Great Lakes
EPA Needs to Define Organizational Responsibilities Better for Effective Oversight and Cleanup of Contaminated Areas Gao ID: GAO-02-563 May 17, 2002To protect the Great Lakes and to address common water quality problems, the United States and Canada entered into the bilateral Great Lakes Water Quality Agreement in 1972. The agreement has been amended several times, most recently in 1987. That year, the two countries agreed to cooperate with state and provincial governments to develop and implement remedial action plans (RAPs) for designated areas in the Great Lakes Basin--areas contaminated, for example, by toxic substances. The Environmental Protection Agency (EPA) leads the effort to meet the goals of the Great Lakes Water Quality Agreement, which include RAP development and implementation. As of April 2002, all of the 26 contaminated areas in the Great Lakes Basin that the United States is responsible for have completed the first stage of the RAP process; however, only half have completed the second stage. Even though EPA has been charged with leading the effort to meet the goals of the agreement, it has not clearly delineated responsibility for oversight of RAPs within the agency, and, citing resource constraints and the need to tend to other Great Lakes priorities, reduced its staff and the amount of funding allocated to states for the purpose of RAP development and implementation.
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Director: Team: Phone:GAO-02-563, Great Lakes: EPA Needs to Define Organizational Responsibilities Better for Effective Oversight and Cleanup of Contaminated Areas
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United States General Accounting Office:
GAO:
Report to Congressional Requesters:
May 2002:
Great Lakes:
EPA Needs to Define Organizational Responsibilities Better for
Effective Oversight and Cleanup of Contaminated Areas:
GAO-02-563:
Contents:
Letter:
Results in Brief:
Background:
Cleanup Progress Has Been Limited in Many Contaminated Areas:
EPA Is Not Fulfilling the Nation‘s Responsibility to Ensure the Cleanup
of Contaminated Areas:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Environmental Protection Agency:
Appendix III: GAO Contacts and Staff Acknowledgments:
Tables:
Table 1: Status of Areas of Concern:
Figures:
Figure 1: CEM Funding Provided to EPA Regions for RAP and LaMP
Activities Has Declined:
List of Abbreviations:
CEM: Costal Environmental Management:
EPA: Environmental Protection Agency:
GLNPO: Great Lakes National Program Office:
IJC: International Joint Commission:
LaMPs: Lakewide Management Plans:
OIG: Office of Inspector General:
RAPs: Remedial Action Plans:
SOLEC: State of the Lakes Ecosystem Conferences:
[End of section]
United States General Accounting Office:
Washington, DC 20548:
May 17, 2002:
Congressional Requesters:
Millions of people in the United States and Canada depend on the Great
Lakes as a source for drinking water, recreation, and economic
livelihood. Over time industrial, agricultural, and residential
development on lands adjacent to the lakes have seriously degraded the
lakes‘ water quality, posing threats to human health and the
environment, and forcing restrictions on activities, such as swimming
and fish consumption.
In an effort to better protect the Great Lakes, and to address common
water quality problems, the governments of the United States and Canada
entered into the bilateral Great Lakes Water Quality Agreement in 1972.
In 1978 the parties reached a new agreement, which, as amended in 1983
and 1987, expanded the scope of the activities by prescribing
prevention and cleanup measures intended to improve the lakes‘
conditions. Specifically, the 1987 amendment committed the two
countries to cooperate with state and provincial governments to ensure,
among other things, the development and implementation of remedial
action plans (RAPs) for designated areas of concern (areas) located in
the Great Lakes Basin”areas contaminated for example with toxic
substances known to cause deformities in fish or animals. The countries
have agreed to use RAPs for managing the cleanup process and restoring
contaminated areas to their beneficial use, such as swimming or
fishing. The countries have identified 43 contaminated areas: 26
located entirely within the United States, 12 in Canada, and 5 shared
by both. The agreement obligates the International Joint Commission
(IJC)”an international body charged with assisting the implementation
of the agreement”to review the RAPs and provide comments on them.
The Clean Water Act charges the U.S. Environmental Protection Agency
(EPA) with leading the effort to meet the goals of the Great Lakes Water
Quality Agreement, which include RAP development and implementation.
The purpose of the section of the act addressing the Great Lakes is to
achieve the goals of the agreement through improved organization and
definition of the agency‘s mission, funding of state grants for
pollution control in the Great Lakes area, and improved accountability
for implementation of the agreement. The act also establishes the Great
Lakes National Program Office (GLNPO) within EPA, charging it with,
among other things, cooperating with federal, state, tribal, and
international agencies to develop and implement specific action plans
to carry out the United States‘ responsibilities under the various
agreements. GLNPO is also charged with coordinating the actions of the
agency, both in headquarters and in the regions, aimed at improving
Great Lakes‘ water quality. Specifically, under the act the
administrator is to ensure that GLNPO enters into agreements with the
various organizational elements within EPA specifically delineating
duties and responsibilities of each element within the agency and the
time and resources needed to carry out and complete them.
According to EPA, the RAP process provides a forum for individuals,
organizations, and local governments to become actively involved in the
restoration of the Great Lakes ecosystems. As such, EPA provides states
certain flexibility in developing RAPs. In some areas, states have
borne the responsibility for developing RAPs. In other areas, local
citizens formed citizen advisory councils to assume this
responsibility. The RAP process consists of three successive stages:
(1) defining an area‘s environmental problem, (2) selecting remedial
and regulatory measures to address the problem, and (3) implementing
the measures and restoring an area to its beneficial use, such as
swimming. As part of the RAP process, the states submit their
respective RAPs to the IJC for review and comment. When an area
successfully completes all three stages of the RAP process, the area‘s
name is removed from the list of contaminated areas, signifying that the
area is restored.
