For any trading program to be accepted, the local limits to which it applies must be technically-based and defensible. In addition, the POTW's credibility in maintaining a strong compliance and enforcement program is an important factor in establishing a trading program. This credibility serves two purposes. First, it serves to assure the public that the POTW can be trusted to effectively administer a trading program so that potential environmental benefits will be achieved. Second, it sends a message to industrial users that they will be accountable for meeting the terms of their trading agreements.
Timing can be important in establishing trading programs.
The Pilot Team concluded that it is most productive for the concept of trading to be introduced to the industrial user community at the same time new local pretreatment limits are being developed or existing ones are being revised. This allows potential trading partners to begin discussions early on in the process of planning how they will meet the new or revised limits. Early discussions can improve their ability to develop and implement more economical and efficient approaches to treatment, fully considering the potential of a coordinated approach to pretreatment among two or more facilities. Lack of information and uncertainty represent significant barriers to establishing trades. In trying to generate interest in trading among facilities discharging to PVSC, the Pilot Team noted that facilities had little, if any, knowledge of what was involved in trading.