worst would be
excessive impediments to implementation.
Best would be to learn how to address all pollutant sources; Worst would be
not to agree.
Best would be increased understanding of requirements to make trading
work, understanding obstacles, and overcoming them; Worst would be to
lose this opportunity to make it work.
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Best would be to learn nutrient training and get perspective of different
agencies represented; Worst would be no accomplishment.
Best would be not to lead to more litigation, find solutions that everyone can
buy into eventually; Worst would be to leave here polarized, discouraged.
Best would be to identify barriers; Worst would be no accomplishment.
Best would be to identify barriers (e.g., laws, institutions, cultural
drawbacks), promote ecological approach to watershed management; Worst
would be not to succeed at this task.
Best would use trading as catalyst for wetlands protection;
Worst would be ...
Best would be to stick to management approach instead of permit approach;
Worst would be not to give trading time to work before introducing national
legislation.
Best would be to learn from air quality trading lessons.
Best would be to find practical solutions; worst would be if third party
objects to procedures. '.
Barriers and Opportunities
Brainstorm List
Barriers (B): lack of trust between regulators, point and nonpoimt source dis-
chargers. (1)
Opportunity (O): nonpoint sources include more than agriculture (i.e., water). (5)
Downstream doesn't want to contribute to upstream costs. (3) (B)
Ensuring accountability, assuring that nonpoint source controls work. (8) (B)
Liability if controls don't work, need public support, balance between
monitoring and modeling. (6) (B)
Lack of information and good information on which programs were
successful and which were not. (5) (B)
B Farmers don't have incentive to control (gains from trading are unclear). (1)
(B)
Equity; asking nonregulated agencies to work with regulated agencies, cost
share assist may not fully fund BMPs. (3) (B)
Better document/study nonpoint source problem. (1) (O)
Best Management Practices (BMP) are extremely costly (1 million per farm)
and farmers can't afford it. (1) (B)
Increases money for BMP implementation. (9) (O) :
Assume that trading works to reduce nutrient loads. (B)
Uncertainty over loads reduction and difficulty in showing water quality
effect. (B)
Achieve real improvements in reducing loads of other pollutants (i.e.,
sediments, pathogens, fecal). (5) (O)
Difficulty in identifying impacted area. (B)
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Hard to design monitoring program for nonpoint sources. (B)
Opportunity to build trust between parties represented here, develop more
innovative solutions, enhance creativity. (O)
Administrative difficulties in managing these BMPs. (B)
Cost. (B)
Multiple agencies. (B)
Not enough point source discharges to buy meaningful levels of reduction. (B)
If it is toxics you are trying to eliminate, trading won't be very helpful.
Poor understanding of natural sources. (1) (B)
Avoid improper transfer (i.e., ground water and surface water). (B)
Look at total water resource. (8) (O)
Air sources contribute to water pollutants, possible air water trading. (1) (O)
Save money. (8) (O)
Bring people together to address common concerns/empowering people (6)
(O)
Pollutant transport and trading. (3) (O)
Evaluate possible nonpoint to nonpoint trading. (3) (O)
Influence authorization. (O)
Possible local "hot spots". (B)
Nonpoint sources/nonpoint source trades difficult. (B)
SUBGROUP 1 Discussion
BARRIER Lack of Good Information/Documentation
Source identifications (actors: dischargers, State, EPA, city, County, USGS,
agricultural agencies, watershed groups)
BMP effectiveness (actors: agricultural agencies, agribusiness, government)
Document existing nonpoint source Controls (actors: program participants,
Federal/State/local agencies)
SOLUTIONS
Improve:
monitoring/remote sensing
data analysis
modeling
demonstration projects
allow time for BMP to work/fail
collect information on BMP effectiveness from other States
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Monitor:
individual trades for effectiveness
load reductions
reductions in other pollutants
surface/ground water effects
operation & maintenance
SUBGROUP 2 Discussion
OPPORTUNITY Look Holistically at Entire Watershed
Characterize ecological resources and stresses in watershed
AG/rural
air
urban
natural
Model/determine pollutant fate/transport
Evaluate alternative trading models :
SOLUTIONS
Collect and evaluate information on watershed basis (actors: Staite, EPA,
USDA, USGS)
Develop a system of integrating data bases
D Upstream, downstream data) (GIS?)
Develop/validate watershed model
m Standardization and ease of database query/retrieval
Capability (user friendly)
Group asks: "Is this effort really worth it? Is trading going to be cost effective?"
SUBGROUP 3 Discussion
ISSUES
Are trading programs viable?
pilot projects (Federal funding)
criteria (EPA and States)
identify sites
consider other trading partners
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Acountability
how to write permits (place dual limits in permit) point source is
responsible for accountability
Third-party contractors to implement
Trust
coalition
GROUP OBSERVATIONS
Group needs to be more frank about issues and practicality (i.e., if
management wants to know what group really thinks, why didn't it ask the
question, "Is trading worth it?").
