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Agricultural & Applied Economics Association Theory and Practice of Pollution Credit Trading in Water Quality Management Author(s): Dana L. Hoag and Jennie S. Hughes-Popp Source: Review of Agricultural Economics, Vol. 19, No. 2 (Autumn - Winter, 1997), pp. 252- 262 Published by: Oxford University Press on behalf of Agricultural & Applied Economics Association Stable URL: http://www.jstor.org/stable/1349740 . Accessed: 28/06/2014 17:22 Your use of the JSTOR archive indicates your acceptance of the Terms & Conditions of Use, available at . http://www.jstor.org/page/info/about/policies/terms.jsp . JSTOR is a not-for-profit service that helps scholars, researchers, and students discover, use, and build upon a wide range of content in a trusted digital archive. We use information technology and tools to increase productivity and facilitate new forms of scholarship. For more information about JSTOR, please contact [email protected]. . Agricultural & Applied Economics Association and Oxford University Press are collaborating with JSTOR to digitize, preserve and extend access to Review of Agricultural Economics. http://www.jstor.org This content downloaded from 91.238.114.64 on Sat, 28 Jun 2014 17:22:46 PM All use subject to JSTOR Terms and Conditions

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Page 1: Theory and Practice of Pollution Credit Trading in Water Quality Management

Agricultural & Applied Economics Association

Theory and Practice of Pollution Credit Trading in Water Quality ManagementAuthor(s): Dana L. Hoag and Jennie S. Hughes-PoppSource: Review of Agricultural Economics, Vol. 19, No. 2 (Autumn - Winter, 1997), pp. 252-262Published by: Oxford University Press on behalf of Agricultural & Applied Economics AssociationStable URL: http://www.jstor.org/stable/1349740 .

Accessed: 28/06/2014 17:22

Your use of the JSTOR archive indicates your acceptance of the Terms & Conditions of Use, available at .http://www.jstor.org/page/info/about/policies/terms.jsp

.JSTOR is a not-for-profit service that helps scholars, researchers, and students discover, use, and build upon a wide range ofcontent in a trusted digital archive. We use information technology and tools to increase productivity and facilitate new formsof scholarship. For more information about JSTOR, please contact [email protected].

.

Agricultural & Applied Economics Association and Oxford University Press are collaborating with JSTOR todigitize, preserve and extend access to Review of Agricultural Economics.

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Page 2: Theory and Practice of Pollution Credit Trading in Water Quality Management

Review of Agricultural Economics-Volume 19, Number 2-Pages 252-262

Theory and Practice of Pollution Credit Trading in Water Quality Management

Dana L. Hoag and Jennie S. Hughes-Popp

We compare the theory of pollution credit trading and its application in the Tar-Pamlico nutri- ent-trading program in North Carolina. Five such programs exist in the United States, but trades are not being made. Six concepts for a successful program were identified from twenty- five years of literature on marketable permits, including: transaction costs, number and rela- tive discharge of participants, abatement costs, enforcement costs, trading ratio, and loading limits. Comparing these concepts to implementation highlighted several factors that encour- age or discourage trades. The program reduced transaction costs by trading at a fixed rate. However, this eliminated the marginal cost benefits crucial for efficient trading. In addition, safety-netted trade ratios raised trading costs. Allowable emissions exceed expected emission levels. Better monitoring and evaluation by economists will reveal where research or commu- nication must be improved and ensure that the fruits of our labors are not unharvested.

cademic institutions, including Land Grant colleges, are under increasing ressure to be accountable. One way to demonstrate accountability is to show

that research has been meaningfully implemented. But what if, for example, a policy fails to elicit expected or theoretical behavior? Would it prove the underly- ing theory inaccurate or incomplete? Not necessarily because information about scientific advances is scattered among many complex journal articles, making it difficult to create a comprehensive, applied implementation strategy. Neverthe- less, some implementation problems do result from poor or incomplete research. Therefore, it is important for researchers to summarize and communicate their results to practitioners and to monitor how research ideas are being implemented.

One example relevant to economics is marketable permits for agricultural pollutants in water. Researchers have contributed substantially to pollution credit trading literature, advancing theories that explain, among other things, how economic incentives, enforcement costs, and trading ratios can affect pollution credit market feasibility. We have successfully convinced others of our contri-

M Dana Hoag is professor, Department of Agricultural and Resource Economics, Colo- rado State University. M Jennie Hughes-Popp is research assistant, Department of Agricultural and Resource Economics, Colorado State University.

