The boys at the Bay Action Plan explain their reservations: Nutrient Trading: Our Concerns
Nutrient trading is essentially a plan to use market forces, rather than direct government fiat, to determine how nutrient reductions are accomplished. Rather than the EPA telling each farmer and sewage plant operator how much of what nutrients they can release, nutrient trading would fix the amount of nutrients allowed to be released, then allocate the nutrients to be released among the current polluters proportional to their current releases, and then permit them to sell the rights to use their share if they want. For example, a farmer could choose not to farm and release nutrients, and sell his share to a municipal sewage plant.
The method is touted as a largely voluntary and market based method of achieving the desired goals. It's not to say it is perfect; but it will do so largely on a voluntary basis, and will encourage the more economically valuable processes to buy the nutrient shares, and hence, pollute more. Now lets consider BAPs "reservations":
1. Nutrient trading is a relatively new and untested technique for pollutant reductions in waterbodies that makes assumptions regarding short- and long-term effects.Yes, but that's a conservative argument. Gay marriage is relatively new and untested, but I suspect that Bill Dennison would support that on grounds of freedom being more important than the unproven and alleged negative effects.
2. All efforts should be made to improve and then preserve local water quality."All?" All efforts to improve and preserve local water quality would entail moving the current population out of the watershed. If that's what it takes, they'll never be satisfied. Can we perhaps settle on some reasonable level of effort?
3. Independent, rigorous, and transparent verification is essential.Yes, but can I trust you to be independent, rigorous and transparent?
4. A policy of net improvement credit is needed to account for uncertainties in non-point sources reductions and runoff variability.I thought your models were perfect, or at least good enough to tell people what they needed to do. That objection pertains to any policy on nutrient reduction you wish to impose.
5. Nutrient trading should not be used to maintain discharges at technology levels below industry standards.Why not? If you've set a series of standards that produce the TMDL that you think is sufficient to achieve your goals, and some industry can use a less efficient (and less expensive) technology to achieve those results, and do so economically, why shouldn't they be permitted to?
6. Nutrient trading may create environmental justice issues by moving problems to disadvantaged areas.Ah yes, the "Environmental Justice" (race) card. Yes, and moving pollution (and industry) to disadvantaged area will also likely provide them opportunities for jobs. Essentially, they're objecting to the possibility that industries will move to where it's cheaper to operate and escape destruction.
7. Trading could benefit large organizations and corporations without protecting the interests of local waterways and grassroots entities.Of course, trading could benefit large organizations and corporations. Of course, it could also disfavor them as well depending on the circumstances. One of the important ideas behind trading it that it favors the use with the greater economic impact. To try and mitigate that is to try to remove a significant part of the idea of freedom that underlies trades.
8. The total impacts of nutrient trades need to be measured and adequate compensation provided.I thought the idea of nutrient trades was to allocate nutrient pollution, not to redistribute money. I'm shocked, shocked that you would try to sneak redistribution into the process.
9. Credited practices and the models used to calculate the amounts of credits awarded need to be standardized.Again, I thought your models were already good (well, no, I really didn't, but you insisted they were good), so you should be prepared to live with the results. Of course, some tweeks need to be permitted in practice, but if you find big problems with the models you need to reexamine the whole system of TMDLs.
10. Growth allocations should be based on demonstrated pollution reductions in other sectors, not on speculative, proposed reductions in those sectors.OK, I'll give you this one. I'm sure we can count on solar and wind power to pick up all the slack in growth, right? We never plan on speculative technologies to solve our up coming problems...
My guess is, they'd rather have the power to name winners and losers than to allow the market to make the decisions.