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Credit Trading Process

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TRYING TO FIND CREDITS?

If your facility is in need of credits to meet permit cap load requirements, view the 2018 Verified Nitrogen Credits (PDF) and 2018 Verified Phosphorus Credits (PDF) lists to see what credits are available and who has them. These lists are updated daily when changes occur.

Check out our Nutrient Credit Trade Negotiation and Register Your Nutrient Credit Trade at a glance summaries to find out how to buy credits.

Need to contact a credit generator on the verified credits lists?
Check out our Certified Generator Contact Information list.

HAVE CREDITS TO SELL?

Certified NonPoint Sources
If your verification plan calculations indicate that you generated credits, you can verify those credits and sell them.
Check out our Verify Your Nutrient Credits (Nonpoint Source), Nutrient Credit Trade Negotiation, and Register Your Nutrient Credit Trade at a glance summaries to find out how to sell credits.

Certified Point Sources
If your Annual Chesapeake Bay Spreadsheet (Excel) indicates that you have generated credits after all data has been entered (after September 30th), you can verify those credits and sell them.
Check out our Verify Your Nutrient Credits (Point Source), Nutrient Credit Trade Negotiation, and Register Your Nutrient Credit Trade at a glance summaries to find out how to sell credits.

Not sure if you are Certified?
Check out our Certified Generator Certification IDs list to see if you are certified and get your current certification ID.

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Process Overview

The PA Nutrient Credit Trading Program (Program) involves three steps: certification, verification, and registration.

The three steps of the Program must occur in that order. Credits must be certified, verified, and then registered by the PA Dept. of Environmental Protection (DEP) Program before they can be applied to NPDES permit effluent limits.

The Program request submission process involves a thorough review of each submission before approval is granted. Details of this process can be found in the Certification, Verification, and Registration sections below.

Lists of current and past approved certifications, verifications, and registrations can be found on the Nutrient Credit Reports page.

Other resources such as forms, instructions, calculation spreadsheets, and links to related documents and websites can be found on the Trading Resources page.


Deadlines

Request submissions are logged in and processed in the order they are received. See the Credit Trading Process page for more details on the request submission process.

To ensure processing can be completed in time for credits to be sold and applied to permit limits no later than the November 28th Chesapeake Bay annual DMR submission deadline, submit complete requests for compliance year 2018 (10/1/17 – 9/30/18) electronically to the Program email (RA-EPPANUTRIENTTRAD@pa.gov) by the following dates:

  • Certification Requests: Tuesday, April 3, 2018
  • Verification Requests: Friday, November 9, 2018
  • Registration Requests: Monday, November 19, 2018
Requests for Compliance Year 2018 will be accepted and processed until the end of the truing period, November 28, 2018.

Credit Certification

DEP's certification of credit generation is required for credits to be generated.

Certification means approval has been given by DEP for a pollutant reduction activity to generate credits. The approved credit generator may or may not generate credits during a compliance year. Generated credits must be verified by DEP before they may be sold and registered to an NPDES permit.

All certification requests are logged in, reviewed for administrative completeness, published in the Pa. Bulletin for a 30-day public comment period, and then reviewed for technical accuracy. Once DEP approves a certification request, that approval notice is published in the Pa. Bulletin.

Point sources (PS) are covered under a mass certification and do not need to submit a separate certification request. However, because this new mass certification is in effect starting CY 2018, all PS intending to verify credits will need to contact the Nutrient Trading Program to be assigned a new certification ID.

Nonpoint Source (NPS) credit generators requesting DEP certification must submit their request including the Nutrient Credit Nonpoint Source Certification Request Form (3830-FM-BCW0503) (form instructions may be found on the Trading Resources page) and a verification plan describing how credit generation will be verified. A verification plan is a written description of what will be done (BMP descriptions, etc.), how it will be done (calculation methodology, etc.), when it will be done, and what documents will be submitted to verify credit generation.

A summary of what a PS and NPS credit generator must do to generate credits can be found on the Credit Generation Requirements page. Further details on these requirements can be found in the Phase 2 Chesapeake Watershed Implementation Plan (Phase 2 WIP) Nutrient Trading Supplement (PDF).