Concerned with continued environmental problems in the lakes, you
asked us to (1) determine what progress has been made in developing and
implementing RAPs and (2) assess the effectiveness of EPA‘s efforts to
ensure that RAPs are developed and implemented. The methodology that
we used to address these issues is presented in appendix I.
Results in Brief:
As of April 2002, none of the 26 contaminated areas in the Great Lakes
Basin for which the United States is responsible had completed all three
stages of the RAP process and been restored to beneficial use.
Currently, all of the areas have defined their respective environmental
problems (stage 1), but only approximately half of the areas selected
remedial and regulatory measures to address these problems (stage 2).
The slow progress of cleanup efforts reflects a general departure from
the RAP process specified in the agreement. In a few areas, the state
or local groups continue to follow the RAP process, although the
ultimate remediation of the contaminated areas remains uncertain. In
some areas, citizen advisory councils developed alternative cleanup
plans that completely abandoned the RAP process. According to state and
local officials, the councils abandoned the process because they lacked
the technical expertise or financial resources to implement the RAPs.
In other areas, the states or citizen groups assumed responsibility for
the RAPs, modifying the process to conform to each area‘s particular
circumstances. Several areas forged ahead to address some of their
environmental problems, with successes realized through other federal
program activity, such as Superfund, or funding from state or nonprofit
sources.
EPA is not effectively fulfilling the nation‘s responsibility under the
Great Lakes Water Quality Agreement of 1978 to ensure that RAPs are
developed and implemented in the contaminated areas. Even though EPA
has been charged with leading the effort to meet the goals of the
agreement, it has not clearly delineated responsibility for oversight
of RAPs within the agency, and, citing resource constraints and the
need to tend to other Great Lakes priorities, reduced its staff and the
amount of funding it allocates to states for the purpose of RAP
development and implementation. For example, in 1992, EPA transferred
the oversight responsibility for RAPs from GLNPO to the agency‘s
regional offices, which it believed to be more familiar with funding
and managing such programs. The regional offices provided initial
support and oversight for the RAP process, but then significantly
reduced the number of assigned staff and the amount of federally
allocated funds devoted to RAP development and implementation. Now, no
EPA office claims responsibility for overseeing this effort. Moreover,
reductions in staff and funding limited the number of areas that EPA
can effectively monitor. According to EPA officials, the agency reduced
its support for RAPs under the assumption that states would continue to
fund the RAP efforts. Instead, the states followed EPA‘s lead and
reduced their support as well. Subsequently, EPA shifted its attention
to other priorities in the Great Lakes Basin that are required under
the agreement. We are recommending that the EPA administrator clarify
which office within EPA is directly responsible for ensuring the
implementation of RAPs and identify the actions, time periods, and
resources needed to help EPA fulfill its RAP oversight
responsibilities.
Background:
Recognizing their mutual interests in the Great Lakes and other boundary
waters, the United States and Canada signed the Boundary Waters Treaty
in 1909, giving both countries equal rights to use the waterways that
cross the international border. Accordingly, the treaty established the
International Joint Commission (IJC), comprised of three commissioners
from each country, to help the two governments resolve and prevent
disputes concerning boundary waters. With increased concern over the
contamination of the Great Lakes, the two countries signed the first
international Great Lakes Water Quality Agreement in 1972 to improve the
environmental conditions in the lakes. The agreement focused on
controlling phosphorous as a principal means of dealing with
eutrophication in the lakes. The parties signed a new agreement in 1978
that called for increased control of toxic substances and restoring
water quality throughout the Great Lakes Basin. Subsequent amendments
were made to the agreement in 1983 and 1987. The 1987 amendments added
several annexes that focused on specific environmental concerns, such as
contaminated sediment.
The 1978 agreement as amended contains 17 annexes that define in detail
the specific programs and activities that the two governments agreed
upon and committed to implement. Although most of the annexes specify
pollution prevention strategies, Annex 2 calls for the preparation of
RAPs to address the restoration and protection of beneficial uses in
specific contaminated areas designated as areas of concern and the
other open waters of the Great Lakes. Such areas may include areas
along the Great Lakes‘ shoreline and areas that drain into the lakes
that states and provinces identified as contaminated areas requiring
cleanup. The agreement binds the United States and Canada to cooperate
with state and provincial governments to designate such areas of
concern, with the IJC reviewing progress by each government in
addressing actions to restore water quality in the lakes. The agreement
as amended also directs that the public be consulted in the RAP process
and that each RAP:
* define the environmental problems and the causes of these problems in
the areas,
* provide an evaluation of remedial measures,
* select remedial measures,
* provide an implementation schedule,
* identify organizations or individuals responsible for implementation,
* include a process for evaluating remedial implementation and
effectiveness, and;
* provide a description of monitoring to track effectiveness and
confirmation that the areas are restored.
In defining the environmental problems, RAPs determine the applicability
of 14 adverse environmental conditions to the area. Such impairments
include beach closings, tainting of fish and wildlife flavor, and bird
or animal deformities or reproduction problems.
In addition, the Water Quality Act of 1987 amended the Clean Water Act
to provide that EPA should take the lead in coordinating with other
federal agencies and state and local authorities to meet the goals in
the agreement. The act also established GLNPO within EPA to fulfill the
United States‘ responsibilities under the agreement and to coordinate
EPA‘s actions both at headquarters and in the affected regional offices.
