Policy Integrity submitted a letter to the EPA on its upcoming rulemaking regarding water quality permitting. The letter makes recommendations on improving the efficiency of EPA’s implementation and enforcement of the Clean Water Act.
Our suggestions include expanding the scope of water quality trading. Steps to achieve this include reevaluating any remaining legal barriers to existing trading programs; encouraging auctioning as an option for state regulators to help build trading programs; and facilitating access to information relevant to trading, monitoring, and enforcement.