Environmental and Resource Economics 15: 27–38, 2000.

27
© 2000 Kluwer Academic Publishers. Printed in the Netherlands.

Tradable Discharge Permit System for Water

Pollution
Case of the Upper Nanpan River of China?

WENDONG TAO1, BO ZHOU1, WILLIAM F. BARRON2 and WEIMIN YANG1

1 Yunnan Institute of Environmental Sciences, 23 Wang Jia Ba, Kunming 650034, China
(E-mail: wtao@public.km.yn.cn); 2 Centre of Urban Planning & Environmental Management,
The University of Hong Kong

Accepted 5 November 1998

Abstract. A discharge permit system for water pollution of the upper Nanpan River has been tested
since 1992. This paper proposed the shift of the current non-tradable permits to tradable permits
to attain the same pollution reduction targets at a lower cost. It was found that this river appeared
good for trading. A pilot trading program for point sources was then recommended to a smaller
trading zone. There would be ten potential trades for chemical oxygen demand discharge, gaining
an annual cost-saving of Chinese Yuan 2.4 million, or saving 18.4% of the total annual cost to attain
the reduction target without trading. The marginal pollution reduction cost was estimated at Chinese
Yuan 959 for one kilogram chemical oxygen demand per day. Meanwhile, ‘without trading’ and
‘with trading’ scenarios would bring about 900.9 kg/day and 51.5 kg/day of redundant reduction
respectively. The net annual benefit arising from trading, about Chinese Yuan 1.6 million, would still
be significant. At last, the study recommended that compliance monitoring and executing institution
requirements be kept in mind while designing the program. An information system needs to be
established to provide potential participants relevant information. The method of permit allocation
and lifespan of permits should also be addressed later.

Key words: permit system, point/point source trading, pollution reduction cost

Abbreviations: BOD – biochemical oxygen demand; CNY – Chinese Yuan; COD – chemical oxygen
demand; NH3 -N – ammonia nitrogen; TDP – tradable discharge permits; TMLA – total maximum
load allowable.
JEL classification: I118, D45, D61, D62

Introduction
The upper Nanpan River in Qujing City, Yunnan Province of China was chosen
for an analysis of the potential benefits of tradable water pollution permit system.
Experience and data from the existing non-tradable permit system, along with
further analysis carried out for this study was used to estimate pollution reduction

? This paper was presented at the 3rd Biennial Pacific Rim Allied Economic Organization
Conference, January 13–18, 1998, Bangkok.
28 WENDONG TAO ET AL.

Figure 1. Sketch of the Upper Nanpan River Catchment.

costs for each of the fourteen potential participants in the trading program. Differ-
ence in the reduction cost functions among the likely participants was used to
estimate the potential for profitable trades. The analysis indicated that trading of
permits for COD discharge could significantly reduce overall cost of pollution
reduction.
The upper Nanpan River in Qujing City is 122 km long with a drainage area of
2486 km2 . Based on the distribution of the point pollution sources, the mainstream
of the river is divided into five subzones by the nodes of the Huashan reservoir,
Xiping Town, the Qujing urban center, Yuezhou Town, and the Xiangshui reservoir
(see Figure 1).
The mainstream is designated for industrial and agricultural uses. However, the
instream water is presently so polluted that it is not suitable for any use. The crucial
pollutants are COD, BOD and NH3 -N. About 30 state-owned industrial polluters
are concentrated along the river in Huashan, Xiping, Yuezhou and the urban center.
In addition to the large industrial discharges, municipal wastewater from Xiping
Town and Qujing urban center also add considerable pollutant loading. Finally,
nonpoint sources further add to the pollutant loads, though the industrial and muni-
cipal discharges dominate today and are expected to continue to do so. The total
pollutant loads into the river are and are expected to remain much higher than the
TMLAs.
With increasing amounts of pollutant loads produced due to accelerated
economic growth, water quality objectives became impossible to attain by enforc-
DISCHARGE PERMIT SYSTEM FOR WATER POLLUTION 29