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Theory and Practice of Pollution Credit Trading in Water Quality Management 253

bution because at least five markets have developed in the United States. How- ever, despite our profession's perceived knowledge about the theoretical ben- efits of marketable permits, potential traders have not been inspired to make trades where markets developed. Trades are not being made in any of the five experimental markets.' We address the question: Why have economists been unable to put theory into practice in this case?

We compare the theory of pollution credit trading and its application in the Tar-Pamlico nutrient-trading program in North Carolina. The program is unique because the point-source dischargers involved are treated as a single unit con- cerning nutrient loading limits, monitoring, and enforcement. Although point- and nonpoint-source trading are typically the trading focus for policy (Letson, 1992b; U.S. Environmental Protection Agency (EPA) Office of Water), this single unit classification allows for point-point- and point-nonpoint-source trading possibilities. By comparing theory to practice, we hope to make implementa- tion more successful in the future.

Our paper begins with a review of the main principles associated with water pollution credit trading theory presented in a simplified manner to identify fac- tors that influence program feasibility. Then we give a description of the Tar- Pamlico program, organized to highlight the consistency of the program with theoretical constructs. We conclude the paper with an assessment of the program that compares theory to practice to identify reasons the program is not used.

Review of Pollution Credit Trading--What We Have Learned Already

Pollution credit trading is a market-based regulatory compliance alternative to traditional command-and-control (CAC) regulations. The market-based ap- proach can achieve the same aggregate level of pollution control as a CAC pro- gram, but permits dischargers to share the pollution control burden more effi- ciently. For water quality, pollution credit trading, in principle, allocates reduc- tions in pollutant loadings across point and nonpoint sources in a watershed using a least-cost criterion-allowing point sources with high abatement costs to trade pollution credits with nonpoint sources that have lower costs may reduce the total abatement costs of water quality improvement (Malik, Letson, and Crutchfield). Point-nonpoint-source trading gives publicly owned treatment works and industrial point sources an option of bringing agricultural and urban nonpoint sources under control instead of requiring more controls at point sources.

To assess the degree that implementation contributed to the lack of water mar- ket trades, we developed a summary of the guidance in economic literature. We will compare this summary in the following section to implementation of the Tar- Pamlico water market. Our review of more than twenty-five years of market-

1There is some confusion about whether trades have occurred. For example, in the North Carolina mar- ket, while firms have earned more than $800,000 in credits through agreements associated with program establishment and disbursed $650,000 for agricultural best management practices, no firm has needed to buy any credits. The source of confusion is whether activity so far indicates intention to trade.

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permit literature suggests six guidance factors that influence the success of a marketable permit-trading program for water quality:2

1. Transaction costs-Lower transaction costs increase trade potential. We can reduce transaction costs by specialization and agreements between polluters and the government.

2. Number and relative discharge of participants-Allowing point-point- and point-nonpoint-source trading increases the potential trade benefits. How- ever, too many or too few participants can make trading difficult and costly. Trading is feasible where there is a small number of large point sources and a fairly small number of large nonpoint sources.

3. Abatement costs-Participants gain when marginal abatement costs differ between traders. Trading costs are minimized when marginal control costs equalize across all dischargers.

4. Enforcement costs-When neither maximum emissions nor cost parameters are identical across firms, enforcement costs may be higher for a trading pro- gram compared with a CAC program.

5. Trading ratio-Uncertainty about pollution abatement, particularly for nonpoint polluters, leads to safety factors for trading, which increases the marginal costs of trades and decreases trading potential.

6. Loading limits--Loading levels must exceed regulation limits to stimulate trades.

Tar-Pamlico Nutrient Trading Program The Tar-Pamlico River Basin, classified as nutrient-sensitive waters (NSW),

covers fifty-four hundred one square miles and twenty-three hundred eight miles of freshwater streams in sixteen counties in North Carolina. The North Carolina Division of Environmental Management (DEM) developed a special nutrient management plan-the NSW Implementation Strategy (the strategy)-for that water body, which included a recommendation to reduce nitrogen and phospho- rus inputs from nonpoint sources with no increases in nitrogen and phosphorus levels from point sources. Environmentalists and point-source dischargers re- jected the recommendations because of insufficient or vague nutrient reduction targets and claims of excessive compliance costs and regulations imposed on point-source polluters (Levitas and Rader, North Carolina Dept. of Environment, Health, and Natural Resources). In light of these criticisms, an alternative plan was developed that contained a provision for nutrient credit trading.

