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NMPF Signs on to ANPC, Newtrient Water Quality Trading Comments

January 7, 2020

NMPF signed on to comments with the Agriculture Nutrient Policy Coalition and wrote a letter of support for Newtrient’s comments, which were submitted to the water quality trading docket December 18. The comments detailed support for Water Quality Trading as an important tool for water quality improvement in the United States.

NMPF 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.” NMPF has also been involved with Maryland’s effort to launch a water quality trading program and Pennsylvania’s water-quality procurement legislation.

In November, Clay Detlefsen, NMPF’s senior vice president for regulatory affairs, provided oral comments stating its strong support for the Environmental Protection Agency’s (EPA) 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‘s efforts this year to update its water quality trading policy to  encourage technologies and practices that reduce nonpoint source pollution.  NMPF also concurred with the six principles 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; and
  • Encouraging simplicity and flexibility in implementing baseline concepts