If this program is for real, it's going to be a long-term commitment. . .
trading is not necessarily the end-all answer but could be a useful tool to get
to where we want to be.
A five to ten year pilot is necessary to really show results (want budget to
come from Congress)
Don't need to rewrite Clean Water Act to include trading across the board . .
don't want to mess with the law.
Do we want to move toward a watershed approach and then decide whether
trading is right for that watershed?
Do we fear the technical tasks involved in a watershed approach?
FINAL PRESENTATION
It's a huge job . . . need lots of data, money, time
Keep exciting initiatives going
doBMPswork?
encourage States to address water quality problems
Coordinate between Federal agencies . . . need to start working together to
gather data
Encourage coalition building
MAJOR POINTS
Trading is only a tool, not an end in itself, to improve the effectiveness of
water quality programs.
Will trading work?
assess through pilot project (Start in 5 pilot projects that need
Federal funding)
Requires long-term commitment.
Coalition building should be emphasized.
Better interagency coordination is needed (e.g., information collection and
sharing).
Accountability will be key (e.g., does participant actually do BMP and was
BMP effective?).
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BREAKOUT GROUP VI DISCUSSION
GROUP MEMBERS
Cindy Ricks, facilitator
Sandy Germann
Lynn Parseghian
Mitch Dubensky
John Hall
Marcella Jansen
Ellen Siegler
Adrian Freund
Carlton Haywood
Bruce Zander
Christopher Novak
Amy King
Christine Wallace
John Baker
Julie Rome
Cam Wheeler
Anne Coan
Best and Worse Outcomes
WORST
People won't listen to each other; disjointed thought; won't clarify; people
will posture and be narrow in their approach; egos will interfere.
No focused recommendations to EPA.
We won't focus on the problem in our discussions.
Some historic antagonisms between groups represented here may block the
opportunities for success.
Lack of focus; inability to reach consensus.
Not be able to frame issues.
Personal fear not be able to understand trading concept.
Freeze to death.
That we make bad assumptions about what the nonpoint source problems
really are. Then we'll be worse off 10 years from now.
Conclude that there is no future for trading.
People will be turned off by the unanswered questions.
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Prematurely conclude that trading does not have substantial promise/role in
water management programs of the future.
That no conclusions are reached; therefore, we'll have no story to tell.
That we don't come up with innovative approaches. i
That we wouldn't realize trading's potential.
BEST
Everyone would express their opinions freely.
State all opinions, complete brainstorming today.
Recognition that point source and nonpoint source differ.
That our group will contribute to the atmosphere and opportunity for
continuing dialogue.
Take one step forward in answering some of the questions.
Increase understanding.
Identify one or two significant issues.
That this group's outcome will serve as an inspiration to a watershed to
undertake trading.
Intelligent, rational discussion.
Better understanding of trading so can take advantage of opportunities.
Identify opportunities and barriers.
Barriers and Opportunities
Brainstorm List
Level playing field regulatory/technological baseline for point and
nonpoint source trading.
Equal responsibility: quid pro quo responsibility for both point and nonpoint
sources prior to starting a trading program.
Lack of information on the water quality impact of some BMPs.
Water quality issues are usually multifaceted cross-pollutant; trading
needs to deal with trading between multiple pollutants and multiple water
quality objectives.
Enforcement and liability need to be addressed: if one party fails! to abide by
the trading agreement, how do you enforce? Accountability.
Point source may think that nonpoint sources are being treated differently
(fairness).
Perception that prohibition on growth or economic activity may occur.
B Trading program needs to be integrated with other regulatory programs.
Old vs. new growth barriers, a trust issue.
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Define private sector.
Need to understand all the facets of nonpoint source.
To allow growth and maintain water quality.
Identification of nonpoint sources.
What is the measure of compliance by nonpoint source: what parameters do
you use to determine effectiveness.
Administer on local level.
Opportunity to explore performance-based compliance rather than
parameter-based.
Watershed basis.
I Develop defensible trading ratio.
i Double-jeopardy for point source: may buy nonpoint source credit but a year
later still have to put in tertiary treatment.
I No incentive for new control technologies is EPA considering movement
away from technology-based requirements?
i How are States going to be able to issue permits that on their face do not
meet water quality standards therefore, a statutory barrier.
i Practical vs. legal requirements of CWA: baseline requirements may be a
barrier because minimum requirements have already been published
practice (nonpoint source) vs. baseline requirement (point source).
current trading schemes require technology.
i Trust among the parties is an opportunity.
i Getting people to buy into uncertainty.
i Limited resources (State, local, Federal).
i Timeframe: nonpoint source approach needs more time to meet water
quality standards than point source farming practices take more time to
produce results.
The possibility to target limited-resource farmers that might not be able to
afford implementing needed practices.
Target water quality problems/contributors.
Organize nonpoint source interests.
Trading examples could serve as catalyst to go further in addressing
nonpoint source in general.