2Pollution credit trading literature is rich. Our list summarizes some important findings for implementation. A more complete review, which details these concepts, can be found in the following literature: Apogee Research, Inc.; Atkinson and Tietenberg; Baumol and Oates; Carpentier and Bosch; Crutchfield, Letson, and Malik; Dales; Devlin and Grafton; Elmore, Jaksch, and Down- ing; Hahn and Noll; Jaksh and Niedzialkoswki; Letson 1992a, 1992b; Letson, Crutchfield, and Malik; Malik 1991, 1992; Malik, Larson, and Ribaudo; Malik, Letson, and Crutchfield; McGartland and Oates; Montgomery; National Commission on Water Quality; O'Neil et al.; Segerson; Shortle and Dunn; Taylor; Tietenberg; Xepapadeas, 1991, 1992.

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Abatement Strategy The DEM, North Carolina Environmental Defense Fund (EDF), Pamlico-Tar River

Foundation, and Tar-Pamlico Basin Association (a coalition of dischargers) adopted a two-phase plan to achieve nationally determined nutrient reduction goals. The parties agreed to finance development of an estuarine computer model for the basin, evaluate wastewater treatment plant engineering, and implement a nutrient reduction trading program during phase 1 (1990 to 1994). The model assesses the relative importance of nutrients from point and nonpoint sources and tracks and targets best management practices (BMPs) for reducing agricultural nonpoint-source discharges. In phase 2 (originally scheduled to begin in 1995), participants would implement a long-term, nutrient-reduction strategy based on the model results.

Nutrient Trading Details The proposed limits, based on concentration limits and projected flow for the

three facilities planning to expand before 1995, would have resulted in a nutrient reduction of 180,000 kg a year total nitrogen and 20,000 kg a year total phospho- rus. Thus, the combined 1994 reduction goal was set at 200,000 kg a year. By the end of 1994, it was estimated that the association's annual nutrient loading would reach 625,000 kg a year. The association would meet the total reduction through a series of stepped-down, annual loading limits, culminating in a nutrient load of 425,000 kg a year in 1994. Association members are jointly responsible for achiev- ing the total annual nutrient loading allowance, but members may allocate indi- vidual discharge levels among themselves. If the association could not meet the nutrient loading allowance, it could buy nutrient credits by contributing funds to the North Carolina Agricultural Cost Share Program (ACSP). ACSP is a volun- tary program that provides technical assistance and pays farmers a percentage of the average cost to implement agricultural BMPs. Association funds would supple- ment state cost-share money already allocated to the Tar-Pamlico Basin and fi- nance additional personnel for BMP review and identification.

Number and Relative Damages of Participants The Tar-Pamlico River Basin has one hundred forty-eight active, permitted

fresh- and saltwater dischargers. Eighteen are large dischargers (having a flow of more than one-half million gallons a day). The association, consisting of twelve publicly owned treatment works and one industry, collectively displaces 80% of the total discharge flow allowed in the river basin (Green).

Abatement Costs The total cost of the program through phase 1 is $2.72 million. The association

spent $1.13 million during phase 1 for the computer model, engineering evalua- tions, ACSP contributions, staff positions, and legal and administrative fees (Leyen). The U.S. EPA contributed the remaining funds.

Enforcement Costs If dischargers violate agreement terms, all existing dischargers (association

and nonassociation) must meet the nutrient effluent permit limits the DEM origi-

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nally proposed. If a localized water-quality problem arises, the DEM may re- quire individual point sources to remove nutrients. If a discharger agrees, the association receives credit toward its allowable annual nutrient loading, but if the plant does not meet its projected nutrient removal level, the DEM may add nutrient levels to the plant discharge permit. The association must then pay for the projected pollution credits plus a penalty charge of 10%.

