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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.
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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…