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Dairy Industry Dominates Discussion at EPA Public Meeting on Advancing Water Quality Trading

November 13, 2019

An EPA meeting on water-quality trading Oct. 21 received a heavy dose of dairy’s strong support for National Milk on market-based solutions to environmental challenges. NMPF regulatory chief Clay Detlefsen was joined by Steve Rowe, president and CEO of Newtrient, and Bruce Knight, principal and founder of Strategic Solutions, all testified about dairy’s support of EPA’s efforts to create a demand for water quality trading programs

National Milk has a long history of supporting water quality trading, serving on the steering committee of the National Network on Water Quality Trading that published “Building a Water Quality Trading Program: Options and Considerations” and “Breaking Down Barriers: Priority Actions for Advancing Water Quality Trading.” National Milk has also been involved with Maryland’s effort to launch a water quality trading program and Pennsylvania water-quality procurement legislation.

At the meeting, NMPF stated its strong support for EPA’s efforts to promote water quality improvements at a lower cost than traditional regulatory approaches, agreeing with EPA that the Clean Water Act allows for pollutant reductions from water quality trading to achieve compliance with regulatory requirements.

Detlefsen also said NMPF appreciated EPA for its efforts this year to update their water quality trading policy to encourage technologies and practices that reduce nonpoint source pollution.  NMPF also concurred with the six principals laid out in the 2019 Memorandum, namely:

  • States, tribes and stakeholders should consider implementing water quality trading and other market-based programs on a watershed scale.
  • EPA encourages the use of adaptive strategies for implementing market-based programs.
  • Water quality credits and offsets may be banked for future use.
  • A single project may generate credits for multiple markets.
  • Financing opportunities exist to assist with deployment of nonpoint land use practices.
  • Encouraging simplicity and flexibility in implementing baseline concepts

National Milk will submit written comments to more fully address the issues and questions raised in the meeting’s Federal Register notice.