The Great Lakes Critical Programs Act of 1990 amended the Clean Water
Act further defining GLNPO‘s role and requiring the submission of all
RAPs to the office and also requiring each plan be submitted to the IJC
for review and comment. The 1990 Act designated states as the primary
parties for developing and implementing plans, although ensuring
successful completion of the plans remains the responsibility of the
United States and EPA under the agreement and the Clean Water Act. When
Coastal Environmental Management (CEM) funding first became available
in 1992, and because the Water Divisions administered other water
program funding, EPA officials made the decision to transfer oversight
of the RAP process from GLNPO to the Water Division in EPA Regions II,
III, and V, which border the Great Lakes.
For the past several years, we and others have reported on slow progress
of the Great Lakes cleanup activities, making particular reference to
the fact that neither GLNPO nor any other EPA office had devoted the
necessary responsibility, authority, and resources to effectively
coordinate and oversee cleanup efforts in the Great Lakes Basin. In
1990, we reported that the development of the RAPs and Lakewide
Management Plans (LaMPs)[Footnote 1] called for in the agreement had
fallen far behind schedule and recommended that EPA better coordinate
GLNPO and EPA‘s headquarters offices to improve the process.[Footnote
2] Likewise, EPA‘s Office of Inspector General (OIG) reported in 1999,
that EPA officials were not as effective as they could be in working
with states and local officials on RAPs and recommended that one
official coordinate these activities.[Footnote 3] The IJC, in its most
recent biennial report, identified the RAP process as an area needing
improvement and reported that the process for preparing RAPs and LaMPs
was no longer being followed, in some cases resulting in an ad hoc
modification of the annex. The IJC also reported that information on RAP
implementation is not readily available in a standardized, consolidated
format.[Footnote 4] Overall, the IJC concluded that although some
progress had been made in the Great Lakes, the governments had not
committed adequate funding or taken decisive actions to restore and
protect the lakes. Citing the public‘s right to know (and in an effort
to get the program back on track), the IJC recommended a results-
oriented approach, suggesting that the governments of the United States
and Canada prepare one consolidated progress report that lists
accomplishments, expenditures, what remains to be done, and the amount
of funding and time needed to restore the contaminated areas to
beneficial use.
Cleanup Progress Has Been Limited in Many Contaminated Areas:
Progress in cleaning up the Great Lakes and restoring the contaminated
areas to their beneficial uses has fallen behind where the parties
hoped it would be. As of April 2002, most of the RAPs for which the
United States was responsible were in the second stage of having
remedial and regulatory measures selected; none has completed all three
stages indicating completion of cleanup. (See table 1.)
Table 1: Status of Areas of Concern:
Area of Concern: Ashtabula River;
State: Ohio;
Date Reported to IJC, Stage 1: 1991;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Black River;
State: Ohio;
Date Reported to IJC, Stage 1: 1994;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Buffalo River;
State: New York;
Date Reported to IJC, Stage 1: 1989;
Date Reported to IJC, Stage 2: 1989;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Clinton River;
State: Michigan;
Date Reported to IJC, Stage 1: 1988;
Date Reported to IJC, Stage 2: 1995;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Cuyahoga River;
State: Ohio;
Date Reported to IJC, Stage 1: 1992;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Deer Lake;
State: Michigan;
Date Reported to IJC, Stage 1: 1987;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Eighteenmile Creek;
State: New York;
Date Reported to IJC, Stage 1: 1997;
Date Reported to IJC, Stage 2: 1997;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Fox River;
State: Wisconsin;
Date Reported to IJC, Stage 1: 1998;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Grand Calumet River;
State: Indiana;
Date Reported to IJC, Stage 1: 1991;
Date Reported to IJC, Stage 2: 1997;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Kalamazoo River;
State: Michigan;
Date Reported to IJC, Stage 1: [Empty];
Date Reported to IJC, Stage 2: 1998;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Lower Menominee River;
State: Michigan/Wisconsin;
Date Reported to IJC, Stage 1: 1991;
Date Reported to IJC, Stage 2: 1996;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Manistique River;
State: Michigan;
Date Reported to IJC, Stage 1: 1987;
Date Reported to IJC, Stage 2: 1997;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Maumee River;
State: Indiana/Ohio;
Date Reported to IJC, Stage 1: 1992;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Milwaukee Estuary;
State: Wisconsin;
Date Reported to IJC, Stage 1: 1994;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Muskegon Lake;
State: Michigan;
Date Reported to IJC, Stage 1: 1987;
Date Reported to IJC, Stage 2: 1994;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Oswego;
State: New York;
Date Reported to IJC, Stage 1: 1990;
Date Reported to IJC, Stage 2: 1991;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Presque Isle Bay;
State: Pennsylvania;
Date Reported to IJC, Stage 1: 1993;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: River Raisin;
State: Michigan;
Date Reported to IJC, Stage 1: 1987;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Rochester Embayment;
State: New York;
Date Reported to IJC, Stage 1: 1993;
Date Reported to IJC, Stage 2: 1997;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Rouge River;
State: Michigan;
Date Reported to IJC, Stage 1: 1989;
Date Reported to IJC, Stage 2: 1994;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Saginaw River/Bay;
State: Wisconsin;
Date Reported to IJC, Stage 1: 1988;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Sheboygan River;
State: Wisconsin;
Date Reported to IJC, Stage 1: 1989;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: St. Louis Bay/River;
State: Minnesota/Wisconsin;
Date Reported to IJC, Stage 1: 1992;
Date Reported to IJC, Stage 2: 1995;
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Torch Lake;
State: Michigan;
Date Reported to IJC, Stage 1: 1987;
Date Reported to IJC, Stage 2: [Empty];
Date Reported to IJC, Stage 3: [Empty].
Area of Concern: Waukegan Harbor;
State: Illinois;
Date Reported to IJC, Stage 1: 1993;
Date Reported to IJC, Stage 2: 1995;
Date Reported to IJC, Stage 3: 1999.
