Is Urban Stormwater Ready for Pollutant Trading? Long Island Sound Pollutant Trading Initiative

The National Fish and Wildlife Federation (NFWF) has been working with the New York State Department of Environmental Conservation (NYSDEC) and the State of Connecticut Department of Environmental Protection (CTDEP) to develop a pollutant trading scheme for nutrients in Long Island Sound (LIS). CTDEP had successfully implemented a nutrient trading scheme for Publicly Owned Treatment Works (POTW) in the watersheds lading to LIS that resulted in active participation and significant reductions in total nitrogen loads to LIS.Because of the success experienced by CTDEP with the POTW nutrient trading scheme, parties are interested in broadening the nutrient trading scheme to non point sources (NPS) and to include New York. Watershed wide nutrient discharges from point and non-point sources were modeled to ascertain a nutrient trading scheme that would be equitable, attract multiple participants, and result in overall nutrient load reductions to LIS.A ten (10%) percent reduction from various NPS loads from baseline conditions can possibly be achieved through implementation of best management practices and low impact development (BMP/LIDs).There are still numerous challenges associated with NPS nutrient trading schemes. Underestimation of NPS control costs and overestimation of point source control costs have triggered alarming concerns about the cost-effectiveness of point to NPS trades. Similarly, the excessive monitoring needs associated with NPS performance evaluation add significant costs to the administrative and technical elements of trading. These factors often lead to NPS trading being less cost-effective and more demanding in terms of administrative, regulatory and policy elements, in comparison to point source trading.The NPS controls can be designed to achieve several auxiliary objectives including sustainability, streambank protection, stormwater harvesting, and flood mitigation that enhance the ecosystem valuation aspects of NPS control projects.