DEVELOPING A NUTRIENT TRADING PROGRAM IN MARYLAND

The Chesapeake Bay Program has produced challenging new goals for reducing nitrogen and phosphorus loads to the Bay. By 2010, Maryland must reduce its annual nitrogen load to the Bay from 57 million pounds to 37 million pounds and its phosphorus load from 3.8 million pounds to 2.9 million pounds. The wastewater component of Maryland's proposed strategy to accomplish this is to upgrade all 67 major wastewater treatment plants in the state to the socalled “limits of technology” for nutrient removal, 3 mg/l for nitrogen and 0.3 mg/l for phosphorus, and assign load allocations to each WWTP based on these concentrations and permitted capacity. The current estimated capital cost to accomplish this is 800 million. The Maryland Association of Municipal Wastewater Agencies (MAMWA) concluded that a nutrient trading program consisting of the creation of four trading associations could meet the goals of first achieving and then maintaining the point-source allocations at substantially lower cost than the original proposed strategy of upgrading all WWTPS by 2010 and recommended this approach to the state. The recommendation was then overtaken by the passage of a bill by the Maryland legislature authorizing a “Chesapeake Bay Users Fee” of thirty dollars a year to be charged to all water and wastewater utility customers in the state, with the revenue from the fee dedicated to the financing of wastewater treatment plant upgrades to the limit of technology for nutrient removal. Current Maryland policy seems to be to upgrade all major wastewater treatment plants in the state (0.5 MGD or larger) and provide 100 percent state grants for the cost. This approach would leave little room for nutrient trading and seems to ignore costeffectiveness consideration in the selection of nutrient reduction strategies.