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Fox P Trade Advisory Group Webinar:
Water quality trading in WPDES permits: applications in the Lower Fox River TMDL
Watershed, Wisconsin.
September 28, 2016
1
Project Status
Task Title
1 Develop Workplan and Project WQ Goal
2 Convene Stakeholders
3 Feasibility: Supply
Feasibility:Demand
Feasibility: Market Survey
4 Hypothetical Trade Scenarios
5 Design: Articulate Goal
Design: Quantification Methods
Design: Manage Risk
Design: Program Administration
Design: Guidance Document
6 Pilot Design (as resources allow)
7 Lessons Learned
Fox P Trade -- Total Project: 42 months -- 3/1/13 - 9/30/16Year 1 (2013) Year 2 (2014) Year 3 (2015) Year 4 (2016)
Hypothetical and Pilot Trades
• Water Quality Trading Packets submitted to Mike Hammers for mock WDNR review and permit adjustment
• Testing completeness of documents.
• Testing review process (and timing)
• Assessing the assumptions of modeling and credit calculation for trades
Hypothetical and Pilot Trades
Hypothetical Trade
• Trading Contract Created– Provisions of interest to
seller/farmer– Provisions of interest to
Buyer/permittee
• Credit Certification Report– Summarizes technical details of
practices, load reductions and credit generation
• Existing WDNR documents– Notice of Intent– Checklist– WQT Plan
Pilot Stewardship Trade
• Land ownership/deed implications
• Credit timing— “effective date”
• Annual vs “permanent” or longer term practices
• Separate Verification Services Agreement
Final Products and Outreach
• Water Quality Trading Hypothetical (and Pilot) Application Packets
– WDNR review process
– Documentation
• Lower Fox WQT Handbook
• Fox P Trade Website (foxptrade.org)
• Lessons Learned
Mike Hammers [email protected]
Experience
• 35 years with Wisconsin DNR
• Drafted WPDES permits for industrial facilities
• Reviewed plans for industrial WW treatment systems
• Coauthored guidance for implementing TMDL WLAs,Phosphorus WQBELs and WQT in WPDES permits
• Statewide WQT coordinator
Location Contacts Contact Information
Northern DistrictHayward Service Center
Lonn Franson [email protected]
Eastern DistrictOshkosh Service Center
Keith Marquardt [email protected]
Southern DistrictFitchburg Service Center
Amy Garbe
Mark RiedelMilwaukee Basin
Western DistrictEau Claire Service CenterCentral Office
Mike Vollrath
Ann HirekaturWisconsin River
Statewide CoordinatorsCentral Office
Amanda MinksPoint Source
Kevin KirschModeling
Andrew CraigNonpoint Source
• Overview of Fox P Trade Water Quality Trades
• Hypothetical Trade – City of Appleton
• Pilot Trade – NEW Water
• WQT Plan Review Process
• Notice of Intent
• WQT Plan
• WQT in WPDES Permits
City of Appleton – “Hypothetical Trade”
NEW Water - “Pilot Trade”
Year 1 Year 2 Year 3 Year 4 Year 5
Phosphorus Credits (lbs/year) 1,085 824 1,138 1,092 1,199
Management Practices – NMP, Mulch and No Till, Cover Crops, Filter Stripsand Grassed Waterway
Number of Fields – 75
Total Number of Acres – 2,462
Year 1 Year 2 Year 3 Year 4 Year 5
Phosphorus Credits (lbs/year) 33 44 54 20 25
Management Practices – NMP, No Till, Cover Crops, and Conservation Cover
Number of Fields – 3
Total Number of Acres – 66.4
City of Appleton – WPDES Permit Public Noticed 8/1/2016
NEW Water - Current WPDES Permit
Averaging PeriodTP WQBELs
(lbs/day)Current TP Discharge
(2011 through 2015)
Monthly Average 79.5 0 of 60 > Mo. Avg. Limit
6-Month Average 26.5 9 of 10 > 6-Mo. Avg. Limit
Averaging PeriodTP WQBELs
(lbs/day)Current TP Discharge
(2011 through 2015)
Monthly Average 203 1 of 60 > Mo. Avg. Limit
6-Month Average 68 9 of 10 > 6-Mo. Avg. Limit
City of Appleton - WPDES Permit Public Noticed 8/1/2016
NEW Water - Current WPDES Permit
Compliance Schedule Required Action Due Date
Facility PlanNotice of Intent
12/31/2018
Construction Plans and SpecificationsWQT Plan
12/31/2019
TP WQBELs become Effective 1/1/2021
Compliance Schedule Required Action Due Date
Final Compliance Alternatives Plan(Notice of Intent)
12/31/2018
Final Compliance Alternatives Plan(WQT Plan)
6/30/2020
TP WQBELs become Effective 7/1/2023
WQT Review Process
• Is the Notice of Intent complete?
