USDA, EPA Partnership Supports Water Quality Trading To Benefit Environment, Economy CAPR questions both the need, and the methodology to this most recent evolution of the imaginary marketplace. One wonders what will be next, water palatable quality global environmental justice trading? From the USDA news "Water quality trading provides a cost-effective approach for regulated entities to comply with EPA Clean Water Act requirements, including water quality-based effluent limits in National Pollutant Discharge Elimination System permits. Trading would allow regulated entities to purchase and use pollutant reduction credits generated by other sources in a watershed. Cost savings and other economic incentives are key motivators for parties engaged in trading. Water quality trading can also provide additional environmental and economic benefits, such as air quality improvements, enhanced wildlife habitat, carbon capture and storage, and new income and employment opportunities for rural America." Translated from agency-speak: Water quality trading may be less expensive than fines and litigation for regulated rural landowners and municipalities. You have the alternative to those expenditures by giving money to others who have spent money, often taxpayer money, on projects elsewhere in your same watershed. This might also get you off the hook because the money you give to others may also pay for others to initiate or complete other environmental projects and so lessen the probability that you would have to face this entire scheme again under another regulated activity. Also from the release, with translation: USDA and EPA will: Coordinate and enhance communications and outreach to states, agricultural producers, regulated sources, and interested third parties on water quality trading; Translation: USDA and EPA will collaborate in creating this water quality bank, the interested third parties are not mentioned, but we have seen the likes in the past. Engage expertise across agencies in the review of grants, loans or technical assistance programs focused on water quality trading; Translation: Those who have created similar banking programs in the past will create this one as well. Share information on the development of rules and guidance that have the potential to affect water quality trading; Translation: There will be another rule making to apply policy to this banking scheme, and there will be a public comment period for the sake of form. Collaborate on developing tools and information resources for states and credit generators to guide decision making, reduce costs in program design and implementation, improve environmental performance, and foster consistency and integrity across regional initiatives; Translation: The methods of implementing and enforcing this banking scheme will be established. Co-host a workshop by 2015 to share tools and resources available to assist in stakeholder decision making and opportunities. Translation: There will be meetings in which those who are regulated will be told how to behave. And finally from the USDA release, with translation: The purpose of this policy is to support states, interstate agencies and tribes as they develop and implement water quality trading programs for nutrients, sediments and other pollutants where opportunities exist to achieve water quality improvements at reduced costs. Translation: We have satisfied the mandate that the purpose of this project is publicly stated. We are telling you now that we will use every means possible to regulate you. “The most terrifying words in the English language are: I'm from the government and I'm here to help.” Ronald Reagan

February 25, 2015