Situation: A livestock expansion is proposed in a non-TMDL area. One idea being tossed around is non-point to non-point phosphorus trading. If a facility wanted to expand or locate into the County they would have to offset their modeled phosphorus loss by purchasing or obtaining credits within that watershed. It would be a pre-emptive TMDL. Any precedent for such an approach that you know of? Point to non-point trading is common, but how about non-point to non-point? Basically, a new or expanded facility would be creating an incentive for others in the watershed to reduce their phosphorus losses.