Urban nonpoint sources need to be involved must determine who the
stakeholders are.
Need to define private sector interests.
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SUBGROUP 1 Discussion
LEGAL CONSIDERATIONS
Regulatory baseline requirements to enable trading (level playing field)
Examine whether nonpoint source baseline should be prerequisite
to trading.
Should common terminology for point source/nonpoint source
control requirements be established? Performance or technology
based? (Examine)
Examine how to establish equivalency between PS and NPS (what
are trading ratios?)
Should additional point source requirements be deferred in lieu of
more stringent nonpoint source requirements? ;
Examine role of stormwater permitting and relationship to PS/NPS
baseline.
Point/nonpoint source enforcement issues (responsibility of each discharger)
Is point source liable if nonpoint source fails to perform
i. Is Clean Water Act change needed?
ii. Can (should) individual landowners be held liable?
Examine monitoring, reporting, and data management necessary to
evaluate nonpoint spurce compliance?
Can different point source/nonpoint source compliance schedules be
allowed?
What form of permitting/contract should be used to enforce
nonpoint source commitments?
Role of point source/nonpoint source stakeholders when technology/water
quality standards improve/tighten.
Examine ways to equalize responsibility of point source/nonpoint
source. !
How to prevent new BAT from deterring point source participation
in trading?
How to issue point source permits that do not (by themselves) meet
water quality standards?
EPA should examine barriers in Clean Water Act.
Are regions approaching permits consistently?
Examine barriers to cross-pollutant trading.
Evaluate incentives for resource restoration/enhancement
(pollutant to wetland trading).
What rules are needed to establish trading regions?
How can consistency be encouraged?
How to address fairness re: inclusion of new stakeholders
(dischargers).
Define area large enough to provide trading opportunities but small
enough to verify water quality benefits.
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SUBGROUP 2 Discussion
ADMINISTRATIVE. POLICY. AND ECONOMIC
CONSIDERATIONS
Trading should continue to be explored as a possible policy option.
Encourage the establishment of technical assistance and cost-sharing
programs for NFS water quality improvement.
Direct funding efforts to nonpoint sources.
research into BMPs development and effectiveness
research into relative contributions of different types of activities
develop models for establishing defensible trading ratios
EPA needs to develop a guidance framework that tells States or smaller
units to describe in their program how they will handle the following:
How to quantify NFS contributions and reductions vs. the currently
more quantifiable point source contributions and reductions.
Integrate the many programs into the whole trading scheme.
BMPs, wetlands protection, and CZMA to simplify and coordinate
implementation.
Develop methods to monitor compliance with the contract
provisions and identify enforcement mechanism for noncompliance
with the contract. Who is liable for noncompliance must be
identified.
i. Who will enforce noncompliance?
ii. Develop a penalty structure and framework that is commensurate
with the violation.
Encourage local involvement and as much local administration as
possible. Resources to these local administrative units are needed.
Encourage innovative ways to get those dollars. Adequate technical
assistance needs to be met.
SUBGROUP 3 Discussion
EDUCATION AND PUBLIC POLICY
Barriers reviewed as opportunities
Local involvement
Economic development
Equity responsibility is not evenly distributed. This remains a
barrier.
Action plans
Legislation: identification of explicit legal barriers to the concept of
trading and attempt to modify laws. Involve the EPA.
Policy: seek strong policy statements from EPA that endorse
concept of trading.
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Education: educate the public as a whole by publishing success
cases to illustrate the flexibility of trading schemes, importance of
involving stakeholders early in the process, education for
interaction.
Public Policy:
i. EPA and States providing seed money and technical assistance.
ii. Get the government involved, announce grants.
iii. Public participation is a key element using a network of
communications on all levels (public meetings, committees).
SUBGROUP 4 Discussion
TECHNICAL CONSIDERATIONS
Lack of quantifiable information on BMPs
Need to measure actual nutrient production
How: Develop methods
Who: States, EPA, USDA, Land Grant Universities
Need cost information
How: Develop a database from existing sources
Who: States, EPA, USDA, Land Grant Universities
Need for priorities among NFS contributions
How: Through modeling
Who: States, EPA, USDA, Land Grant Universities
Need more information on effectiveness of BMPs
How: Field demonstrations
Who: States, EPA, Forest Service, and agricultural services
Develop method for determining the baseline (TMDL) for watershed.
Measure/model background conditions
Determine role of natural landscape
Determine role of natural processes and landscape (hydrology,
climate, geology)
Who: State environmental agencies
Develop method to determine success in terms of water quality
improvements (ecological, chemical, and physical).
Who: State environmental agencies
Develop technically defensible trade ratios to meet water quality objectives
Who: State agencies with technical guidance from the EPA
How: using information gathered in II.
EPA needs to develop a technical guidance manual
Phased approaches (maybe, maybe not)
In future, address trading between water quality objectives and, between
parameters.
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