The Chesapeake Bay Foundation appreciates the concern about nutrient trading expressed by Dr. Robert S. Lawrence of the Johns Hopkins Bloomberg School of Public Health ("Nutrient trading a dirty deal for the bay, Dec. 9). We would like to present some additional information to the conversation about this complicated and controversial topic.
We agree with Dr. Lawrence that any trading program that allows local waters to remain dirty is unacceptable. Reducing pollution so that local waterways and the bay meet water quality standards is the ultimate goal of the Clean Water Blueprint for the Chesapeake Bay and its rivers and streams. It is also required by the Clean Water Act.
In addition, Dr. Lawrence is right that the Environmental Protection Agency and the states need to be more active in enforcing existing law. Whether it is a concentrated animal feeding operation, a wastewater treatment operation or a municipality treating runoff from urban streets, polluters who violate regulations or laws should be held accountable.
However, enforcing existing laws and regulations is but one arrow in our quiver. Trading is another. Nutrient trading programs, in particular, provide one of the only mechanisms to quantify and offset pollution associated with new development. Experts believe that because of the high cost of reducing urban storm water runoff, the most likely "buyers" in trading markets will be local governments. That means all of us as taxpayers.
The Chesapeake Bay Foundation and the Choose Clean Water Coalition support a list of 10 principles that ensure a trading program will result in real pollution reductions and protection against pollution "hot spots."
Our bottom line is that we will not agree to any trades, no matter how much money they save, if they fail to insure the following:
•Water quality must be protected or improved — no exceptions. Trades must not degrade local water quality, and trading programs should be structured in ways that result in a net improvement to water quality.
•Before an entity can sell credits, it must have achieved its targeted baseline for pollution reduction. Credits can be sold only when sellers goes beyond what is necessary to achieve their share of pollution reductions.
•Accountability, transparency, and verification are essential. For trading to be viable, the public has to be able to review, comment on, and even challenge a trade.
Trading is complicated — the proverbial "devil is in the details." We believe these obstacles can be overcome, however, and that when they have been, trading could be one of the tools to achieve what Dr. Lawrence, the Chesapeake Bay Foundation and the public agree on: Clean, safe water for all is an urgent and immediate goal.
The Maryland Department of the Environment is committed to a formal process among all the stakeholders starting in January to work through how we account for new growth and also how we work through all the details of trading. Having perspectives such as Dr. Lawrence's will ensure that the connection between pollution and human health risks is addressed.
The writer is senior water quality scientist at the Chesapeake Bay Foundation.