ing the national concentration-based discharge standard (OLGTPS 1993). There-

fore, a non-tradable permit system for water pollution of the upper Nanpan River
downstream of the Huashan reservoir was developed in 1992. It was designed
to control effluent discharge of point sources. Initial waste allocation of the
TMLAs adopted ‘grandfathering’, an allocation of permits to existing sources
commonly based on historical discharge levels. The current permit system appor-
tioned the TMLAs among the 30 major existing industrial dischargers and the
municipal sources. The deadlines for meeting the permit limits (compliance dead-
line, permitted discharge loading, etc.) were delineated specific to each permit
holder. The farthest compliance deadline is December 1999. However, in practice,
some dischargers had not yet made their effluent meet the permit limits by the
deadlines due to weak enforcement.
TDP is one type of market-based approaches to environmental protection long
advocated by economists. By providing flexibility to the dischargers, the TDP
system is potentially more cost-effective than a non-tradable permit system for
attaining a specific pollution reduction target. The regulatory/administrative frame-
work to institute a TDP system for water pollution is yet to be developed in China.
However, several cases of permit trades have occurred in Shanghai, Beijing, and
Zhejiang (Xu 1996). The key to the application of TDP in China is disseminat-
ing the TDP concept to environmental managers and demonstrating to them its
successful application (Tao 1996).
The current non-tradable permit system in the upper Nanpan River lays a good
foundation for a shift to a tradable one in terms of institutional capacity for manage-
ment and monitoring and by providing data about dischargers and their associated
environmental impacts (Tao 1995). The present study evaluates the applicability of
a point/point source trading system to the upper Nanpan River and estimates the
potential cost savings relative to the non-trading system.

Status of Upper Nanpan River Regarding Necessary Conditions for Trading

The trading will not be applicable to all watersheds or river segments. A number of
economic, technical, and institutional factors must be considered when evaluating
the applicability of a trading program to a specific water system. From the case
studies and the Fox River experience in the USA, several conditions appear to
be necessary in order for a trading program to be effective (USEPA 1992a, b).
The conditions are: (1) that there is an identifiable catchment, (2) that there are
significant and sufficient point sources, (3) that the TMLAs have been established,
(4) that there are accurate and sufficient data, (5) that the concentration-based
discharge limitations must be met at a minimum, (6) that there is a large difference
in treatment costs across dischargers, (7) that the TDP system be accepted by the
community and regulatory agency, (8) that an adequate institutional structure be
in place, and (9) that there be adequate compliance incentives and enforcement
mechanisms.
30 WENDONG TAO ET AL.

Considering the significant contribution of point sources to the upper Nanpan River
pollution, it is reasonable to confine the permit trading to point sources. Examin-
ation of each of the above necessary conditions found that prospects appear good
for the upper Nanpan River catchment. Basically, the catchment appears to satisfy
eight of the nine conditions.

A REVIEW OF HOW WELL THE STUDY AREA SATISFIES THE NECESSARY

CONDITIONS FOR SUCCESSFUL TRADING

1. There is an identifiable catchment. The upper Nanpan River has been identified
as a discrete segment. Permit trading may be confined to either the same area
as the non-tradable system or to selected subzones of it.
2. There are significant and sufficient point sources. While nonpoint sources
contribute somewhat toward water pollution, point sources for the crucial
pollutants dominate. There are nearly thirty existing industrial dischargers
participating in the non-tradable system. The municipal and industrial sources
could form a wider trading market. Furthermore, comparison of the current
and projected discharges with the TMLAs shows that control of point sources
would make the TMLAs attainable.
3. The TMLAs have been established. The TMLAs have been established under
the current permit system. A detailed TDP program could be developed on the
basis of the current permit system, or the TMLAs and total reduction targets
for the regulated pollutants could be developed.
4. There are accurate and sufficient data. Accurate and sufficient data on
wastewater characteristics of the major dischargers have been accumulated for
development of pollution control options. However, a computer information
system should be set up to renew and take full use of those continuously
developed data.
5. The concentration-based discharge limitations must be met at a minimum.
In general, TMLAs are developed and enforced for catchments where
concentration-based discharge requirements could not maintain or attain the
designated water quality objectives. In such a case, TMLAs are assumed to be
the more stringent discharge limit. All the industrial dischargers in the catch-
ment must, at a minimum, meet the concentration-based national discharge
standards.
6. There is a large difference in treatment costs across dischargers. Some of the
existing dischargers hold excessive allowances, a few face advanced treatment
requirements, and others only need primary treatment. Analysis on pollution
control options and associated costs showed that the remaining large reduc-
tions were accompanied by difference in unit pollution control costs across
dischargers (CNY88.6/kgCOD/day–7393.3/kgCOD/day). The combination of
required reductions and unit cost differences would provide incentives for
trading.
DISCHARGE PERMIT SYSTEM FOR WATER POLLUTION 31