• Projected date credits are available
• Version of SnapPlus
• NRCS Conservation Practice Standard
• Is WQT feasible?
NOI Response Letter Content
• Confirm compliance schedule requirement met
• Remind permittee of deadline for next required action
• Special instructions for WQT plan submittal
• Information needed with trade ratios
• Plan format
• Enclosures
• WQT plan content list
• Using P Trade Report from SnapPlus
• O&M plan requirements for specific management practices
• Approved Nutrient Management Plan (NMP) for entirefarm
• Documentation of soil nutrient level trends
•Cropping history, or
•Soil testing
• Points of standard application
• Base loadings and credit threshold
• Interim credit duration
Description and Location of Sites where Credits Will be Generated
Location(s) Where Credits will be Generated Provide the location of each site or field (tax parcel is acceptable, identifying a farm is optional); Describe or provide a map showing the proximity of the sites/fields to the applicant and applicant’s receiving water. Note whether
the location of any site or field is downstream from the applicant’s discharge.
Include a map or aerial photo each site or field where management practices will be applied. Include major drainage ways, overlays of HUC 12 sub-watershed boundaries, site or field outlines, nearest waterway, direction of flow from site or field to waterway and proximity to applicant and applicant’s receiving water.
Provide a description of existing land uses.
Methods for Reducing Nonpoint Source Loadings
Methods Used to Generate Load Reductions Describe methods/management practices used at each field or site to reduce loadings to surface waters of the traded parameter. Provide the design life of each practice
A management practice description should include the NRCS Standard and all selections made when the Standard allows more than one option. Examples include the width of a filter strip and the identification plant species used for conservation cover should be included in the description.
History of Project Site(s)
Provide a minimum of three years of cropping and tillage history for each field used to generate credits. Sources such as dated photographs and application reports for loans or insurance are acceptable.
Identify the model(s) used to derive load reductions of the traded parameter.
Credit Threshold and Method for Derivation
Describe how the credit threshold was obtained or derived. Credit thresholds may be farm-based, watershed-based or provided in the TMDL report for the watershed in which the credit user is located.
Provide an Operation and Maintenance Plan for each Management Practice
Derivation of WQT Credits
Explain the derivation of trade ratios used to determine credits (by year) for each field or site
Provide the amount of interim and long-term credits generated for each site field or site
List Headings (no. of subheadings if > 1)
•General Information (5)
• Water Quality Trade Background
• Description and Location of Sites where CreditsWill be Generated (2)
• Methods for Reducing Nonpoint Source Loadings (5)
• Derivation of WQT Credits (2)
• Trade Timeline (2)
• Inspections and Reporting (9)
• Certification (3)
• Other Items
Guidance Content
• Use SnapPlus P Trade Report (PTR) rather thanPhosphorus Index (PI)
• Include all farm fields in the database
• Use predominate soil type for PTR
• A minimum of 2 years of historical data are required
• Two PTRs are required, one with and one withoutmanagement practices
• Submit the SnapPlus databases along with PTRs
• Include updated PTRs in permit required annualWQT reports
Cover Crop Guidance Content
• Follow WI NRCS Conservation Practice Standard, Cover Crop (340) andWisconsin Agronomy Technical Note 7
• Provide approved nutrient management plan (590)• Document through a minimum of three years of historic cropping records
or soil testing that nutrient levels are stable or dropping• For each field generating credits:
• Indicate whether high groundwater or tile drainage is present;• Confirm that no gullies are present;• Identify selected cover crop plant species;• Specify cover crop seeding date;• Specify minimum seeding rate;• Indicate seeding method;• Provide a date when the cover crop will first be establishment;• Provide the criteria that will be used to verifying cover crop establishment;• Provide cover crop termination time and method; and• Provide a schedule for inspection and verification of each year's cover crop.