In addition, the nutrient trading program regulations (25 Pa. Code § 96.8) entitled "Use of offsets and tradable credits from pollution reduction activities in the Chesapeake Bay Watershed," specify procedural requirements to ensure that credits are calculated correctly and accomplish pollutant reductions.

POINT SOURCES (PS)

To ensure processing can be completed in time for credits to be sold and applied to permit limits no later than the November 28th Chesapeake Bay annual DMR submission deadline, submit complete certification requests electronically to the Program email (EPPANutrientTrad@pa.gov) by Tuesday, April 3, 2018.

On October 3, 2015, the Department of Environmental Protection (DEP) published notice in the Pennsylvania Bulletin of a mass certification of credits by eligible point sources with assigned cap loads.

Effective October 1, 2015, to be eligible to generate credits for sale, all Significant Sewage PS discharges within the Chesapeake Bay Watershed with annual mass load effluent limitations ("cap loads") in an NPDES permit listed in the Point Source Credit Generators Table (PDF)(Table 7.1 of the Phase 2 WIP Wastewater Supplement) must demonstrate treated effluent concentrations below 6 mg/L Total Nitrogen (TN) and 0.8 mg/L Total Phosphorus (TP) (i.e. "baseline concentrations"), in accord with the procedures for credit verification described in the Phase 2 WIP Nutrient Trading Supplement (PDF).

Where effluent limitations for TN and/or TP are established in Part A of the permit for reasons other than the cap load assigned for protection of the Chesapeake Bay ("local nutrient limits"), the permittee is eligible to generate Credits when the permittee demonstrates that these effluent limitations have been achieved in accord with the procedures described in the Phase 2 WIP Nutrient Trading Supplement (PDF).

The individual cap loads, amount of offsets, and delivery ratios for each significant permitted point source facility are also listed in the Point Source Credit Generators Table (PDF).

Effective October 1, 2015 (Compliance Year 2016), the calculation of credits must be made using new formulas described in the Phase 2 WIP Nutrient Trading Supplement (PDF).

In addition:

  • To generate credits, facilities must be able to demonstrate that they are in compliance with their NPDES permit.
  • The total amount of credits the facility is certified to generate cannot exceed its permitted cap load.
  • This PS certification will expire September 30, 2017. Between October 1, 2015, and September 30, 2017, PS will not be required to submit requests for certification of credits to DEP. However, requests for the verification and registration of credits for compliance purposes will still be required.

NONPOINT SOURCES (NPS)

To ensure processing can be completed in time for credits to be sold and applied to permit limits no later than the November 28th Chesapeake Bay annual DMR submission deadline, submit complete certification requests electronically to the Program email (EPPANutrientTrad@pa.gov) by Tuesday, April 3, 2018.

A person who wishes to generate credits from a NPS pollutant reduction activity must submit a certification request using the DEP Nutrient Credit Nonpoint Source Certification Request form (3830-FM-BCW0503) (form instructions may be found on the Trading Resources page).

  • The calculation of credits for NPS Best Management Practices (BMPs) should be done using the Nonpoint Source Nitrogen Calculation Spreadsheet (Excel), and/or the Nonpoint Source Phosphorus Calculation Spreadsheet (Excel) provided by DEP. At this time, these spreadsheets should not be used to calculate reductions generated from the carbon sequestration BMP and the water control structure BMP. Note: the 3:1 uncertainty ratio is not included in the automatic calculations and must still be applied to the credit values calculated in these spreadsheets.
  • The calculation of credits for poultry litter export should use the Poultry Litter Export Calculation Spreadsheet (Excel) provided by DEP.
  • The Nutrient Trading GIS App may be used to identify surface waters and their basin, Ch. 93 water quality uses, and impairments (required information on the certification request form).

Certification requests must include a verification plan. This verification plan should describe the methods that will be used for credit verification, including a description of documentation that will be provided, sufficient to allow verification that the pollutant reduction activity in the certification was properly implemented during the applicable compliance period. The verification plan must include self-verification by the person responsible for implementing the pollutant reduction activity or third-party verification, and is subject to approval by DEP.

CERTIFICATION NOTICE PROCESS

To ensure processing can be completed in time for credits to be sold and applied to permit limits no later than the November 28th Chesapeake Bay annual DMR submission deadline, submit complete certification requests electronically to the Program email (EPPANutrientTrad@pa.gov) by Tuesday, April 3, 2018.

