“…Water quality trading programs are a particular application of environmental market principles that has received considerable theoretical, policy, and rhetorical attention in the water resources and environmental economics literature [e.g., Dales , ; Montgomery , ; Eheart , ; Eheart et al ., ; Lence et al ., ; Riggs , ; Hung and Shaw , ; Morgan and Wolverton , ; Wainger , ]. Water quality markets are often advocated as a means to reduce the costs of achieving goals of the Clean Water Act, particularly nutrient control requirements [ Sado et al ., ]. Nutrient pollution is regulated by several statutes, the most relevant of which is the National Pollutant Discharge Elimination System (NPDES, 40 CFR 122) through which the Environmental Protection Agency (EPA) issues a permit that authorizes a regulated point source (e.g., wastewater treatment plant, WWTP) to discharge some maximum allowable amount of a pollutant.…”