7. The TDP system be accepted by the community and regulatory agency. China
has generally approved the rights to trade permits. The Provisional Method
to Manage Permits for Water Pollutant Discharge, a circular released by the
National Environmental Protection Agency of China, pointed out that the
discharge allowances for water pollutants could be transferred among the
local dischargers. China’s Environmental Protection Action Plan (1991–2000)
approved by the State Council stated that a detailed policy on pollution permit
trading needed to be formulated in the 90s. The decision whether to adopt
trading to meet TMLAs is up to the local governments. At this time the
Qujing Municipal Environmental Protection Bureau staff are supportive of
and committed to trading. To what extent the dischargers would seek to trade
permits was difficult to determine, though no one expressed opposition to the
permits trading during the local seminars and other contacts with industries.
The Qujing Municipal Wastewater Treatment Plant will be constructed with a
World Bank loan and domestic investment to serve the Qujing urban center.
The World Bank required that the Plant be managed by a private entity. The
Plant will be the largest participant of the trading program in terms of waste-
loads. That would ensure it a positive position in the trading market. The
municipal sources will participate in permit trading actively and seek to make
money in the trading market.
8. An adequate institutional structure be in place. The region has a capacity for
environmental monitoring adequate to support a trading program. Although
a specific institutional structure to facilitate trading needs to be determined
later, the local environmental protection bureaus appear to be good candidates.
Though they need further capacity building, they have shown their capability
for the permit system management.
9. There be adequate compliance incentives and enforcement mechanisms. Suffi-
cient and effective compliance incentives and enforcement mechanisms are
not yet in place. On one hand, the environmental protection bureaus do not
have enough personnel and resources to conduct unannounced checks. On the
other hand, bargaining is the predominant phenomenon in economic activities
in China owing to the special relationship between the government and the
enterprises (Yun 1997). With respect to discharge permits, enterprises may
bargain either to extend the deadline to comply with their permit limits, or
to eliminate or reduce the penalty for non-compliance. If these constraints are
resolved, the upper Nanpan River stands an excellent chance of developing a
successful trading program. The National Environmental Protection Agency of
China has realized these common enforcement problems and is seeking tech-
nical assistance to formulate enforcement policy of environmental legislation.
Moreover, environmental performance becomes a motivation for enterprises to
invest in pollution control as China’s market system expands. Public exposure
through mass media has a strong influence on the polluter’s behavior in China.
32 WENDONG TAO ET AL.

Specification of Trading Program for the Upper Nanpan River

A point/point source trading program for COD and 5-day BOD discharge is
proposed for the upper Nanpan River. Participants would include both existing and
new point sources in the vicinity of Xiping Town and the Qujing urban center. The
trading program would be based on the current non-tradable permit system, but
provide opportunities for point sources that would otherwise have to install high-
cost technologies to buy excessive permits from others, while low cost dischargers
could reduce their discharges as an offset.

C ONTROLLED POLLUTANTS

The controlled pollutants are those for which the discharge allowances could be
traded among the participants of the trading program. Tradable permits use the
approach of total mass loading control. It was found that at least before the year
2010, only the crucial pollutants of NH3 -N, COD and BOD would be suitable for
total mass loading control. It would be simpler to manage and more effective to
control other pollutants through a concentration limit approach (Tao 1995; YIES
1995). NH3 -N is and will continue to be from a few dischargers. Therefore, COD
and BOD are proposed as the pollutants to be controlled by the trading program.
Considering the common characteristic of oxygen consumption due to both
COD and BOD, it seems proper to allow trades between COD and BOD as long as
an appropriate trading ratio is specified.

T RADING ZONE

The trading zone of permits is the geographical area within which dischargers of a
given pollutant would be allowed to buy and sell permit allowances. Generally,
the greater the number of sources targeted by a permit system, the greater the
likelihood the permits will be actively traded among firms (Government of Canada
1992). However, in over-large trading areas local ‘hot spots’ – localized areas in
which instream water quality standards are exceeded, may be a problem.
With regard to the distribution of existing and future dischargers, it would be
pragmatic to establish a pilot trading program within the subzone 3 and 4 – a total
channel length of 38 km. Most of the dischargers along the upper Nanpan River
are within subzone 3 and 4, and the channel distance is relatively short.