Description and Location of Sites where Credits Will be Generated
Location(s) Where Credits will be Generated Provide the location of each site or field (tax parcel is
acceptable, identifying a farm is optional); Describe or provide a map showing the proximity of the
sites/fields to the applicant and applicant’s receiving water. Note whether the location of any site or field is downstream from the applicant’s discharge.
Include a map or aerial photo of each site or field where management practices will be applied. Include major drainage ways, overlays of HUC 12 sub-watershed boundaries, site or field outlines, nearest waterway, direction of flow from site or field to waterway and proximity to applicant and applicant’s receiving water.
OK: Tax parcels provided in the WQT Plan and Credit Certification Report (CCR is WQT Plan's Appendix 2).
OK: A map of the Bob Van De Loo fields and NEW Water outfalls is provided in CCR's Location Map worksheet.
Maps of all fields are provided in CCR Location Map worksheet and Nutrient Management Plan (NMP is WQT Plan's Appendix 5), but: o Fields identified as Daves 1-2 and Nelson 1 in CCR and SnapPlus
databases are shown on CCR Location Map and NMP as Daves and Nelson;
o Waterways are identified in the NMP maps; o HUC 12 sub-watershed boundaries are not shown on the field maps; and o While the direction of runoff from fields is not shown, NMP maps show
field slopes.
Provide a description of existing land uses. OK: Paragraphs 5.2 and 5.3 of the WQT Plan provide a description of existing land uses.
Methods for Reducing Nonpoint Source Loadings
Methods Used to Generate Load Reductions Describe methods/management practices used at each field
or site to reduce loadings to surface waters of the traded parameter.
Provide the design life of each practice A management practice description should include the
NRCS Standard and all selections made when the Standard allows more than one option. Examples include the width of a filter strip and the identification plant species used for conservation cover should be included in the description.
OK: Overview provided in Executive Summary. Field location and periods of
application provided in CCR's Credit Breakout worksheet. OK: Design lives provided in CCR Credit Breakout worksheet. OK: NRCS Standard provided in Executive Summary and CCR's Credit
Breakout worksheet.
Note that the management practices specified by the WQT Plan include reducing the application of manure and planting small-grain grass with alfalfa in place of planting alfalfa alone. Both of these practices result in load reductions according to SnapPlus model runs. The WQT Plan assigns the NRCS Standard of Nutrient Management - 590 to both of these practices since there is no specific standard for planting grass with alfalfa.
The WQT Plan does not explain what happens to the manure that will not be land applied on the three fields used to generate credits. NEW Water's future WQT plan submittal should explain that the manure is not be shifted to other fields on the Bob Van De Loo farm or other farm in the Lower Fox River Basin.
Some Focal Points of My Review
• Demonstration of credits needed
• Cropping and tillage history
• Derivation of trade ratio
• Adequate detail in management practice O&M
• Inspection schedule
• Review SnapPlus databases
• Verify calculation of credits
• Soil testing schedule
• Verify WQT agreement/contract is in place
Field Name/Number
And tax parcel number(s)Acres
Crop and tillage information,
CP Name with NRCS Standard
Year 1
(2017)
Year 2
(2018)
Year 3
(2019)
Year 4
(2020)
Year 5
(2021)
Crop rotation
Current cropsCorn silage Corn silage Corn silage Oat-Pea Forage w/
Alfalfa Seeding
Spring
Alfalfa
Conservation cropsCorn silage to
small grain cover
crop
Corn silage to
small grain cover
crop
Corn silage to
small grain cover
crop
Oat-Pea Forage w/
Alfalfa/Grass
Seeding Spring
Alfalfa/Grass
Current tillage Fall Chisel, disked Fall Chisel, disked Fall Chisel, no disk Fall Chisel, no disk None
Conservation tillageSpring Cultivation,
cover crop no till
Spring Cultivation,
cover crop no till
Spring Cultivation,
cover crop no till
Spring Cultivation None
No Till / Residue Management -
329x x x
Cover Crop - 340 x x x
Nutrient Management - 590 x x x x
P Trade Report
Baseline pounds 123.00 122.00 133.32 55.44 41.99
Improved pounds 83.60 48.27 41.75 27.83 25.89
Difference 39.40 73.73 91.57 27.60 16.10
Uncertainty Factor 2.0 2.0 2.0 2.0 2.0
Delivery Factor
Downstream Factor
Equivalency Factor
Habitat Adj. Factor
Trade Ratio 2.0 2.0 2.0 2.0 2.0
Credits 19.70 36.86 45.79 13.80 8.05
Trade Ratio = UF+DeF+DoF+EF-HAF
Difference divided by Trade Ratio
Daves 1-2
130035901, 130024700,
130024900
36.4
A-[Rwf-Cs30]-Csl-Csl-Csl-OPfAs-A
Outputs of the SnapPlus P Trade Report
Baseline lbs - Improved lbs
Based on CP
June 23, 2016
Mr. Robert Kennedy, Operations Supr.
