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Explore drivers, policies, and lessons on nutrient trading from baseball. Learn about EPA trading policy updates, nutrient removal goals, and plant improvement approaches. Discover how computer modeling can evaluate pollutant trading effectively.
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Nutrient Reduction Moneyball 5 Cities Plus Conference 2019
Nutrient Reduction Moneyball • Nutrient trading drivers and policies • Assessment methodology • What is a good trade? • What can we learn about nutrient trading from baseball?
Traditional Nutrient Reduction Drivers • Water Quality Standards • Total Maximum Daily Loads • Gulf Hypoxia Nutrient Reduction Plans
2019 EPA Trading Policy Update • Reiterated EPA’s strong support for water quality trading • Provided guidance regarding use of market-based programs to reduce water pollution • Watershed scale trading • Adaptive management • Credit banking • Establishing baselines • Credit generation for multiple markets • Financing opportunities
Nutrient Removal Goals • Technology-Based Goals • Biological Nutrient Removal (BNR, or Level 1) • 10 mg/L N, 1 mg/L P • Enhanced Nutrient Removal (ENR, or Level 2) • 5 mg/L N, 0.5 mg/L P • Water-Quality Based Goals • Load Reductions to Meet Hypoxia Goals • 45% Overall but Higher Point Source Reductions Typical • Nutrient Criteria or TMDL
Permitting Assumptions and Flexibilities • Seasonal or Annual Effluent Limit Averaging Period • Reduce Operational Impacts (e.g. wet weather) • Mass Limits rather than Concentrations • Facilitates Trading, “Bubble” Permitting • Design Flow vs. Actual Flow • Addressing Far Field Water Quality Impacts • “Bubble Permitting”, or point-to-point trading, is OK
Nutrient Removal Portfolios • 6 Facilities • 6 Alternatives (Eliminated least cost-effective L1 and L2) • 6^6 = 46,656 possible treatment portfolios
What is a good trade? • Facility dependent • Pollutant dependent • Depends on level of nutrient removal needed
Final thoughts… • We need objective knowledge to evaluate pollutant trading • Computer modeling makes it cost effective to evaluate vast numbers of trade scenarios • Do we have the “right math” to evaluate the value of a trade? • Credit banking, credit generation, and so on…