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Massachusetts Estuary Project(MEP) <br /> Linked Watershed EmbaymentModel Peer Review <br /> concentrations,the attainment of the current criteria and the presumptive attaimnent of eelgra'ss and other <br /> biological indicator endpoints should be a focus of a structured adaptive management program within the <br /> CWMPs. <br /> In the EPA approval letter,and in MDEP's construct of the TMDL,there appears to be room for <br /> flexibility and a willingness to work with the towns to develop viable implementation plans. Because of <br /> the cost and time that will be required to implement infrastructure improvements of this scale, there is a <br /> likelihood of phasing that would provide an opportunity for structured adaptive management program. A <br /> potential management outcome already identified in CWMPs is constructing sewers and centralized <br /> wastewater treatment facilities. Those actions would technically shift the nitrogen load from a nonpoint <br /> source load allocation to a point source wasteload allocation within the TMDL. That reallocation requires <br /> an update of the adopted TMDL, and reapproval by EPA,which would also provide an opportunity to <br /> apply the reassessment and adjustments that are learned in an adaptive management framework. <br /> A watershed/adaptive management approach could serve to more equitably distribute nitrogen reductions <br /> and their implementation costs among the contributing watershed sources. Market mechanisms,such as <br /> nitrogen trading,may also facilitate management and lower costs. However,the size and character of <br /> Cape Cod's watersheds,the high levels of nitrogen removal required to meet TMDLs, and the limited <br /> diversity of sources and management options may be obstacles to watershed market mechanisms,like <br /> trading. Small watersheds with few sources responsible for most or all of the impairment have low <br /> market appeal because options for trading are so limited. Hence,nitrogen credits would likely be a scarce <br /> commodity in many Cape Cod watersheds and would become even more limited as attainment of the final <br /> TMDL nears. <br /> Nitrogen trading may have a role in accelerating progress in the early phases of management,providing a <br /> mechanism for implementing the most cost-effective actions first. Initially,nitrogen management costs <br /> on Cape Cod maybe low compared to the early,projected water quality benefits,i.e., cost-to-benefit <br /> ratios would be lower. Typically,marginal costs will increase with time, especially if attaining the final <br /> management target requires intensive application of a high level of costly technology. At the point where <br /> the"knee of the curve"for cost-to-benefit ratios is passed,trading may no longer provide an incentive to <br /> implement, yielding to a final management structure such as a collective utility with an equitable cost <br /> share among residents. More detailed study on market options,utilities and other funding mechanisms is <br /> recommended, expanding upon the Cape Cod Commission(2009)initial exploration of trading and other <br /> options. <br /> December 30,2011 <br /> 27 <br />