Appleton Wastewater Treatment Facility
2006 E. Newberry St.
Appleton, WI 54915
Subject: WDNR Review of Appleton WWTF Water Quality Trading Plan
WPDES Permit No. WI-0023221-08-0
Dear Mr. Kennedy:
On behalf of the Wisconsin Department of Natural Resources (the Departyment), I am pleased to inform you
that the Department finds the Acme Farm and Ash Apple Farm Water Quality Trading (WQT) Plans (WQT-
2016-0001H and WQT-2016-0002H) prepared by the Great Lakes Commission to be acceptable and consistent
with WQT rules and Department guidance. The WQT Plans and supplemental information were received via
email on April 18th and June 3
rd of 2016.
Based on Department review, the WQT Plans conform in general with Department Water Quality Trading
Guidance and s. 283.84, Wis. Stats. The reviewed plans indicate that Appleton WWTF will utilize WQT as a
compliance option through the use of six-year conservation practice rotations that include cover crops, mulch
tillage, no till and filter strips on a total of 2,462 acres. The WQT Plans propose to generate 1,085 pound of
phosphorus credits in 2017, 824 pounds in 2018, 1,138 pounds in 2019, 1,092 pounds in 2020 and 1,199 pounds
in 2021.
The Department conditionally accepts the Acme Farm and Ash Apple Farm WQT Plans as a basis for water
quality trading with the following comments:
1. That the approved WQT plans are followed;
2. That all conditions for the use of WQT contained in the reissued permit are met;
3. That a Management Practice Registration Form 3400-207 is submitted for each field when a
management practice is installed; and
4. That the WQT Plans will be updated and resubmitted to the WDNR for its review when fields and/or
practices are changed.
Note that the Department will consider all comments on the WQT Plans that it receives during the public
comment period for the reissuance of the Appleton WWTF WPDES permit and the informational hearing on the
WQT Plans. As a consequence, WQT conditions contained in the proposed permit reissuance and public
noticed may be changed prior to permit issuance. The Department will provide you with an explanation of any
changes that it makes.
If you have questions regarding this matter, please contact me at (920) 303-5435 or
Sincerely,
Keith Marquardt
Water Resource Management Specialist
Bureau of Water Quality
Wisconsin Department of Natural Resources
Cc: Chris Stempa – Appleton
Kelley O’Connor, Wastewater Supr.-Green Bay DNR
wisconsin.gov Printed on Recycled
Paper
dnr.wi.gov
Scott Walker, Governor Cathy Stepp, Secretary
State Customer Service # 888-936-7463
Oshkosh FAX# 920-424-4404
State of Wisconsin DEPARTMENT OF NATURAL RESOURCES Oshkosh Service Center 625 East County Road Y, STE 700 Oshkosh, WI 54901-9731
Content of Letter
• Assigns code number to trade, for example WQT-2016-0001H
• States WQT is acceptable and consistent with WQT rules andDNR guidance
• Repeats some details from WQT plan, for example:• Total number of acres used to generate credits
• Lists management practices used to generate credits
• Number of credits generated.
• States conditions of approval
•WQT plans are followed
•WQT permit conditions are met
• Points out that WQT will be noticed for public comment
Permit Drafting
Public Notice
Informational Hearing
EPA Approval of the Water Quality Trade
Permit Issuance
• Monitoring Requirements and Effluent Limitations•Limit representing minimum control level (TBEL)•TP WQBELs
• Statement of WQT Authorization•Listing of WQT credits
• Method for Demonstrating Compliance with WQT• Additional WQT Requirements
•Monthly certification•Notification of management practice failure•Management practice registration form
• Annual WQT Report• Permit Reopener Clause• Compliance Schedule if Needed
•Remainder of TP WQBELs compliance schedule•Annual WQT Reports
WPDES Permit No. WI-0065251-02-0
Green Bay Metropolitan Sewerage District
1.1.1 Sampling Point 076 - Calculated Combined Effluent for TMDL Reporting
Monitoring Requirements and Effluent Limitations
Parameter
Limit
Type
Limit and
Units
Sample
Frequency
Sample
Type Notes
Phosphorus,
Total − lbs/day Daily Calculated See Footnote 3.2.5.1.