PARTICIPANTS
Ideally, from an environmental and economic standpoint, all sources of pollution
within the trading zone would be included in a given trading program. Frequently,
however, it would be administratively costly and impractical to include directly
many small sources (Government of Canada 1992). This trading program could
contain all 18 existing industrial participants of the non-tradable permit system in
DISCHARGE PERMIT SYSTEM FOR WATER POLLUTION 33

the trading zone and the two major municipal sources. Future industrial dischargers
also could be brought into the trading program. If all the pollution credits were
issued in the initial allocation, then anybody who made an application to develop a
new pollutant source, or to increase discharges from an existing source, would first
need to purchase sufficient credits from existing market players (NSWEPA 1994a).

T OTAL MAXIMUM DAILY LOADS AND INITIAL ALLOCATION OF PERMITS

YIES (1995) gave each subzone a TMLA during low-flow conditions that could
be considered in implementation of the trading program. The TMLAs in low-flow
conditions do not take into account the contribution of nonpoint sources and could
then be apportioned to the point sources within the trading zone.
The initial allocation will affect the bargaining power of participants in a trading
program. There are a few methods for permit allocation that appear appropriate for
the tradable permit system, such as modifying the current allocations, negotiating,
rewarding existing dischargers and growth/entry that adopt cleaner production,
and auction, among others. It is no simple matter to select the most practicable
one. Hence, alternatives for initial allocation of permits under the trading program
are hereafter identified as an important concern to be addressed in later stages.
To simplify the benefit analysis, existing allocations are used to estimate the cost
savings of trades at the present stage.

Benefits of Trading Program for the Upper Nanpan

Since BOD is not regulated by the current permit system (i.e., no wasteload
allocation was undertaken), benefit analysis puts emphasis on COD discharge of
the participants within the trading zone. Among the 18 industrial participants of
the current permit system in the trading zone, 12 industrial dischargers plus the
two main municipal sources are identified as potential trading participants with
reference to their remaining reductions.

P OLLUTION REDUCTION OPTIONS AND COSTS

Due to the unavailability of first hand pollution control information, most of

the pollution reduction options and associated costs are derived from second-
ary data/information sources. Major information sources are the existing research
reports, environmental impact statements, feasibility study reports, design specific-
ation, permit application documents, and government guidelines for best prac-
tical environmental protection technologies. Since the sources used are relatively
detailed and developed for the local conditions, they provide a reasonable approx-
imation of actual reduction costs for the individual dischargers considered in the
study. The pollution reduction options and costs are derived through a process as
follows:
34 WENDONG TAO ET AL.

• to characterize participants’ wastewater with existing available informa-

tion/data;
• to evaluate the existing wastewater collection system, wastewater treatment
facilities and internal water-reuse system so as to find out the remaining
problems;
• to select water pollution reduction options against the remaining problems;
• to develop the annual reduction costs of each option using the cost transfer
method.
The annual reduction cost, the sum of annualized capital cost and annual operation
and maintenance cost, is employed to compare the cost-effectiveness of pollution
reduction options. While converting one-time capital costs to annual equivalent
capital costs, it is assumed that the wastewater treatment plants or facilities depreci-
ate over a 20-year period and the discount rate is then 5%. Capital cost of industrial
dischargers embraces costs of wastewater collection system, civil construction,
equipment and installation of wastewater treatment plants or facilities, and waste-
reclamation. Capital cost of municipal sources mainly includes land cost, civil
construction cost, and equipment and installation cost. The principal elements
of operation and maintenance cost are labor, energy, chemicals, materials and
supplies. All costs are converted to 1990 CNY, using the official composite price
index.
Each option reduces discharge from the current load to a given level. The
options are those optimum feasible ones relative to certain reductions. The options
that reduce pollutant loads to nearly zero or permit limits are also sought. For this
reason, it may be possible to find a few options for most of the participants so that
a step function rather than a smooth incremental cost curve is developed for each
participant. Therefore, unit costs are used to identify trading opportunities.