DEP will publish notice of receipt of a administratively complete certification request in the Pennsylvania Bulletin for an informal 30-day public comment period. During this 30-day period, a team will review the request for technical acceptability and consistency with program requirements.

Certification serves as DEP's final determination of the amount of credits that the pollutant reduction activity may generate.

If DEP certifies a pollutant reduction activity, DEP will publish final notice of the action in the Pennsylvania Bulletin, which begins a 30-day appeal period.


Credit Verification

DEP verification of credit generation is required for credits to be sold.

Verification means approval has been given by DEP that a generator has used their approved verification plan to demonstrate that a pollutant reduction activity generated credits during the compliance year. Verified credits may be sold.

To ensure processing can be completed in time for credits to be sold and applied to permit limits no later than the November 28th Chesapeake Bay annual DMR submission deadline, submit complete verification requests for compliance year 2018 (10/1/17 – 9/30/18) electronically to the Program email (EPPANutrientTrad@pa.gov) by Friday, November 9, 2018.

Verification requests from PS and NPS are logged in, reviewed for administrative completeness, and then reviewed for technical accuracy. The technical review may involve verification activities such as monitoring, inspecting sites, and performing compliance audits.

PS credit generators requesting DEP credit verification must submit their request using the DEP Nutrient Credit Point Source Verification Request form (3830-FM-BCW0506b) (form instructions may be found on the Trading Resources page) and Annual Chesapeake Bay Spreadsheet (Excel), which documents nutrient reductions based on sampling results and calculations.

NPS credit generators requesting DEP credit verification must submit their request using the DEP Nutrient Credit Nonpoint Source Verification Request form (3830-FM-BCW0506a) (form instructions may be found on the Trading Resources page) and documentation of pollutant reduction activity implementation.

Credit verification must demonstrate that the pollutant reduction activity was implemented as described in the verification plan submitted with the certification application, and that all program requirements are met. The calculation of credits generated from pollutant reduction activities should be done using the same calculation method as contained in the DEP-approved verification plan.


Credit Registration

DEP registration of credits is required for credit trading to occur and for credits to be applied toward permit cap loads or resold.

Registration means approval has been given by DEP for a sale of credits upon review of an agreement between a buyer and seller. Registered credits may be applied to meet NPDES permit cap load requirements or resold.

Credits must be certified and verified before being traded and registered. Registration is DEP's accounting mechanism to track verified credits before they are used to comply with the NPDES permit effluent limits.

Trades can take place through direct communication between credit buyers and credit generators, or the participating parties may use PENNVEST nutrient credit auctions to buy or sell credits. Credits bought/sold through PENNVEST auctions must still go through all three steps in the DEP Nutrient Trading Program. Details on how to participate in these auctions can be found on the PENNVEST IHS Markit Auction website.

To ensure processing can be completed in time for credits to be applied to permit limits no later than the November 28th Chesapeake Bay annual DMR submission deadline, submit complete registration requests for compliance year 2018 (10/1/17 – 9/30/18) electronically to the Program email (EPPANutrientTrad@pa.gov) by Monday, November 19, 2018.

Registration requests from point and nonpoint sources are logged in, reviewed for administrative completeness, and then reviewed for technical accuracy.

Entities wanting to register the buying or selling of credits with DEP must submit their request using the Nutrient Credit Registration Request form (form instructions may be found on the Trading Resources page). A copy of the valid contract between buyer and seller must accompany the Registration Request Form. Traded credits must be documented in a valid contract for their purchase prior to registration.


Contact Us

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For further information, contact:

Nutrient Trading
Department of Environmental Protection
Bureau of Clean Water – Division of Operations
RCSOB, P.O. Box 8774
Harrisburg, PA 17105
(717) 787-6744
RA-EPPANutrientTrad@pa.gov

The information outlined on this website is intended to supplement existing requirements. Nothing on this site shall affect regulatory requirements. The information herein is not an adjudication or a regulation. There is no intent on the part of DEP to give the information on this website that weight or deference. This information establishes the framework, within which DEP will exercise its administrative discretion in the future. DEP reserves the discretion to deviate from this statement if circumstances warrant.