Hall & Associates has led state, regional and nationwide efforts to promote the use of more cost effective pollution reduction measures to address areawide pollution impacts. Use of coalitions is often a more cost effective and politically powerful means for seeking regulatory program modification. The firm has used watershed coalitions to develop detailed scientific assessments to assist in deriving appropriate point and non-point pollution reduction measures. The formation of the Tar Pamlico Basin Association in 1989 provided the platform to develop one of the nation's first pollution credits trading programs and saved millions in municipal expenditures. That program formed the basic model for EPA’s eventual pollution credits trading policies.
Since establishing this groundbreaking approach the firm has assisted in developing several other point/nonpoint trading programs (Minnesota River), Delaware (point/non-point trading) and pretreatment trading (Peachtree City, GA.) Presently the firm is managing numerous coalition efforts, including activities in Pennsylvania, Minnesota, Kansas, New Jersey and Iowa. The firm is also managing a nationwide coalition to address proper development of nutrient standards for streams and to obtain EPA clarification of appropriate technologies to address peak flow processing at POTWs.
Pollution credits trading is an increasingly useful option to achieve environmental requirements with lower capital expenditures. Mr. Hall was the lead author on a manual for developing trading groups and programs to achieve CWA requirements (link). Large system requirements (such as the Gulf of Mexico with predominant agricultural components) are excellent candidates for using such approaches. We are in the process of developing the Upper Mississippi River Watershed Trading Coalition, which will promote point/non-point trading to address nitrogen loadings from municipal sources in Iowa, Minnesota, Illinois, Wisconsin and Missouri.