Water Quality Trading & Adaptive Management

7/29/2019 Water Quality Trading & Adaptive Management

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Several options exist to meet WQBELs and TMDL allocations

including:

Adaptive Management Modifying wastewater treatment systems

Modifying your production process to limit additives or raw

materials

Trading

Options can be used in combination


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Water quality trading is an exchange

of pollutant reduction credits.

A buyer with a high pollutant controlcost can purchase pollutant reduction

or treatment from a willing seller.

Trading can produce substantial costsavings but must result in an

improvement in water quality and a

net reduction of the pollutant being

traded.


4/31

Fox River Basin Developed guidance,

element list, issue summary,and reports.

Rock River Basin Developed a framework

and pursued some tradesbut lack of sufficienteconomic incentives prevent

trades.

Red Cedar Basin City of Cumberland Trade

Wisconsins History with Trading


5/31

WQT May be Used To:

Demonstrate compliance with WQBELs

Offset pollutant load from new or expanding

discharger

WQT Guidance Not Applicable to TBELs

WQT not allowed when localized exceedance of

water quality standards will occur


6/31

Nutrients Phosphorus

Nitrogen

Total Suspended Solids (sediment)

Temperature

Dissolved Oxygen-related Parameters (e.g.,biochemical oxygen demand)


7/31

Non-TMDL WQBELs

Credits must be

generated upstream of

credit users discharge

TMDL WQBELs

Credits may begenerated within the

drainage area for the

impaired segment

(segmentshed)


8/31

Credit threshold is the pollutant load below

which reductions must be made to generate

pollutant reduction credits.

Credits Generated by Point Source Threshold is lesser of WQBEL or TBEL

Credits Generated by Nonpoint Source Lesser of TMDL LA or Performance Standard (e.g., ch. NR 151)

5-yr Interim Credit = Reduction from Existing Pollutant Load


9/31

Final Trade Ratio = Delivery + Equivalency + Reserve +

UncertaintyHabitat Adjustment

For trades involving point and nonpoint sources the trade

ratio cannot be lower than 1.2:1 (1.2 pounds of nonpoint for

every pound of point source pollutant). For trades located

upstream in the same HUC-12 the equation simplifies to:

Final Trade Ratio = 0.2 + UncertaintyHabitat Adjustment


10/31

Delivery (distance between generator and user)

TMDLSame factors used in TMDL

Non-TMDLUSGS SPARROW model for P,

N and sediment

Equivalency (form of pollutant)

Not necessary with phosphorus Not yet specified for N and TSS (sediment)


11/31

Downstream Trade Ratio Factor:

Percent Difference

between Buyers Loadand Total Load at

Point of Discharge

Downstream Trade

Ratio Factor

< 25% 0.2

25 - 50% 0.450 - 75% 0.6

75% > 0.8


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Reserve Factor

Reserve sets aside a portion of the pollutant credits to help

offset liability and uncertainty between the buyer and seller

associated with potential failure of management practices.

Pollutant / Constituent Reserve Factor

Total Phosphorus 0.2

Total Suspended Solids (TSS

or SSC)

0.2

Total Nitrogen Currently Not Available

Thermal Not Applicable


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BMP or Practice

Uncertainty Trading

Ratio

Applicable Technical

Standards

Schedule

for Credit

Use Notes

Whole Farm Managementwith multiple practices

1:1 Multiple This includes an approved nutrientmanagement plan, filter/buffer strips,

grassed water ways, conservation or no-till

tillage, and cover crops.

Conservation Easement 1:1 NRCS 327 Conservation

Cover

Credit for land out of production.

Companion Crops

(perennial vegetation)

1:1 Provides continuous protection to soil

surface.

Tillage

Mulch Till 3:1 NRCS 345 Mulch Till

No-Till 3:1 NRCS 329 No-till

Grassed Water Way 2:1 NRCS 412 Grassed

Waterway

Nutrient Management NRCS 590 Nutrient

ManagementFirst Trade Term:

Prior to Confirmation with

Soil Testing

4:1 Once it has been established through soil

testing that nutrient levels are dropping

and that the nutrient management plan is

being followed the trade ratio can be

lowered in subsequent permit/trade

cycles.

