The article first summarizes CWA requirements relevant to TMDLs and outlines elements of an effective trading program. It then examines the program recently established by the State of Connecticut to allow trading of nitrogen credits among sewage treatment plants on Long Island Sound to achieve an established TMDL, and the CWA issues presented. Finally, it gives a brief comparison to the program being designed for the Chesapeake Bay, for which no TMDL has been established. Current brief descriptive summaries of several often cited programs are appended.
Ann Powers, The Current Controversy Regarding TMDLs: Contemporary Perspectives "TMDLs and Pollutant Trading", 4 Vt. J. Envtl. L. 1 (2003), http://digitalcommons.pace.edu/lawfaculty/193/.