Area of Concern: White Lake;
State: Michigan;
Date Reported to IJC, Stage 1: 1987;
Date Reported to IJC, Stage 2: 1995;
Date Reported to IJC, Stage 3: [Empty].
Source: EPA Great Lakes Ecosystem Report 2000.
[End of table]
No area of concern in the United States has had its designation removed”
that is, been delisted”although the Great Lakes Strategy 2002 plan,
which was developed by representatives of federal, state, and tribal
governments in the Great Lakes area, lists as one of its objectives the
removal of 3 areas from the list by 2005, and 10 by 2010.
The RAP process envisioned in the agreement is not being consistently
used as a model for cleanup activities occurring at the areas. While
cleanup activities have occurred in many areas, such activities have
generally resulted from other environmental programs or initiatives. The
RAP process has essentially been abandoned for some areas, modified for
others, and for a limited number of areas the process is being followed
to address the environmental impairments. According to state officials,
a major reason that the RAP process is not being followed is the lack of
general funding, including funding from EPA. Whether or not the process
is being followed at an area often depends in part on state involvement
in the process and whether there is local interest. As a result,
implementation of the agreement is uneven across the areas and, in
areas where the process has been abandoned, the initial investment in
the process may have been largely wasted.
Each of the eight Great Lakes states”Illinois, Indiana, Ohio, Michigan,
Minnesota, New York, Pennsylvania, and Wisconsin”has approached the
RAP process in a somewhat different manner after EPA reduced its
funding, but in general the volume of resources they devoted to the
process has diminished in the past 10 years, according to state
officials.
* The state of Michigan, which contains 14 areas, completed the first
stage of the RAP process”defining the environmental problems”in 1987 and
1988. In the preparation stage, the state funded a group of state
coordinators, who spent part or all of their time on RAPs. Today, the
coordinators spend only a small fraction of their time on RAPs and serve
mainly as an area‘s informational point of contact. In addition, the
state decided that it would no longer follow the three-stage process
set forth in the agreement. Responsibility for the Michigan RAP process
rests primarily with local groups known as public advisory councils,
and while none of these groups have abandoned their work, state
officials indicated that two groups are on the verge of quitting and
that others had significantly decreased their activities. The officials
further stated that, while RAPs may be a catalyst, they are not driving
the implementation of the areas‘ cleanup activities. Instead, officials
noted, other federal programs, such as Superfund, and state and
nonprofit programs provide funding for cleanup and restoration
activities. An organization representing the public advisory councils
recently recommended that the state play a more aggressive role in
supporting their efforts by providing funding and technical support.
* The state of New York, which has six contaminated areas, employs a
part-time coordinator for each area. According to state officials, over
the years the overall activity in the RAP process has decreased, but
the state retains oversight and commitment to the process. However, the
RAP process is not the impetus for cleanup activities at the areas.
Instead, other programs, such as EPA‘s Resource Conservation and
Recovery Act, have been used to clean up contaminated areas.
* In Wisconsin, which has five contaminated areas, the work on the RAP
process for the areas was stopped after EPA decreased funding for RAP
activities. As with other states, cleanup work continues at the areas
through other programs, although the state only completes projects
consistent with a RAP when it has the time and funds to do so, according
to a state official. The state does not monitor RAP progress, and
community groups are no longer actively involved in the process.
* In Ohio, which has four contaminated areas, the RAP process evolved
differently in each area. For example, a structured process exists to
address the environmental impairments in one area, but the process is
less structured in two other areas and significantly modified in
another, according to a state official. Community organizations are
involved in three of the four areas. The state has also modified the
three-stage process specified in the agreement, saying that the RAPs
could never be used to cleanup an area because they are not
implementation documents, according to the official.
* In Minnesota, Illinois, Pennsylvania, and Indiana, which have one
contaminated area each, any work underway in the areas is largely the
result of other programmatic activity, such as the removal of
contaminated sediment in Waukegan Harbor, Illinois, as part of the
Superfund program. There is local involvement in the RAP process in the
areas in Illinois, Pennsylvania, and Indiana. In Minnesota, a nonprofit
group sponsors environmental projects in the region where the area is
located, but it is not directly involved in the RAP process.
EPA and others often present environmental cleanup activities that
relate to the goals of the RAP process as evidence that progress is
being made at the areas, but these activities often relate to the goals
of other programs, such as Superfund. Such reporting makes it difficult
to determine what progress is being made in eliminating the impairments
identified in the individual RAPs. In this connection, the members of
the IJC responsible for reviewing the progress of the areas have
reported their frustration in assessing RAP progress because EPA has
not provided meaningful information to them.
EPA Is Not Fulfilling the Nation‘s Responsibility to Ensure the Cleanup
of Contaminated Areas:
EPA is not effectively fulfilling the nation‘s responsibilities to
ensure that RAPs are developed and implemented in the contaminated
areas. Several EPA actions, such as diffusing RAP responsibility within
the agency, reducing federal funding and staff support for the RAP
process, and shifting the agency‘s attention to other cleanup
priorities in the Great Lakes Basin have all contributed to the uneven
progress in RAP development and implementation. For example, in 1992,
EPA transferred the responsibility for overseeing the RAP process from
GLNPO to its Water Divisions in Regions II, III, and V. GLNPO retained
responsibility for certain RAP-related activities, such as preparing
progress reports and funding research that affected the contaminated
areas. The Water Divisions provided initial support and oversight for
the RAP process, but following several sequential cutbacks in process-
related state funding and staff, their capacity to oversee the RAP
process was diminished to the point where EPA could no longer ensure
the ultimate restoration of the contaminated areas. As support for the
RAP process waned, EPA shifted its attention to other environmental
problems in the Great Lakes, such as completing plans to address
lakewide environmental problems. Although important, these activities
did not supplant the need for RAPs to address the contaminated areas.
