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Comment on EPA national trading policy

From Clean Water Network

The Network has been working to ensure that EPA’s new trading policy will lead to real water quality improvements and will not undermine existing Clean Water Act programs.  Now we need you to submit comments to get your experiences with water pollution trading into EPA’s docket!

EPA’s Water Quality Trading Guidance

Tracy Mehan, EPA Assistant Administrator of the Office of Water, has identified water quality trading as one of his highest priorities.  EPA is now moving ahead with their plans to issue guidance on water pollution trading despite serious reservations from many in the environmental community.  On May 15 EPA released a draft of the Agency’s water pollution trading guidance for public comment (go to: Network members have closely monitored EPA’s progress and this April, 34

Network members submitted a letter to the Agency identifying substantive problems with EPA’s approach.  The letter identifies specific safeguards that any trading scheme must include if it is to lead to real water quality improvements.  None of these safeguards were incorporated into the Agency’s subsequent draft that was released for public comment. Nancy Stoner of NRDC and a group of CWN members are preparing additional comments, which will be circulated to Network members for submission by the July 1 deadline. However, EPA seems to be listening to industry and agricultural interests, instead of protecting the environment.  The water pollution trading guidance, as proposed by the Agency so far, has a lot of nice rhetoric, but lacks the protections necessary to ensure that trading isn’t another "innovative initiative" to skirt the Clean Water Act.

Do you have a trading program on your watershed?  If you do, or you have experience with a trading scheme, we want EPA to hear from you directly.  You can comments on this proposal by sending three copies to:

W-02-07 Comment Clerk, Water Docket (MC4101), EPA, 1200 Pennsylvania Avenue, NW, Washington, DC 20460. Comments may also be submitted electronically to Electronic comments must be submitted as an ASCII, WP5.1, WP6.1 or WP8 file. Please send the Network a copy of your comments as well!

 Congressional Hearing on Water Quality Trading

On June 13 the House Subcommittee on Water Resources and Environment held a hearing on EPA’s trading plan.  Subcommittee Chairman Duncan (R-TN) expressed his enthusiastic support for trading and regulatory flexibility in general.  Representatives DeFazio (D-OR), Blumenauer (D-OR), and Gilchrist (R-MD) were all more cautious in their statements, expressing concern about trading toxics and the creation of hotspots. The first panel consisted of EPA and USDA.  The second panel was heavily stacked in favor of trading with state, industry and farming witnesses expressing their strong support for the guidance.  Rena Steinzor, Center for Progressive Regulation, challenged their view with recommendations that EPA: focus on control of nutrients by fostering exchanges between point and non-point sources; include an appropriately low, and steadily declining, "cap" on total discharges; rely on accurate methods for measuring emissions, awarding allowances, and reconciling the number of allocated allowances with subsequent trades; prevent the formation of local "hot spots;" involve the public in the setting of caps and the operation of the program; and rest the program on a foundation of enforceable commitments.

For more information contact Eddie Scher at or 202-289-2395.

This information is posted for nonprofit educational purposes, in accordance with U.S. Code Title 17, Chapter 1,Sec. 107 copyright laws.

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