I DENTIFICATION OF TRADING OPPORTUNITIES

Comparing the unit costs across all reduction options of the potential participants
identifies the trading opportunities. We rank all the options according to unit cost
from the most expensive to the cheapest. In principle, permit trading allocates
pollutant load reductions across point sources using least cost as the criterion. The
most likely trade would occur when the participant with the highest unit cost offers
the highest permit price for a unit of excessive allowance on sale released by the
one with the lowest unit cost. Consequently, it is assumed that the participant with
the most expensive option is the first to buy such a unit excessive allowance on
sale.
The actual load of a participant is either larger than or equal to the allow-
ance. The participant that is with discharge load larger than that allowed has to
reduce its load. Application of a new specific control technology might result in a
participant having excessive allowances. Such excessive allowances could be sold.
Nonetheless, few dischargers are assumed to solely seek financial gain by upgrad-
DISCHARGE PERMIT SYSTEM FOR WATER POLLUTION 35
Table I. Cost-effectiveness with and without trading to meet permit limits.

Code of Required Selected reduction Without trading With trading

participant reduction option (without/with Reduction Annual cost Reduction Annual cost
kg/day trading) kg/day CNY kg/day CNY

QUC 8424.39 QUC4/QUC3 + GPM5 + QHTS2 9110.0 11344200 8424.4 9191898

+ QMLTP2 + QMB2 + QCF6
+ QPPP3 + QMB3 + QMBP3 + XT2
XT 773.35 XT2/XT2 822.5 788800 804.5 771516
QMB 47.59 QMB1/QMB2 50.0 27446 47.6 23186
ZPFP 23.05 ZPFP2/GPM5 23.0 170416 23.1 7177
ZWTM −16.88 / 0.0 0 0.0 0
GPM 257.06 GPM5/GPM5 296.8 92220 257.1 79881
LAF 0.00 / 0.0 0 0.0 0
QCF 768.15 QCF6/QCF6 857.0 537350 768.2 481661
QHTS 26.85 QHTS1/QHTS1 27.0 8375 27.0 8375
QMBP 46.45 QMBP2/QMBP2 47.0 19166 47.0 19166
QMFC 109.47 QMFC3/QMFC3 109.5 13058 109.5 13058
QMLTP 69.97 QMLTP2/QMLTP2 85.0 40723 70.0 33537
QPIMP 43.78 QPIMP3/QPIMP3 44.0 8660 44.0 8660
QPPP 241.63 QPPP2/QPPP2 244.0 30721 244.0 30721

Total 10814.86 11715.8 13081135 10866.4 10668836

ing their treatment facilities and selling the excessive allowances, considering the
low proportion of the cost needed to meet permit limits to the cost of industrial
product (i.e., 0.04% to 0.65% with exception of one paper mill at 7.33%). This
assumption fits with the Fox River experience (USEPA 1992b). The other options
of the buyer are then deleted from the ranking if the buyer gets enough discharge
rights to meet its permit limits.
For the options that are extended from the sold option, it is feasible to increase
excessive allowances through adding up unit treatment processes. For the options
that are not extended from the sold option, it is impossible to improve wastewater
treatment facilities because they are developed to reduce loading from the same
current load as the sold option but with different combination of unit treatment
processes. Therefore, the former options are substituted by the increments of
reduction load and cost, and the latter are deleted from the ranking.
Although the research aims at examining the implications of trading in real
settings, our trading cases (see Table I) are hypothetical. We simply wish to illus-
trate the potential effect of such an alternative to the current permit system for
water pollution control.
36 WENDONG TAO ET AL.