Oversight Responsibility Within EPA for Contaminated Areas Is Unclear:
Responsibility for oversight of the RAP process within EPA has changed
over time and today no office claims that responsibility. Amendments to
the Clean Water Act in 1987 named EPA as the lead agency and charged
GLNPO with coordinating EPA‘s actions aimed at improving the water
quality of the Great Lakes. The act was amended in 1990 to, among other
things, require GLNPO to ensure the submission of RAPs for each area of
concern. The EPA administrator is responsible under the act for ensuring
that GLNPO specifically delineate the duties and responsibilities, the
time commitments, and resource requirements with respect to Great Lakes
activities when entering into agreements with other organizational
elements within EPA. Shortly after the 1990 amendments were enacted,
EPA officials transferred oversight of the RAP process from GLNPO to its
Water Divisions in Regions II, III, and V, which border the Great Lakes.
While this decision was not formally documented, an EPA official
familiar with the decision stated that EPA headquarters considered
GLNPO‘s primary focus to be on research and basin-wide activities.
Furthermore, the official did not think that, as an office, GLNPO had
the organizational mindset or capacity to oversee the RAP process.
According to GLNPO officials, EPA believed the Water Divisions were
more familiar with funding and managing similar programs. GLNPO,
however, continued to track the status of RAPs and provide technical
assistance and grant funds for projects associated with RAPs.
In 1995, EPA‘s Region V Office reorganized and created teams responsible
for the Great Lakes including their contaminated areas. These teams are
focusing on developing and updating the LaMPs for each lake. The
directors for GLNPO and the Region V Water Division share responsibility
for the teams. In addition to the CEM funds provided for RAPs by the
Water Divisions, GLNPO‘s base budget has averaged about $14.5 million
annually since 1993. During that same period GLNPO awarded about $3.2
million annually to states, tribes, local organizations, and academic
institutions to fund Great Lakes activities related to the areas such as
sediment research and pollution prevention.
In a September 1999 report on EPA‘s Great Lakes Program, the EPA OIG
recommended that the EPA‘s Region V administrator clarify the role of
GLNPO as it relates to RAPs and LaMPs. The administrator agreed with
this recommendation and stated that GLNPO‘s roles and responsibilities
would be addressed during the development and implementation of a Great
Lakes strategy. At that time, regional officials expected this strategy
to be completed by April 2000. EPA released its Great Lakes strategy on
April 2, 2002; however, this strategy did not clarify GLNPO‘s roles and
responsibilities for RAPs, nor did it include provisions for specific
funding to carry out the strategy. GLNPO officials stated that they
decided not to include this clarification in the strategy because it
required more specifics than could be included in the document. Still,
as of April 2002, the agency had not clarified GLNPO‘s role in any
other document.
GLNPO officials have stated that state and local governments are
primarily responsible for implementation of RAPs through their local
pollution control programs, except when federal programs and
authorities, such as Superfund, are in the lead for a particular
effort. Further, other EPA officials have noted that the financial
assistance provided states for developing RAPs was intended only to be
seed money and that the states were expected to continue funding the
process. State and other EPA officials, including GLNPO officials,
maintain that the federal government is ultimately responsible for the
RAPs and cleaning up the areas. According to the director of the Water
Division in Region V, there needs to be clear delineation of oversight
responsibility for RAPs, which are, in the end, a federal
responsibility.
EPA Cut Funding and Staffing for Program-Related Activities:
Over the past 10 years EPA has taken several steps that have reduced its
ability to sustain the RAP process, such as reducing the amounts of RAP-
related funding allocated to the states and reducing the number of
agency staff assigned to oversee RAP activities. To assist states in
preparing RAPs for the contaminated areas, EPA provided funding to the
states from the CEM program. States used the funding to hire staff to
focus on the planning process and organize community involvement to
develop the RAPs. The funding was allocated to the three EPA Regions
and then provided to the states. EPA decreased its regional CEM funding
from $9.2 million in fiscal year 1992 to $2.5 million in fiscal year
2002. (See figure 1.)
Figure 1: CEM Funding Provided to EPA Regions for RAP and LaMP
Activities Has Declined:
[Refer to PDF for image]
This figure is a vertical bar chart depicting CEM funding provided to
EPA regions for RAP and LaMP activities during the time period of
fiscal years 1992 through 2002 with approximated funding as follows:
Fiscal year: 1992;
CEM funding: $9.2 million.
Fiscal year: 1993;
CEM funding: $8.5 million.
Fiscal year: 1994;
CEM funding: $6.1 million.
Fiscal year: 1995;
CEM funding: $7.0 million.
Fiscal year: 1996;
CEM funding: $7.0 million.
Fiscal year: 1997;
CEM funding: $5.5 million.
Fiscal year: 1998;
CEM funding: $5.5 million.
Fiscal year: 1999;
CEM funding: $4.5 million.
Fiscal year: 2000;
CEM funding: $2.5 million.
Fiscal year: 2001;
CEM funding: $2.5 million.
Fiscal year: 2002;
CEM funding: $2.4 million.
Source: EPA operating budget plans.
[End of figure]
Approximately 75 percent of the CEM funding was provided to Region V in
fiscal years 1992 through 2002. The director of the Water Division for
EPA Region V stated that when the CEM funding was first available for
work on both RAPs and LaMPs, 7 or 8 staff positions were provided for
each of the 6 states in the region. The decrease in funding resulted in
reducing the staff committed to RAPs in the three states that we
visited”Ohio, Michigan, and Wisconsin. For example, in Wisconsin, as
the funding for RAPs and other Great Lakes activities was reduced, the
state reduced its staff working on RAPs and LaMPs from 9 full-time to
one full-time and one part-time position. As a result, the state could
no longer provide support for the local RAP committees or updates for
the RAPs and stopped doing remedial action work at the contaminated
areas, unless it related to some other program, such as Superfund.
