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Cap & Trade in Florida? How water quality credit trading can benefit you.
Mark P. Thomasson, P.E., LEED AP
WSource Group, LLC
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Regulatory limit on discharge
Ability to create credits (allowances)
Flexibility in meeting discharge allowance
Ability to buy or sell allowances
Market driven flexibility to achieve compliance in the most affordable manner
What is Cap & Trade
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State Level:
Oregon
Connecticut
Watershed Level:
Virginia Nutrient Credit Exchange Association/Chesapeake Bay TMDL
http://water.epa.gov/type/watersheds/trading.cfm
Where is this being done?
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HB 2862 (2005) authorized trading & create exchange
V.N.C.E.A.I.
Voluntary, market-based nutrient credit trading
Annual compliance update
Point Source governed by GP
Non-point offset new or expanded
Compliance achieved in 2011
Virginia Nutrient Credit Exchange
The Chesapeake Bay Watershed spans six
states and the District of Columbia.
(Source: EPA)
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Long Island Sound Nitrogen TMDL
General Permit for Nitrogen Discharges
Nutrient Credit Exchange (CTDEP)
2002 – Reduce Nitrogen by 65% by 2014
2013: $5.61/lb/yr; $60.9M
Successful - Not sustainable (59 of 79)
Connecticut’s Statewide POTW Program
Source: CTDEEP
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Temperature main concern Water Quality Trading in NPDES Permits Internal
Management Directive, August 2012 Clean Water Services, Hillsboro, OR
5 facilities, watershed-based permit Thermal trade, supplemental stream shading,
increase base flow, BOD trade
City of Medford NPDES Permit #100985 Rogue Basin TMDL Thermal Trade
Source is the driver
Oregon Water Quality Trading
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TMDL
Maximum capacity
NNC
When defaults to TMDL
When expresses as a load
What are caps in Florida?
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LSJRPilot
2008 Legislature created pilot in LSJR
Statute: 403.067(10)
Rule: 62-306
Pre/Post BMAP Trades
HB 713 (2013)
Statewide rule
Trading in Florida
Source: FDEP
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Seller Buyer Parameter
Amount
Traded
(kg/yr)
Cost for
Trade
Town of Hastings Wastewater
Treatment Plant (WWTP)
St. Johns
County
Total Phosphorus
(TP) 271
$30,000/
year
Clay County Utility Authority
(CCUA) – Aggregate Clay County
Total Phosphorus
(TP) 1,476 $0
CCUA Fleming Island WWTP Clay County Total Nitrogen (TN) 409 $0
Jacksonville Electric Authority City of
Jacksonville Total Nitrogen (TN) 30,340
$2,086,676/
year
What Trading Has Taken Place?
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403.067 (2013)
Consistent with Fed Law
Implemented in a permit (WQCT permit)
Department establishes value
Department enforces sellers responsibilities
May be authorized in BMAPs
Department may adopt rules
HB 713 Expanded Trading
Buy
Sell
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General Requirements BMAP or RAP Confirmed or Modeled Permit or BMAP to Sell
Eligibility Meets baseline Above requirements Not required
Process for: How quantified, LF, UF How validated
Create a public registry Compliance
What’s in the Rule?
CHAPTER 62-306
WATER QUALITY CREDIT TRADING
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Facilities (WWTP, IWW, Ag, MS4s)
Counties, Cities (septic tanks, non-MS4)
FDOT & Ports
Owners / Developers
Operators
Consultants
The Environment!
Who can benefit?
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EPA (water.epa.gov/type/watersheds/trading.cfm)
Environmental Trading Network (www.envtn.org)
Virginia Nutrient Credit Exchange Association (www.theexchangeassociation.org )
Connecticut Nitrogen Credit Exchange (www.ct.gov/deep)
Oregon DEP Water Quality Trading Program (www.deq.state.or.us/wq/trading/trading.htm)
Mark Thomasson: [email protected], 850-510-2226
Additional Resources
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