Pennsylvania’s innovative and pioneering nutrient trading program offers farmers, communities and industries a valuable tool to meet or exceed state and federal water quality goals. This effort is important to Governor Rendell, as it allows Pennsylvania to make great strides in reducing nutrient discharges in the most cost-effective way.
Unfortunately, treatment facilities are not taking advantage of this practical solution to meet regulatory requirements, and therefore may be doing themselves a disservice when looking for financial assistance through the Commonwealth.
The Department of Environmental Protection has received 63 nutrient reduction compliance plans from sewage treatment plants that, when taken together, represent a vast majority of Pennsylvania’s point source discharges that are delivered downstream to the Chesapeake Bay. Of these facilities, only two elected to use nutrient trading to keep compliance costs down. The remaining facilities plan to, or have completed, physical upgrades to treatment plant capabilities.
For the large growing facilities that need to increase physical and hydraulic capacity, upgrading infrastructure may be the best solution. When included as part of a major sewage treatment plant expansion, nutrient reduction technology can be very cost effective, averaging only about 10-15 percent of the overall project cost. In contrast, retrofitting a recently expanded facility solely for nutrient reduction technology can be expensive per each pound of nutrient removed.
Owners, operators and municipal leaders often turn to PennVEST for financial assistance to undertake these projects. PennVEST financing requires an analysis of the options available and a demonstration that the selected alternative is the most cost effective option. Competition for public infrastructure investment dollars is real. Funding is needed for combined sewer separation, hydraulic overloads and system expansions, as well as nutrient reduction technology. Applicants for PennVEST funding need to demonstrate that the nutrient reduction method that is ultimately chosen is the most cost effective approach to achieve compliance, and that all other options, including nutrient trading, have been taken into account.
Systems not needing increased capacity have the opportunity to optimize an existing plant and investment in nutrient reductions elsewhere in the watershed through the trading program. Mount Joy Borough, Lancaster County, is utilizing such an approach by taking advantage of nutrient trading to meet its municipal sewage compliance obligations, while investing in its local farmers to promote sustainable production agriculture. The borough secured about half of the reductions necessary to reach its cap limit through plant optimization, and half by investing in 930 acres of continuous no-till land on a local family farm. On a pound-per-year basis, the agricultural reductions cost about half of the reductions realized through the treatment plant upgrade.
Nutrient trading allows operators to invest in the cheapest nutrient reduction opportunities available in the watershed, not just those options available at their own treatment plant. Although not proposed by any treatment facilities, several municipalities partnering in one upgrade at one facility could share the resulting stream of nutrient reductions in each of their permits, providing yet another approach to meeting nutrient reduction requirements.
These are just some of the cost effective options available through the trading program. While many facilities can achieve cost effective nutrient reductions through proper planning and operational changes, others may have to incur capital costs. A facility must prove that it has explored all of its options before deciding on infrastructure upgrades if it is to secure PennVEST support.
Kathleen A. McGinty
Secretary
Department of Environmental Protection