EPA also reduced its staffing levels for the RAPs. The agency had funded
RAP liaison positions to facilitate and coordinate work on RAPs. In
EPA‘s Region V, which encompasses most of the areas of concern, there
were 21 RAP liaisons with at least one assigned to each area in 1999.
As of 2001 this staffing had been reduced to two part-time and one full-
time liaison. An EPA official responsible for the liaisons stated that
work on RAPs was no longer a priority and priorities had shifted to
LaMPs. In fiscal year 2002, one person was assigned to work full-time
on the RAP for the Detroit River area, but neither Region V nor EPA
headquarters had any staff responsible for monitoring RAP progress.
GLNPO has provided grant funding to the Great Lakes Commission, a
binational agency promoting information sharing among Great Lakes
states, to update information on the contaminated areas and the RAPs on
GLNPO‘s web site. The information provides an overview of the status of
RAPs with updated information provided by state or local officials. The
information, however, does not present an analysis of the progress in
cleaning up areas or time frames for expected completion.
EPA Has Shifted Its Focus to Other Great Lakes Activities:
EPA has reduced support for the RAP process and redirected its efforts
to several other Great Lakes initiatives, many of which are required in
the agreement and either directly or indirectly affect the areas.
Specifically, the Water Divisions have focused resources on the
development of LaMPs. LaMPs address overall concerns in the open lake
waters, such as reduction in loadings of critical pollutants, but they
do not replace the RAPs, which are intended to clean up the shoreline
where most of the contamination occurs. GLNPO has been involved in
several other initiatives, including coordinating the development of a
Great Lakes strategy. The strategy was developed by the U.S. Policy
Committee, which is comprised of representatives from federal, state,
and tribal organizations responsible for the actions specified in the
agreement. The strategy sets forth certain goals, objectives, and
actions the parties agree to address, including the following.
* The reduction of toxic substances in the Great Lakes Basin ecosystem.
[The reduction of mercury and dioxin emissions from medical waste
incinerators was one objective under this goal. A key action for this
goal is that Minnesota will achieve a 70 percent reduction of its 1990
mercury emissions by 2005.]
* The development of environmental indicators for the Great Lakes
through a series of State of the Lakes Ecosystem Conferences (SOLEC) at
which indicators are discussed and agreed upon. These biennial
conferences, jointly sponsored by GLNPO and Environment Canada, bring
together representatives from federal, state, and provincial
organizations, and the general public. The latest conference, held in
October 2001, approved 33 of 80 indicators being proposed to assess
conditions in the Great Lakes.
* Maintaining a ship for research and monitoring on the Great Lakes and
providing another vessel for sampling contaminated sediment.
The strategy also addresses cleaning up areas through RAPs and sets
forth objectives to cleanup and delist three areas by 2005, and 10 by
2010 and an acceleration of sediment remediation efforts leading to the
cleanup of all sites by 2025. In addition, the strategy calls for
delisting guidelines for the areas, which were completed in December
2001. The guidelines include tasks such as requiring monitoring data
for achieving restoration goals and addressing impairments caused by
local sources within the areas. While the strategy sets forth numerous
environmental objectives state environmental officials have questioned
how the objectives will be achieved without additional funding.
Conclusions:
The process now being used to develop and implement RAPs for many of
the contaminated areas in the Great Lakes Basin has deviated from the
process outlined in the agreement between the United States and Canada.
Momentum for RAP activity waned since EPA diffused the responsibility
for ensuring RAP progress among its various offices, began reducing its
staff and process-related funding to the states, and shifted its
priorities to completing other activities in the Great Lakes Basin. As
a result, states and local communities have had to seek funding from
other federal programs or other sources in order to continue their
cleanup activities. Although EPA‘s initial investment in the process
yielded some results in terms of planning documents and public
involvement, EPA is not in a position to provide assurance that such
involvement will continue in the future or that the RAPs will be
implemented. Without a clear delineation of oversight responsibilities
within EPA for RAP implementation, all preliminary efforts and
expenditures may have been largely wasted. Absent EPA‘s support,
involvement, and consistent oversight, states and local communities
will have difficulty keeping the process moving forward.
Recommendations for Executive Action:
To help EPA more effectively oversee the RAP process and meet the
United States‘ commitment under the Great Lakes Water Quality
Agreement, we are recommending that the EPA administrator:
* clarify which office within EPA is responsible for ensuring RAP
implementation, and;
* identify the actions, time periods, and resources needed to help EPA
fulfill its RAP oversight responsibilities.
Agency Comments:
We provided EPA with a draft of this report for its review and comment.
The agency generally agreed with the findings and recommendations in
the report. EPA maintained that significant progress was being made at
the areas of concern with most RAPs having completed Stage 2 and one
having completed Stage 3. However, we and the IJC believe that this does
not represent significant progress, and no area of concern within the
United States has been delisted. EPA also stated that the RAP process
does not fairly represent environmental improvements that are being made
at the areas of concern. We recognize that some cleanup activities are
being taken within the areas of concern that relate to other program
requirements, but maintain that the RAP process is still the primary
cleanup vehicle. The agency also stated that it has been actively
involved in ensuring that RAPs are developed and it is reviewing the
RAP process to create a more effective program. While this may have
been true initially, EPA significantly reduced this support and
currently provides only limited support for the process. We commend EPA
for developing delisting principles and guidelines, but this effort
does not directly address the need to improve the overall effectiveness
of the RAP process. EPA agreed with our recommendations to clarify
which office within EPA is responsible for ensuring RAP implementation,
and it will seek to clarify these responsibilities within EPA. As to
our recommendation to identify actions, time periods, and resources
needed for fulfilling its RAP oversight responsibilities, EPA commented
that this would be a difficult task because of the wide spectrum and
scale of environmental problems within the areas of concern and other
priorities and responsibilities within EPA. We recognize that this task
may be difficult, but it is critical if EPA is to fulfill its oversight
responsibility. The full text of EPA‘s comments is included as appendix
II.
