What common elements should a credible trading program have?
• Legal authority: The CWA along with state regulations provide a legal authority for states and tribes to develop and administer trading programs. • Units of trade: A common unit of trade should be clearly defined. • Timing of credits: The creation and duration of credits should be considered. Credits should be generated and used within the same time period in order to comply with permit limits and prevent localized exceedances of water quality standards. • Managing uncertainty: The trading program should include methods of managing uncertainty such as using trading ratios, monitoring, modeling, and BMP efficacy estimates. • Compliance and Enforcement: The trading program should have mechanisms for compliance and enforcement. These could include record-keeping, certifications, inspections, and reporting. • Public notice: The program should include adequate public notice, for example, through the TMDL and permit process and a public website. • Program evaluation: Program evaluation sho
