Abstract: Market-like trading programs for water quality management begin with enforceable limits on the amount of the pollutant allowed in a watershed. Properly designed market-like trading programs then create incentives for dischargers to reduce nutrient control costs over time by making pollution prevention innovations. However, the structure of the Clean Water Act can be a barrier to establishing market-like trading programs. First, we describe the general features and advantages of market-like trading programs. Then we offer practical suggestions for bringing market-like design concepts to nutrient trading programs within the existing legal and regulatory setting.