WQT TP
Credits − lbs/day Monthly Calculated Monitoring requirements effective July
1, 2023. Also see Footnotes 3.2.5.1
through 3.2.5.6.
WQT TP
Computed
Compliance
Monthly
Avg.
203 lbs/day Monthly Calculated Monitoring requirements and effluent
limit effective July 1, 2023. Also see
Footnotes 3.2.5.1 through 3.2.5.6.
WQT TP
Computed
Compliance
6-Month
Avg.
68 lbs/day Monthly Calculated Monitoring requirements and effluent
limit effective July 1, 2023. Effluent
limit effective for the periods of May
through Oct. and Nov. through April
each year. Also see Footnotes 3.2.5.1
through 3.2.5.6.
WQT TP
Credits − lbs/month Monthly Calculated Monitoring requirements effective July
1, 2023. Also see Footnotes 3.2.5.1
through 3.2.5.6.
WQT TP
Credits, Crop
Year Total
− lbs/yr Monthly Calculated Monitoring requirements effective July
1, 2023. Also see Footnotes 3.2.5.1
through 3.2.5.6.
1.1.1.1 Calculation of Combined Effluent Results
Total phosphorus monitoring results (lbs/day) reported for Sampling Point 076 shall be calculated as the sum of those
respective parameters reported at Sample Points 001 (GBF Effluent) and 051 (DPF Effluent).
1.1.1.2 Water Quality Trading
The permittee may use water quality trading (WQT) to demonstrate compliance with total phosphorus (TP) effluent
limits of 203 lbs/day monthly average and 68 lbs/day 6-month average. As specified in approved WQT plans WQT-
2018-00001PT, the following credits are available.
3.2.5.2.1 Water Quality Trading Credits by Crop Year1
Crop Year1
2023 2024 2025 2026 2027
Total Phosphorus Credits (lbs TP/yr) 33 44 54 19 25 1 The crop year extends from November through October. For example, the 2023 crop year begins
November 1, 2022 and ends October 31, 2023.
The permittee shall not use more WQT credits each 12-month crop year than shown in the above table.
Only those credits established by a WQT plan approved by the Department may be used by the permittee to
demonstrate compliance with the TP effluent limits identified in this footnote. If the permittee wishes to use credits
not identified in an approved WQT plan, the permittee must amend the existing plan or develop a new plan and obtain
Department approval of the amended or new plan prior to use of new credits. Prior to Department approval, the
amended or new WQT plan will be subject to notice and opportunity for public comment.
In the event credits as defined in the approved WQT plan are no longer generated, the permittee shall comply with the
TP effluent limits contained in this footnote without the use of WQT credits.
Each Month:
• Select the number of TP credits (WQT TP Credits) that will be used for the month.
• Subtract the selected WQT TP Credits from the monthly average and report difference as the WQT TP Computed Compliance in lbs/day.
• Subtract the selected WQT TP Credits from the monthly average TP discharge and report the difference as WQT TP Computed Compliance .
• Multiply the selected WQT TP Credits by the number of days in the month that discharge occurred and report as WQT TP Credits lbs/month.
• Total the number of credits used during the crop year by totaling monthly total credits used for each month starting with November and ending with October each crop year and report the total cumulative number of credits as WQT TP Credits, Crop Year Total lbs/yr column.
Every April and October
• Recalculate the number of credits used if necessary.
Monthly Certification
The permittee shall certify each month that the nonpoint source management practices installed to generate WQT credits are operated and maintained in a manner consistent with that specified in the approved WQT plan. Such a certification may be made by including the following statement as a comment on the monthly discharge monitoring report:
“I certify that management practices identifiedin the approved WQT plan as the source ofcredits are installed, established and properlymaintained.”
Notification of Management Practice Failure
The permittee shall notify WDNR by telephone within 24 hours or next business day of becoming aware that WQT credits used or intended for use by the permittee are not being implemented or generated as defined in the approved WQT plan. A written notification shall be submitted to the Department within 5 days regarding the status of the permittee’s WQT credits.
