«January 2012 SENIOR SCIENTISTS AND POLICYMAKERS FOR THE BAY NUTRIENT TRADING SUBCOMMITTEE Nutrient Trading Preliminary Investigation: Findings and ...»
Environmental justice principles reveal that those economically disadvantaged already suffer lopsided consequences of onerous environmental practices. Allowing these practices to continue unabated by allowing perpetrators to pay fees to credit marketers or aggregators elsewhere only perpetuates an existing disparity and provides a 7 | www.bayactionplan.com marketplace that sanctions disparity for economic gain. Communities suffering the impact of onerous environmental problems should share, as a matter of equity, the economic and ecological benefits of the regulatory activity that seeks to address those impairments.
If any compounds beyond nutrients and sediments are considered for trading (e.g., toxins, endocrine disrupters), serious consideration of the environmental justice issues will need to be made.
7) TRADING COULD BENEFIT LARGE ORGANIZATIONS AND
CORPORATIONS WITHOUT PROTECTING THE INTERESTS OF LOCAL
WATERWAYS AND GRASSROOTS ENTITIES.
8) THE TOTAL IMPACTS OF NUTRIENT TRADES NEED TO BE
MEASURED AND ADEQUATE COMPENSATION PROVIDED.
Various development activities may have multiple impacts that transcend the impacts from nutrients and sediments. For example, even though the construction of wastewater treatment facilities can vastly reduce nutrient pollution (e.g. septic to small WWTP), www.bayactionplan.com | 8 nonetheless this still creates impacts (e.g., loss of riparian vegetation, increased impervious surfaces with associated runoff) that can lead to deleterious impacts. These multiple impacts provide another reason to have adequate compensation ratios. Some Best Management Practices have highly variable application efficiencies which lead to divergent nutrient results and nutrient credits need to reflect the actual nutrient savings.
For example, transport of animal manure can be highly variable and difficult to assign credit. The length of time and conditions that animal manure is stored and the distance that it is transported will affect the nutrient removal efficiency. In Pennsylvania, credits appear to be provided inversely to the logical agronomic use and practices that were the worst are given more credit, i.e. if an agricultural operation previously incorporated manure within two days to maximize nutrient efficiency they receive fewer credits for manure export than an operation that allowed manure to sit in the field and release nutrients to the environment. Also, manure transport does not properly account for ammonia volatilization rates, potential for redeposition within the Chesapeake Watershed, or the nitrogen emissions from the vehicles transporting the manure. A more rigorous mass-balance approach must be used when crediting all practices.
9. CREDITED PRACTICES AND THE AMOUNTS OF CREDITS AWARDEDNEED TO BE STANDARDIZED.
Discrepancies in the amount of credits awarded for different practices can lead to inequities across jurisdictional boundaries. Non-point source practices are particularly difficult to standardize (see recent PennFuture report) and highly variable crediting can undermine the nutrient trading program. The standardization, like the verification process, needs to be conducted by independent, third parties in a scientifically rigorous manner. This standardization of nutrient credits should not curtail innovation and creativity of nutrient reduction practices.
10: “GROWTH ALLOCATIONS” REPRESENT AN UNMITIGATED
GIVEAWAY OF POLLUTION AND SHOULD BE ELIMINATED OR,
RECOGNIZING THE POLITICAL DIFFICULTY IN WITHDRAWING AN
ALLOCATION PREVIOUSLY AWARDED, SEVERELY CURTAILED.
In order for a market system to function effectively, a firm pollution cap needs to be put in place, and growth allocations effectively extend that cap date well into the future, harming the development of the market. The granting of extra pollution capacity to wastewater treatment plants should be based on demonstrated pollution reductions in other sectors, and should not be granted on speculative, proposed reductions in those sectors.