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The purpose of this paper is to identify critical elements of an effective trading program. Even if a substantial number of trades are made, the silver bullet will miss its target by a wide margin unless trading programs satisfy these minimal requirements. An equally likely and unfortunate scenario is that agricultural operators will decline the invitation to participate in trading programs, preferring to go about business as usual without sanctioning what they perceive to be quasi-regulation. Under either scenario, implementing unworkable and ineffective trading regimes will only serve to distract policymakers from making the hard choices necessary to ensure real and lasting gains. Trading is a means, not an end. If it fails, it should go. Bay states should be prepared with contingency plans should trading markets fail to perform as expected, including plans to implement mandatory programs for agricultural reductions to achieve the Bay TMDL if pollution reductions fall behind schedule.

The purpose of this paper is to identify critical elements of an effective trading program. Even if a substantial number of trades are made, the silver bullet will miss its target by a wide margin unless trading programs satisfy these minimal requirements. An equally likely and unfortunate scenario is that agricultural operators will decline the invitation to participate in trading programs, preferring to go about business as usual without sanctioning what they perceive to be quasi-regulation. Under either scenario, implementing unworkable and ineffective trading regimes will only serve to distract policymakers from making the hard choices necessary to ensure real and lasting gains. Trading is a means, not an end. If it fails, it should go. Bay states should be prepared with contingency plans should trading markets fail to perform as expected, including plans to implement mandatory programs for agricultural reductions to achieve the Bay TMDL if pollution reductions fall behind schedule.