Trading Ratio The Tar-Pamlico program uses a 3:1 ratio for cropland BMPs and a 2:1 ratio for

confined animal operations. The ratios were set at more than 1:1 because nonpoint- source loadings are less predictable over time and space and more random and less reliably controlled than point sources. Accounting for these trading ratios, the association must pay $56 a kg (based on average nonpoint-source control costs and administrative fees) of excess nutrient discharges (whether nitrogen or P) into the ACSP. All BMP pollution credits have a useful life of ten years unless cost-share program contracts with nonpoint sources provide for a longer period. If the nutrient reduction goal for the association were met entirely through BMPs, it was estimated to cost $11.2 million (200,000 kg x $56 a kg = $11.2 million).

Existing nonassociation dischargers expanding to one-half million gallons a day or more may participate in nutrient reduction trading based on a credit price of $62 a year to reduce the permit limitations the DEM proposed-2mg/1 total phosphorus and 4mg/1 (summer) plus 8mg/1 (winter) total nitrogen. New dis- chargers cannot participate in trade; they must implement nondischarge systems or be subjected to DEM-proposed permit limits.

Phase 1 Achievements and Phase 2 Provisions Engineering evaluations completed in 1991 indicated that most plants met the

phosphorus limit, but nitrogen levels typically exceeded limits originally pro- posed (U.S. EPA Office of Water and Office of Policy, Planning, and Evaluation). By implementing operational and minor capital improvements, the association collectively reduced discharges below proposed limits in 1991 and 1992 (Crutchfield, Letson, and Malik). By the end of phase 1 in December 1994, total nutrient loadings were reduced from 670,000 kg to less than 420,000 kg-5,000 kg less than the targeted level (Taylor et al.), which was an overall reduction of 37%.

The estuary model was also developed in phase 1. Model results indicated that a 45% reduction in 1991 nitrogen load levels would achieve water quality standard targets. Phosphorus limits were held constant at 1991 levels.

In December 1994, the Environmental Management Commission approved phase 2 of the plan, which acknowledged the 45% nitrogen load reduction target, but because of uncertainty that current BMP and point-source technologies could achieve this goal, a 30% reduction target was set as an interim goal (North Caro- lina Div. of Environmental Mgmt. Water Quality Section). Only 8% of the 30% reduction was allocated to point sources. Nonpoint sources were accountable for the remaining 92% without knowledge of how the goal was to be accomplished.

Groups, including the North Carolina Environmental Defense Fund, protested the phase 2 proposal on multiple accounts, including a lack of procedures for

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nonpoint-source nutrient reductions and the conservative interim overall reduc- tion goal for point and nonpoint sources (Radar, Harrison, and Rowles). In De- cember 1995, the DEM announced a nutrient management plan for nonpoint sources that preserved the 30% reduction target for the first years of phase 2, but allowed for target adjustments in future years, pending results from an improved estuary model (North Carolina Div. of Environmental Mgmt. Water Quality Sec- tion). In addition, the $56 a kg trade rate for excess discharge was reduced to $29 a kg during phase 2 talks. As of August 1997, the EDF has refused to sign phase 2. While delays continue, the program works toward a suitable solution for all.

Program Assessment A comparison of our list of research guidance for a marketable permit pro-

gram and the implementation of the Tar-Pamlico River Basin program revealed that, in some ways, the program used effective organizational plans to make trades more attractive. For example, as suggested by factor one in the guidance factor list, the transaction costs for trades were greatly reduced. The reduction was accomplished by forming a point-source polluter association, which represents a small number of polluters with considerable discharges. The association can trade as a group with an established program that represents farmers, the ACSP, at predetermined rate of $56 a kg. Members paid most of the transaction costs when they established the association and when they paid more than $1 million for phase 1. The only remaining transaction costs to firms is the effort and paper- work to buy the credits. The farmer organization incurs the costs to implement BMPs, and there is no enforcement mechanism to assure implementation.

As suggested by guidance factor two, the administrative structure also has notable implications that make trades more attractive. Point sources can trade with each other or with nonpoint sources. In addition, point-source contributors pay for pollution control, but farmers are paid for pollution prevention. Aside from questions about equity, this lowers the transaction costs for farmers and the association by making it more simple for buyers and sellers to establish trades.

Despite the program's positive attributes, substantial deviations existed from an optimal design suggested by research. Contrary to guidance factor three, the pro- gram uses average cost prices, instead of margin pricing. In addition, as suggested by guidance factor five, the trading ratio was set at 3:1, or 2:1 for some situations. Therefore, farmers' nutrient reductions may have been priced higher than the asso- ciation was willing to pay. However, point-source polluters did not trade among themselves, which the trading ratio and average cost pricing cannot explain.