The permittee shall provide WDNR written notice within 7 days of the trade agreement upon which the approved WQT plan is based being amended, modified, or revoked. This notification shall include the details of any amendment or modification in addition to the justification for the changes.
Annual Reporting
When using WQT to demonstrate compliance with effluent limitations, the permittee shall report by January 31st each year beginning January 31, 2024 the following information in a written report:
• The number of WQT credits (lbs/month) used each month of the previouscrop year to demonstrate compliance;
• The source of each month’s WQT credits by identifying the approved WQTplan that details the source;
• A summary of the annual inspection of each nonpoint source managementpractice that generated any of the WQT credits used during the previouscrop year including whether channels and/or gullies have formed on thefields; and
• Identification of noncompliance or failure to implement any terms orconditions of this permit with respect to WQT that have not been reportedin discharge monitoring reports.
WQT Reopener
Under any of the following conditions as provided by s. 283.53(2), Wis. Stats., and Wis. Adm. Code NR 203.135 and 203.136, the Department may modify or revoke and reissue this permit to modify or eliminate permit terms and conditions related to WQT:
• The permittee fails to implement the WQT plan asapproved;
• The permittee fails to comply with permit terms andconditions related to WQT; or
• New information becomes available that would changethe number of credits available for the WQT or wouldchange the Department’s determinations that WQT isan acceptable option.
Proposed Changes: Effluent quality from the upgraded WWTF is expected to be in the range of 0.2 to 0.4 mg/L total phosphorus which will not meet the new phosphorus effluent limitations at all times. In order to ensure compliance at all times, the WWTF will utilize water quality trading credits for phosphorus.
Water Quality Trading: The Department has tentatively decided to approve the permittee’s water quality trading plan and allow the permittee to demonstrate compliance with the water quality based effluent limits for total phosphorus as specified in Water Quality Trading Plans WQT-2016-0001H and WQT-2016-0002H.
WPDES Permit No. WI-0050521-09-1
WPDES PERMIT
STATE OF WISCONSIN
DEPARTMENT OF NATURAL RESOURCES PERMIT TO DISCHARGE UNDER THE WISCONSIN POLLUTANT DISCHARGE
ELIMINATION SYSTEM
Baker Cheese Factory Inc.
is permitted, under the authority of Chapter 283, Wisconsin Statutes, to discharge from a facility
located at
N5279 County Road G, St. Cloud
to
a wetland tributary to the Mullet River, Sheboygan River Watershed (SH03) and groundwater in the Sheboygan River
Basin via land application and absorption pond seepage in Fond du Lac County
in accordance with the effluent limitations, monitoring requirements and other conditions set
forth in this permit.
The permittee shall not discharge after the date of expiration. If the permittee wishes to continue to discharge after
this expiration date an application shall be filed for reissuance of this permit, according to Chapter NR 200, Wis.
Adm. Code, at least 180 days prior to the expiration date given below.
State of Wisconsin Department of Natural Resources
For the Secretary
By _________________________
Nanette E. Jameson
Wastewater Specialist
_________________________
Date Permit Signed/Issued for Modification
PERMIT TERM: EFFECTIVE DATE - January 01, 2015 EXPIRATION DATE - December 31, 2019
EFFECTIVE DATE OF MODIFICATION: December 01, 2015
City of Appleton Hypothetical Trade
NEW Water Pilot Trade
Will DNR use the documents that I created for the Fox P Trade Project?
Thank you.
•Implementing Water Quality Trading in WPDES Permits
•A Water Quality Trading How To Manual
http://dnr.wi.gov/topic/SurfaceWater/WaterQualityTrading.html
•Agricultural Nonpoint Source Implementation Handbook for AM and WQT WPDES Permit Compliance Options
http://dnr.wi.gov/news/input/guidance.html
•Water Quality Trading for Phosphorus in the Lower Fox River Watershed: A Handbook
(http://foxptrade.org)
Water Quality Trading & Adaptive Management Overview
Water Quality Trading & Adaptive Management: Finding, Quantifying Credits
Water Quality Trading & Adaptive Management--Developing a Plan
Water Quality Trading & Adaptive Management--Implementing & Verifying Offsets
http://dnr.wi.gov/topic/SurfaceWater/atlas.html