We conducted our review from September 2001 through April 2002 in
accordance with generally accepted government auditing standards. (See
appendix I for a detailed description of our scope and methodology.)
As arranged with your offices, we plan no further distribution of this
report until 30 days after the date of this letter unless you publicly
announce its contents earlier. At that time, we will send copies to
other appropriate congressional committees, the EPA administrator, and
the International Joint Commission. We will also make copies available
to others upon request.
Should you or your staff need further information, please contact me on
(202) 512-3841. Key contributors to this report are listed in appendix
III.
Signed by:
John B. Stephenson:
Director, Natural Resources and Environment:
List of Congressional Requesters:
Honorable Evan Bayh:
United States Senate:
The Honorable Mike DeWine:
United States Senate:
Honorable Carl Levin:
United States Senate:
Honorable Debbie Stabenow:
United States Senate:
Honorable James Oberstar:
House of Representatives:
Honorable Vernon Ehlers:
House of Representatives:
Honorable Steven LaTourette:
House of Representatives:
Honorable John Dingell:
House of Representatives:
Honorable Louise Slaughter:
House of Representatives:
Honorable Sherwood Boehlert:
House of Representatives:
Honorable Sherrod Brown:
House of Representatives:
Honorable Bart Stupak:
House of Representatives:
Honorable Marcy Kaptur:
House of Representatives:
Honorable Robert Borski:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To assess what progress had been made in developing and implementing
cleanup plans for the contaminated areas around the Great Lakes, we
reviewed the Great Lakes Water Quality Agreement of 1987, which set
forth the United States‘ obligation to cooperate with state governments
to ensure the cleanup of the contaminated areas and described the
process for developing and implementing the cleanup plans. We also used
Internet web site information that described the cleanup status at the
contaminated areas of concern. In addition, we visited areas of concern
(areas) in the Milwaukee Wisconsin Estuary and Ashtabula, Ohio, where
we discussed cleanup efforts, implementation plans, and assistance
provided by federal, state and local agencies. Further, we gathered and
analyzed information obtained through interviews with officials from
the International Joint Commission (IJC), the Great Lakes Commission,
the Northeast Midwest Institute, EPA Headquarters and Region V Office
of Water, and the Great Lakes National Program Office (GLNPO), the U.S.
Army Corps of Engineers, the Wisconsin Department of Natural Resources,
the Ohio Environmental Protection Agency, and local community advisory
groups responsible for cleanup activities at the selected areas.
To determine how the cleanup plans were being used at other areas, we
visited the Michigan Department of Environmental Quality, which manages
the greatest number of contaminated areas (14), and solicited telephone
and written comments from each of the other five Great Lakes states
concerning their cleanup activities and the remedial action plan
process. To further assess EPA efforts to provide oversight for the
contaminated area cleanup process, we reviewed EPA‘s legislative
responsibilities for providing oversight under the Clean Water Act and
discussed with EPA, state, and other federal agencies EPA‘s success in
fulfilling these responsibilities.
[End of section]
Appendix II: Comments from the Environmental Protection Agency:
United States Environmental Protection Agency:
Great Lakes National Program Office:
77 West Jackson Boulevard:
Chicago, IL 60604-3590:
May 15, 2002:
John B. Stephenson:
Director, Natural Resources and the Environment:
U.S. General Accounting Office:
Washington, DC 20548:
Dear Mr. Stephenson:
Thank you for the opportunity to review the proposed General Accounting
Office (GAO) Report; Great Lakes: EPA Needs to Define Organizational
Responsibilities Better for Effective Oversight and Cleanup of
Contaminated Areas. We appreciate your staffs efforts to understand the
complexities of the Remedial Action Plan (RAP) Program for the Great
Lakes Areas of Concern (AOCs) and we are giving careful consideration
to your recommendations. Our initial comments are outlined below, with
the understanding that EPA will be given an additional opportunity to
comment on the report after it is submitted to Congress.
Your first charge was to determine what progress has been made in
developing and implementing RAPs. I want to reaffirm the U.S. Great
Lakes Program's strong and ongoing commitment to the Great Lakes Water
Quality Agreement (the Agreement), and to the RAP process for the U.S.
AOCs. Since the 1987 signing of the Protocol to the Agreement, the U.S.
Great Lakes Program has focused a large amount of effort and resources
to restore these areas. And while we can always improve on the process,
I can confirm that much progress has been made toward restoring the
beneficial uses in these areas. We are committed to doing as much as
possible to meet all our responsibilities under the Agreement. As an
example, the recently released Great Lakes Strategy, a product of the
U.S. Policy Committee, focuses multi-agency resources and commitments
on the AOCs to help achieve the Strategy's goals of delisting at least
three AOCs by 2005 and a cumulative goal of ten by 2010.
The implementation of the identified remedial actions in the RAPs can
be complicated due to the multi-media nature of the problems
encountered and the inter-agency and inter-jurisdictional coordination
required to implement these actions. In addition, the very substantial
costs involved in many of these activities have slowed the rate of
progress in many AOCs. But this situation has not deterred the
achievement of significant progress in the AOCs. From a process
standpoint, most of the RAPs have completed Stage 2 documents, and one
has completed a Stage 3. Recently, the Presque Isle Bay, Pennsylvania
AOC Citizens Action Group has requested that the AOC be redesignated as
the first U.S. AOC to be an Area of Recovery.