E STIMATION OF COST- SAVINGS

The potential annual benefit, direct reduction cost savings, is the difference of the
total annual cost of all participants to meet permit limits without trading and that
with trading. The “without trading” approach requires each discharger to achieve
its permit limits by upgrading its own wastewater treatment facilities; the “with
trading” approach allows permit trading to be an alternative for the dischargers to
achieve their permit limits.
Without trading, the calculation of the total cost is relatively straightforward.
It is obtained by getting the sum of the reduction cost of all participants’ option
that just makes the permit limits achieved. Under a trading program, there are
two choices for the dischargers to meet their permit limits – upgrading their own
wastewater treatment facilities or buying excessive allowances from the other
holders. Thus, the calculation of the total cost with trading is the sum of the
reduction cost of the participants that would meet their permit limits by upgrading
their own wastewater treatment facilities and the reduction cost through trading.
For example, although QCF applies the same pollution reduction option with and
without trading, it would sell 88.8 kgCOD/day of excessive reduction beyond
768.2 kgCOD/day to QUC if trading is allowed. The 88.8 kgCOD/day of traded
reduction and associated cost of CNY55689/year is then transferred from QCF to
QUC.
Based on our simulation, there would be only one case of trade between the
industrial participants (GPM adopts reduction option 5 and sells excessive reduc-
tion to ZPFP). However, there would be eight trades between municipal source
QUC and industrial participants and one case between the two municipal sources
(XT sells excessive reduction to QUC). These trades would gain a cost saving of
CNY2.4 million/year, or 18.4% of the total annual cost to attain the total reduction
target without trading. Because of the earlier mentioned assumptions to identify
trading opportunities, this amount of cost savings is a conservative estimation so
that it is modest compared to those (US$23 000 to US$27.2 million; 1 US$ ≈ 8.3
CNY) of US case studies of tradable permits for water pollution (USEPA 1992b).
Inclusion of the Qujing Municipal Wastewater Treatment Plant, which is
currently under preparation, into the trading market might bring out monopo-
listic behavior. With regard to their higher pollutant loading and potential trader
position, the municipal sources cannot be excluded from the trading program. To
prevent monopolistic behavior of the municipal sources, government could set
interventions to the permit trading prices, or an industrial congregation could be
instituted.
Theoretically, trading makes the differential in unit cost across dischargers
approach zero. The unit price of the last trade can approximately be considered
the marginal pollution reduction cost. In this case, it is estimated to be CNY959/kg
COD/day.
The ‘without trading’ and ‘with trading’ scenarios of the upper Nanpan River
permit system will, due to specific pollution control options, bring about 900.9
DISCHARGE PERMIT SYSTEM FOR WATER POLLUTION 37

kg/day and 51.5 kg/day of redundant reduction respectively beyond the required
reduction (see Table I).
A fair comparison between incentive-based and command-and-control policies
necessitates that any additional benefits associated with command-and-control
policies be offset against the cost advantages enjoyed by their incentive-based
counterparts (Oates et al. 1989). The net annual benefit arising from trading would
be direct pollution reduction cost-savings minus benefit of the additional reduction
of (900.9–51.5) kg/day. The net benefit of about CNY1.6 million is still signific-
ant when the benefit of such additional reduction is monetized by the marginal
reduction cost.
Estimation of the benefits of any TDP system is difficult before the system is
actually in place. In practice, the actual level of benefits will depend largely on
the extent of trading (USEPA 1992b). If BOD data were used to estimate the cost-
savings, results would be different. The research presented here intends to help
the government and industries accept the TDP program by illustrating the benefits
from trading.

Conclusion and Recommendations

The upper Nanpan River appears promising with regard to the necessary condi-
tions for an effective and efficient point/point source trading program. It would
achieve the same total pollution reduction targets but at a lower total cost. The
pilot point/point source trading program in a smaller trading zone would bring out
a relatively thick trading market, saving 18.4% of the total pollution reduction cost.
Nevertheless, the actual benefits of trading are highly dependent on the design of
the program and the particular incentives facing both dischargers and the affected
regulatory agencies. Some situations still need improving before any operation of
a trading system. There are concerns important for implementation, which would
need to be addressed later, including the following:
• A computer information system needs to be established to pool information
and data on participants and instream water quality changes so as to facilitate
trading and management.
• The equilibrium permits allocation and cost-savings are sensitive to the initial
permit distribution. Initial allocation method of permits for trading should be
carefully selected.
• Several factors should be considered when establishing an appropriate lifespan
for permits. Too short a lifespan will be a disincentive to trading. However, if
the lifespan of permits is too long, this will restrict flexibility within the trading
system and make it more difficult for the regulatory authority to improve water
quality (NSWEPA 1994b).
• A trading rulebook should be formulated in collaboration of the local environ-
mental protection bureaus. On one hand, compliance monitoring and institu-
tional/administrative requirements must be considered. On the other hand, the
38 WENDONG TAO ET AL.

program must be carefully designed not only to minimize the administrative

and transaction costs imposed on dischargers and regulatory agencies, but also
to ensure that trading does not result in degradation of local water quality.

Acknowledgments
This work was carried out with the aid of a small grant from EEPSEA. Our thanks
to Dr. David James, Dr. John Whalley, Dr. David Glover and Dr. Herminia Fran-
cisco, as well as many EEPSEA workshop participants for their useful comments
and suggestions. We would like to thank the US EPA Region 5, NSW EPA of
Australia and David James for providing valuable materials.

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