Second Trade

Term:Confirmation with Soil

Testing

3:1

Subsequent Trading Terms 2:1


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Habitat Adjustment Factor

NRCS Technical Standard Description

395 Stream Habitat andImprovement and Management

658 Wetland Creation

657 Wetland Restoration


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Final Trade Ratio = Delivery + Equivalency + Reserve +

UncertaintyHabitat Adjustment

For trades involving point and nonpoint sources the traderatio cannot be lower than 1.2:1 (1.2 pounds of nonpoint for

every pound of point source pollutant). For trades located

upstream in the same HUC-12 the equation simplifies to:

Final Trade Ratio = 0.2 + UncertaintyHabitat Adjustment


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Credits Generated by a Nonpoint Source SNAP-Plus and RUSLE2 for agricultural field practices

New Barnyard Toolworking with UW

SLAMM and P-8 for urban practices

Credits Generated by a Point Source Effluent monitoring


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Credits must be generated before they are used

Point source pollutant reduction must be measurable

BMP in-place and effective

Credit use timing depends on credit source

Point sourceAveraging period of limit

NonpointAnytime during calendar year

(highly variable discharge exception)


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Phosphorus WQBEL

Permit language allowing credits to be used when

demonstrating compliance with the limit

Reporting requirements for source and amount of credits

acquired Certification by permittee that BMPs are in place and are

effective


19/31

DNR provides ground rules forbrokers and central exchange.

Credit user and generator may

use a contract.


20/31

Oversight

1

Credit Generator Credit User

Credits Credits
http://dnr.wi.gov/


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22/31

Compliance option focusing on water quality

improvements, rather than a phosphorus offset

Allows point sources to work with nonpoint sources toreduce overall phosphorus loads so that water quality

criteria can be attained

Interim Limits with extended compliance schedule.

NR 217.18, Wis. Adm. Code


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NOT an option for all point

sources

Specific eligibility requirements

must be met

NOT water quality trading

End of pipe compliance option

Eligibility Requirements

1. Receiving water exceeding

the WQC

2. NPS contribute >50% of P

load or NPS must be controlled

3. Filtration or equivalent

technology required to meetWQBEL

NOTE: MS4s considered nonpoint under

adaptive management


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Must use sound scientific data and rationale

PRESTO also available Calculates basin specific average annual phosphorus loads

from point and nonpoint sources

PRESTO combines three concepts: WatershedDelineation, Effluent Aggregation, and PollutantRunoff

Watershed

Delineation

Pollutant

Runoff

Effluent

Aggregation


25/31

Eligible

Adaptive Management selected aspreferred option

Develop theAdaptive Management Plan


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NR 217.18(2)(d)

Step 1: Identify partners

Step 2: Describe the watershed and set loadreduction goals

Step 3: Conduct a watershed inventory

Step 4: Identify where reductions will occur

Step 5: Describe management measuresStep 6: Estimate load reductions expected by

permit term

Step 7: Measuring success

Step 8: Financial security

Step 9: Implementation schedule with milestones


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Point Sources

Partners to develop the plan County LWCDs

Consultants WDNR staff

Partners reducing P loads to receiving waters Agricultural producers

Non-permitted urban sources

MS4s

Other point sources


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Voluntary compliance options for WPDES permit

holders to comply with phosphorus requirements

Options will be used when it is economically

preferable to control nonpoint sources or other pointsources of P

Both require nonpoint and/or other point source

reductions

Contractual agreements should be made

Need to look in same watershed (HUC 12)


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Adaptive Management Trading

Pollutants Covered TP (and possibly TSS) All pollutants except

toxics

End Goals Attaining the water quality

criteria

Offsetting the limit

Implementation Area Watershed-focused Upstream-focused

Offsets No trade ratios Trade ratios apply

Timing Implemented throughout the

permit term

Generating credits

before they can be used

In-Stream Monitoring Required Not required

Level of Documentation

Needed

General watershed

information

Field-by-field

documentation


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Documents

Water Quality Trading & Adaptive Management