Finally, the responsibility for future reductions weighs heavily on the side of nonpoint sources. Contrary to guidance factor six, the total nitrogen and phos- phorus loading limits the DEM set for the association allow them to increase current loadings. These two DEM decisions may affect the point-source pollut- ers' willingness to finance nonpoint-source controls.

Administrative Structure The problem of establishing an appropriate market value for a pollution credit

is not unique to nutrient trading programs. The Environmental Protection

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Agency's Emission Trading Program has problems it is trying to eliminate by centralizing buying and selling interest in the new cash market and by establish- ing a market for futures contracts and options in sulfur dioxide emissions allow- ances (Rosenzweig and Villarreal). These exchanges are unrealistic for nutrient pollution credit trading for the following reasons.

1. The geographic size of a typical nutrient trading market is limited. 2. Property rights differ between buyers and sellers. Point source dischargers

are legally required to control nutrient discharges while farmers are not. A market with marginal cost pricing is difficult to set up if buyers and sellers are few and their property rights are different.

Property rights can hamper trades in two ways:

1. They create enforcement problems. Pollution credit trading theory is based on self-regulation among participants with equal responsibility. However, the association is not involved in implementing nonpoint-source controls beyond providing nutrient reduction funds to the cost-share program. Tar- geting and implementing BMPs is left to soil and water conservation agen- cies. The arrangement relieves the association from risk of noncompliance if BMPs are unsuccessful. However, individual members of the association are at risk of more stringent effluent limits, regardless of their participation in the association and monetary contributions to the BMP fund (U.S. EPA Office of Water and Office of Policy, Planning, and Evaluation).

2. Because farmers are not required to cut pollution levels, they may be reluc- tant to accept trades because they may construe acceptance as admitting they are polluters. Although North Carolina has tried to explain that support is from the trading program, most farmers do not distinguish this support from existing programs that help farmers adopt BMPs (Ranells). Firms also may be reluctant to transfer control to outsiders if the compliance costs are low because it could convey sensitive information or focus public attention on their pollution levels. This is a particular problem in the Tar-Pamlico market.

Potential Trade Gains Tar-Pamlico is a small number of large point-source polluters (the association)

and a small number of large nonpoint-source polluters (farmers represented by the ACSP). Combining point-point- and point-nonpoint trades results in a more cost-effective allocation than point-nonpoint trading alone. Given the relative discharge levels and numbers of point-nonpoint-source contributors, the greater the number of trading participants in Tar-Pamlico, the more opportunities to trade, and the lower the total cost for an abatement level.

Program Pricing One of the most important limitations of the Tar-Pamlico nutrient trading pro-

gram is that the $56 a kg (and later $29 a kg) trade rate for nutrients is based on an average cost for the region, not a marginal cost. Consider the example in fig- ure 1. Suppose the association's marginal abatement cost is PS and the marginal

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Figure 1. Effect when average cost pricing (ACP) is set below the efficient trading price (EFT)

MC ($) 20

PS 15

10 NPS A F

MB C

(ETP)6.66 o o (ACP) 5 D

PS -> 0 3 6 9 12 15 15 12 9 6 3 0 <-NPS Units of Nutrients Removed

cost to the nonpoint source is NPS. With ACP, the nutrient credit price is $5 a kg (below the equilibrium level of $6.66). At ACP, each source would clean up 7.5 units of nutrients. The nonpoint source would not want to sell more than 7.5 units because the marginal cost of doing so is more than $5. Assume, for simplic- ity, the price of a trade at 7.5 units is $6.66 (it would fall between $5 and $10). The total cost to PS increases by an amount represented by area ABF and decreases by BCDE. The loss in producer surplus to the farmer is CDEF. The area BCDE is a gain to NPS and a loss to PS and, thus, cancels out. The net ACP cost is AEF.

A second limitation of the program cost is the trading ratio. Setting the trading ratio at a level greater than 1:1 reduces the cost-effectiveness of nonpoint-source controls and thus discourages trade from the perspective of point source dis- chargers because each credit becomes more expensive as the ratio increases.