While very important, these highlights of progress in the RAP process
do not fairly represent the actual on the ground improvements which are
being continuously implemented in all 31 U.S. AOCs. Numerous
contaminated sediment remediations, enforcement actions, infrastructure
improvements, habitat restoration projects, pollution prevention
programs, and educational opportunities are more accurate measures of
progress in achieving the restoration of the beneficial uses in the
AOCs and, eventually, to their formal delisting.
EPA is committed to tracking and reporting on progress achieved in the
AOCs: We have created and are actively maintaining a website for the
U.S. AOCs at [hyperlink, http://www.epa.gov/glnpo/aoc/].
In addition, we recently released a summary document entitled AR
Overview of U.S. Great Lakes Areas of Concern which is available from
EPA's Great Lakes National Program Office (GLNPO). This document will
be updated and released on a regular basis.
Your second charge was to assess the effectiveness of EPA's efforts to
ensure that RAPs are developed and implemented.
Section 118(3)(A) of the Clean Water Act calls for the Program Office
(GLNPO) to ensure that each Great Lakes State in which an AOC is
located submits a RAP for each AOC to the Program Office and to the
International Joint Commission. Through Coastal Environmental
Management (CEM) funding which provides resources for managing and
coordinating the RAP program, through the U.S. Policy Committee (which
includes federal and state agencies) that assists in overseeing the RAP
program, and by commitments included in the U.S. Great Lakes Strategy
(as mentioned above), EPA has been actively ensuring that RAPs are
being developed for all 31 U.S. AOCs and that the remedial actions
identified in the RAPs are being implemented under appropriate
environmental statutes and programs, and as resources are made
available.
To build upon this record of progress, EPA is actively reviewing the
RAP process to create a more effective program. We have been holding
internal discussions and working with our State partners to help refine
and redirect our efforts. One significant outcome of this effort has
been the completion of the federal/state authored paper entitled
Restoring U.S. Areas of Concern: Delisting Principles and Guidelines.
This document gives RAP practitioners important tools for insuring
progress and maintaining momentum in the AOCs. The U.S. RAP program
will continue to identify opportunities to improve the program and to
accelerate the rate of remedial activities and environmental
restoration.
It is important to remember that RAPs are only one of many requirements
that the U.S. has under the Agreement. The RAPs were not intended to
track and report on the many other provisions of the Agreement which
have substantial and immediate benefits for the AOCs.
Response to Recommendations:
Your first recommendation is that the EPA Administrator clarify which
office within EPA is responsible for ensuring RAP implementation.
As described in the GAO report, EPA's management responsibilities for
the RAP program has been modified over the life of the program. At the
moment, these responsibilities are divided between the Water Divisions
in EPA Regions 2, 3, and 5 and GLNPO. EPA will seek to clarify these
responsibilities in discussions with representatives from these three
Regions, GLNPO, and EPA headquarters.
Your second recommendation is that the EPA Administrator identify the
actions, time periods, and resources needed to help EPA fulfill its RAP
oversight responsibilities.
The identification of actions, time periods, and resources needed would
help the Agency fulfill its RAP oversight responsibilities. Reliably
assessing and fulfilling these needs, however, is very difficult, given
the wide spectrum and scale of the environmental problems which need to
be addressed to restore the AOCs, and the other important priorities
and programs that fall within EPA's responsibilities. EPA will discuss
this recommendation in detail and identify, where possible, the steps
needed to implement this recommendation.
It is important to understand that the RAP Program was never structured
or envisioned to provide the funding required to initiate all the
remedial actions identified during the RAP process. Rather, the limited
RAP funding was initially provided to assess and recommend the remedial
actions required to restore the AOCs and to manage and implement the
program. It should also be recognized that the required actions are
dependent upon the use of authorities across many agencies and many
levels of government and the full use of these authorities across
governmental agencies must be thoroughly considered.
In closing, I want to reiterate EPA's strong commitment to the RAP
Program for cleaning up and restoring Great Lakes AOCs. We have many
significant accomplishments that have bettered environmental conditions
in the AOCs, but we also recognize that the RAP process can be
significantly improved and that the GAO's conclusions and
recommendations can help ensure that even more environmental
improvements are made.
I appreciate the opportunity to coordinate with your staff on this
project and look forward to the final report. Should you need
additional information or have further questions, please contact Mr.
Gary Gulezian, Director of EPA's Great Lakes National Program Office,
at 312-886-4040.
Very truly yours,
Signed by:
Thomas V. Skinner:
Great Lakes National Program Manager:
[End of section]
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contact:
John Wanska (312) 220-7628:
Staff Acknowledgments:
Key contributors to this report were Willie E. Bailey, Jonathan S.
McMurray, Rosemary Torres-Lerma, Stephanie Luehr, and Karen Keegan.
[End of section]
Footnotes:
[1] LaMPs are management plans for the open waters of each lake to
reduce loadings of critical pollutants in order to restore beneficial
uses.
[2] See U.S. General Accounting Office, Water Pollution: Improved
Coordination to Clean Up the Great Lakes, [hyperlink,
http://www.gao.gov/products/GAO/RCED-90-197] (Washington: D.C.: Sept.
28, 1990).
[3] U.S. Environmental Protection Agency, EPA‘s Great Lakes Program
EPA/OIG Rept. 99P00212 (Washington, D.C.: Sept. 1, 1999).
[4] International Joint Commission, Tenth Biennial Report on Great
Lakes Water Quality, (June 29, 2000).
[End of section]
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