Dogs Don’t Eat Dogs



Our friends at the Center for Progressive Reform recently released an important report, Fairness in the Bay:  Nutrient Trading and Environmental Justice,  about the negative impacts of nutrient trading on low-income and disadvantaged communities.  Nutrient trading is a market-based approach to pollution reduction that creates an exchange enabling polluters to purchase credits from someone who reduces pollution from a different source in a different place.  For example, under nutrient trading, a wastewater treatment plant needing to reduce its pollution could purchase credits from a farmer.  Nutrient trading has been incorporated into Maryland’s pollution reduction efforts under the Chesapeake Bay TMDL (Total Maximum Daily Load) as a way to deal with additional pollution anticipated to result from future growth and development.   The scheme has been understandably highly controversial within the environmental community –some feel that trading will compromise the integrity and effectiveness of the whole TMDL effort, while others are certain that the market-based tool is only way to reduce costs while achieving pollution reduction.


CPR’s report rightfully points out that market-based nutrient trading could have a particularly deleterious impact on communities lacking a voice and power in water quality decisions.  The report cites specific concern about the potential for pollution hotspots resulting from trading.   If you look at where our biggest pollution sources are located –too often in areas already suffering from poverty and a host of other environmental risks – allowing more pollution in already compromised communities is not an equitable solution.


Maryland Department of the Environment has been hosting stakeholder meetings around the state, listening to comments, concerns, and suggestions about their “Accounting for Growth” policy, which provides a framework for how to keep pollution in keeping with the Chesapeake Bay TMDL when future development and growth takes place.  The policy relies heavily on nutrient trading to keep pollution loads resulting from growth in check.  As we understand it, the nutrient trading framework is still under development at Maryland Department of Agriculture and no official regulations have been issued for public review or comment.


As government entities and communities around the Chesapeake Bay watershed are planning and implementing pollution reduction actions, the question of how these investments impact low-income and minority communities deserves serious attention.   We have before us a ripe opportunity to ensure that the deep investment of resources needed to reduce pollution will raise the tide for all boats.