Loading Limits Willingness to trade depends greatly on the need to reduce pollution, which is

a function of DEM-set limits. Phase 2 sets nitrogen limits for the association at 405,256 kg and phosphorus limits at 69,744 (North Carolina Div. of Environmen- tal Mgmt. Water Quality Section). These figures are about 86,000 kg and 15,000 kg higher, respectively, than the 1994 loading levels. Any point-point-source trading

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may be completed at a marginal cost near zero when the nutrient loading allow- ance is above the actual loading. Until the marginal cost of point-source reduc- tions exceeds the price of a nutrient credit, there is neither economic incentive nor need to conduct point-point- or point-nonpoint-source trades.

Conclusions Federal water pollution control legislation objectives have not been met, largely

because of nonpoint-source contributions. Recent legislation has tried to deal with the problem, but how nonpoint controls would be imposed and who would pay for them is a subject of debate (Libby). A promising method of approaching nonpoint- source control is to use market forces, such as nutrient credit trading programs.

Economists have supported the idea of using market forces to protect the environ- ment for twenty-five years. Only recently, however, has the broader policy commu- nity begun to regard market instruments favorably. This increased attention on nu- trient trading programs demands careful study of existing nutrient trading programs, such as the Tar-Pamlico program. Dischargers have not traded in water pollution credit trading programs. We could perceive this as proof that marketable permits do not work when institutional and implementation problems could be at fault. This fear has already been realized in the North Carolina's Neuse region where local offi- cials have hesitated to implement an already established marketable permit pro- gram because of failures in the Tar-Pamlico program (anonymous source).

Comparing the Tar-Pamlico program with pollution-credit-trading market theory identifies several factors that encourage or discourage trades. On the posi- tive side, the program features many elements of an optimal design. Most nota- bly, the program reduced transaction costs at the margin by creating a manage- ment unit to administer trades at a fixed rate. However, a fixed price, based on average cost, eliminated the marginal cost benefits that are crucial for efficient trading. In addition, trading costs were raised by the safety net trade ratios of at least 2:1. Finally, under phase 2 agreements, allowable nitrogen and phosphorus loadings for the association may increase well above expected emission levels, thereby eliminating the association from the group of trade participants. Trading in the Tar-Pamlico Basin may be seriously hindered, or even rendered impos- sible, without this group of point-source dischargers of substantial size.

During phase 1, the Tar-Pamlico program successfully implemented a market- based approach that is administratively simple and politically acceptable and has taken important steps toward achieving the theoretical level of cost-effective- ness. State implementation of a trading program in phase 2, however, is ham- pered by two factors. First, controversy surrounds the DEM's decision to allo- cate the bulk of the reduction responsibility to nonpoint-source polluters. The point-source group (the Association) may increase total nitrogen and phospho- rus levels under the current plan. This may eliminate the incentive for the asso- ciation to pay for nonpoint-source cleanup-which was the original goal of the Tar-Pamlico program. A second and related factor is that there is a lack of gener- ally applicable models or data linking land use practices to water quality effects. The results of the estuarine model and the recently released nutrient manage- ment plan for nonpoint-source polluters provide a starting point for achieving nutrient reduction targets, but are not sufficient alone.

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Putting theory into practice requires compromise between the desire to promote cost-effectiveness and to have an administratively simple, politically acceptable pro- gram. Our cursory review indicates that reassignment of the reduction responsibili- ties between point-nonpoint-source polluters coupled with improved information about nutrient-removal capabilities of BMPs may allow for a more cost-effective trad- ing ratio and increase the number of trading participants. In addition, pricing trades competitively at the margin would increase trade attractiveness.

Economists may be correct in attributing the failure of trading programs to improper implementation. But lessons from the implementation can also improve theory. For example, the perceived intangible costs of trades (such as public im- age) to both sides may be high, possibly outweighing any advances that might be changed in implementation strategy. Therefore, researchers may want to focus their attention on reducing these intangibles or on developing strategies for trad- ers to manage them. In the end, it is in the economists' interest to summarize and communicate research results clearly and to monitor and evaluate how imple- mentation is proceeding. Better monitoring and evaluation will also reveal where research needs to be improved. We leave the reader with two questions: How well do economists accomplish this task? How can we improve results?

Acknowledgments The authors thank Doug Radar of the Environmental Defense Fund and our reviewers for their

assistance in preparing this manuscript.

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