POLLUTANT TRADING AND A PHASED PERMITTING APPROACH FOR THE TRUCKEE RIVER TMDL PROGRAM

This paper presents the findings, conclusions and recommendations for the implementation of a trading program for TMDL modifications on the Truckee River. In addition, this paper discusses the viability of a seasonal TMDL and includes a discussion on the phased approach towards developing pollutant trading permit language. The State of Nevada's Division of Environmental Protection (NDEP) listed the Truckee River on their 1988 303(d) list and established TMDLS for total nitrogen, total phosphorus and TDS on the Nevada side of the river. As a result of the TMDL process, the Truckee Meadows Water Reclamation Facility (TMWRF) had waste load allocations (WLAs) incorporated into their NPDES permit, which has resulted in potential restrictions on planned growth. In order to accommodate for planned growth and to meet water quality objectives, a pollutant load trading program is being implemented. The development of the trading program, includes establishing the technical basis for modifying the TMDLs and WLAs and for identifying the optimum mix of structural and nonstructural projects and programs to be implemented. This involves the development of watershed and water quality models. In addition, the development of the pollutant trading program involves a phased NPDES permitting approach, while pollutant trades are developed, implemented and regionally accepted.