Pollutant Trading is an up-and-coming topic in stormwater management, especially in places such as the Chesapeake Bay and other watersheds where TMDLs are driving numerical limits for stormwater discharges.  State and local programs are seeking effective ways to trade pollutant loads between nonpoint sources in order to meet overall pollutant load reduction goals at the watershed scale.  This paper focuses on trading and offsite compliance options for nutrients, with a focus on the Chesapeake Bay watershed.  However, it is relevant to other areas seeking to set up this type of program.  The paper is not a “how-to” guide for setting up a program, but introduces important policy and programmatic issues with program development.  The paper was co-authored by the Center for Watershed Protection and the Williamsburg Environmental Group.