The "waterkeeper" and "riverkeeper" who argue against the use of nutrient trading are missing the point and misleading Baltimore Sun readers ("Cardin bill undermines Clean Water Act," Commentary, Aug. 25).
Both the science and economics of cleaning the Chesapeake Bay make it clear that using nutrient trading programs will be necessary to prioritize pollution reduction measures that match high environmental benefits and lower costs of compliance.
The U. S. Environmental Protection Agency is in the final months of setting binding caps on the amount of nitrogen, phosphorous and sediment that can enter the Chesapeake Bay. In the years to come, Maryland and the other bay states will be required to identify and implement all manner of actions that will permanently reduce these pollutants and improve bay water quality.
In May, Maryland implemented the next generation of storm water management regulations on new land developments that require the permanent post-development storm water runoff to have the same characteristics as the runoff from a healthy forest. This means that new development will always maintain existing conditions or, when building on grassland, agriculture or existing urbanized lands, new developments will permanently improve the existing environmental conditions.
How the rest of the mandated pollutant reductions will be achieved is a difficult problem that is being worked out now in Annapolis and other state capitals. It is easy to write that "polluters" should be accountable, but we all are polluters. When we drive our cars, flush our toilets, wash clothes, buy local sweet corn, or fertilize our lawns, we all contribute to bay pollution. Most Marylanders live in a county or town that must make changes that further reduce storm water and wastewater pollutants as dictated by EPA.
The science of bay pollution argues strongly that nutrient trading programs be part of the clean-up strategy. Take nitrogen as an example. One pound of nitrogen that runs off your yard does not always stay in your local creek or river, it migrates downstream until it reaches the main stem of the Chesapeake Bay where it is concentrated with nitrogen from as far away as Cooperstown, N.Y., creating the oxygen-starved "dead zone" that has come to symbolize the decline of the bay.
What most people find surprising is that a pound of nutrients from, say, the Susquehanna, Potomac or James Rivers, the three largest sources of bay pollutants, impacts the bay differently. For example, every pound of nitrogen that leaves the Susquehanna has three times the impact on deep water oxygen concentrations in the middle bay than does a pound of nitrogen originating from many parts of central Maryland located much closer to the bay. Because of differences in geographic impact, it makes sense to concentrate pollution control efforts in areas of Maryland's Eastern Shore, as well as northeast and southern Pennsylvania, where controls will have the greatest effect and achieve the most rapid improvement to bay water quality. One of best ways to do this is through nutrient trading programs.
Economics also argues for nutrient trading. In the 2003 report, "The Cost of a Clean Bay: Assessing Funding Needs Throughout the Watershed," the Chesapeake Bay Commission (CBC) projected that meeting the less rigorous 2000 Chesapeake Bay Agreement goals would cost governments $18.7 billion across the three Bay Commission states (Maryland, Virginia, and Pennsylvania). But much of bay cleanup will be achieved by pollution control regulations that impart enforceable obligations on private interests. The costs of these measures are not borne by government but by individuals and entities in the watershed, making the total cost to the public many billions more than the CBC's $18.7 billion estimate of direct government costs.
The CBC encourages the application of strategic spending in order to reduce bay pollution in the most cost-effective manner. The five most cost-effective ways to reduce nitrogen pollution are agricultural practices that range in cost from $1.57 to $4.41 per pound of nitrogen removed. In contrast, the six most commonly applied urban nitrogen reduction practices carry a direct cost of $280 to $2,698 per pound of nitrogen removed.
Nutrient trading does not allow more pollution than the EPA limits, but it does present the potential for cities, counties, individuals and wastewater treatment plants to be matched with low cost water quality improvements in other locations and do their part for bay clean-up by providing more environmentally beneficial mitigation at far lower cost. Without nutrient trading, most Marylanders will have only the most prohibitively expensive options available when deciding how to comply with EPA's bay cleanup mandates.
The writer is vice president for policy and government relations at the National Association of Industrial and Office Properties in Baltimore.