Great Lakes
Organizational Leadership and Restoration Goals Need to Be Better Defined for Monitoring Restoration Progress Gao ID: GAO-04-1024 September 28, 2004The Great Lakes remain environmentally vulnerable, prompting the United States and Canada to agree on actions to preserve and protect them. As requested, this report (1) determines the extent to which current EPA monitoring efforts provide information for assessing overall conditions in the Great Lakes Basin, (2) identifies existing restoration goals and whether monitoring is done to track goal progress, and (3) identifies the major challenges to setting restoration goals and developing a monitoring system.
Current Environmental Protection Agency (EPA) monitoring does not provide the comprehensive information needed to assess overall conditions in the Great Lakes Basin because the required coordinated joint U.S./Canadian monitoring program has not been fully developed. Information collected from monitoring by other federal and state agencies does not, by design, provide an overall assessment of the Great Lakes because it is collected to meet specific program objectives or limited to specific geographic areas. Multiple restoration goals have been proposed through efforts by EPA and other organizations. EPA developed basin-wide goals through its Great Lakes Strategy 2002 and goals for plans addressing individual lakes. Other organizations have also identified basin-wide restoration goals and priorities. Monitoring of progress toward goals is generally limited to tracking specific action items proposed in the Great Lakes Strategy 2002; other proposed goals are generally not monitored to determine progress. Efforts to coordinate basin-wide goals and a monitoring system face several challenges. The lack of clearly defined organizational leadership poses a major obstacle. Both EPA's Great Lakes National Program Office (GLNPO) and a newly created interagency task force have coordination roles raising uncertainty as to how leadership and coordination efforts will be exercised in the future. Second, coordinating existing restoration goals and monitoring activities among the many participating organizations within the United States, and between the United States and Canada is a significant challenge. Third, centralized information from monitoring activities is not yet available, making it difficult to assess restoration progress. In addition, an inventory system developed by EPA and Canada may not have adequate controls on voluntarily provided information.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-04-1024, Great Lakes: Organizational Leadership and Restoration Goals Need to Be Better Defined for Monitoring Restoration Progress
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
September 2004:
Great Lakes:
Organizational Leadership and Restoration Goals Need to Be Better
Defined for Monitoring Restoration Progress:
GAO-04-1024:
GAO Highlights:
Highlights of GAO-04-1024, a report to congressional requesters
Why GAO Did This Study:
The Great Lakes remain environmentally vulnerable, prompting the
United States and Canada to agree on actions to preserve and protect
them.
As requested, this report (1) determines the extent to which current
EPA monitoring efforts provide information for assessing overall
conditions in the Great Lakes Basin, (2) identifies existing
restoration goals and whether monitoring is done to track goal
progress, and (3) identifies the major challenges to setting
restoration goals and developing a monitoring system.
What GAO Found:
Current Environmental Protection Agency (EPA) monitoring does not
provide the comprehensive information needed to assess overall
conditions in the Great Lakes Basin because the required coordinated
joint U.S./Canadian monitoring program has not been fully developed.
Information collected from monitoring by other federal and state
agencies does not, by design, provide an overall assessment of the
Great Lakes because it is collected to meet specific program objectives
or limited to specific geographic areas.
Multiple restoration goals have been proposed through efforts by EPA
and other organizations. EPA developed basin-wide goals through its
Great Lakes Strategy 2002 and goals for plans addressing individual
lakes. Other organizations have also identified basin-wide restoration
goals and priorities. Monitoring of progress toward goals is generally
limited to tracking specific action items proposed in the Great Lakes
Strategy 2002; other proposed goals are generally not monitored to
determine progress.
Efforts to coordinate basin-wide goals and a monitoring system face
several challenges. The lack of clearly defined organizational
leadership poses a major obstacle. Both EPA‘s Great Lakes National
Program Office (GLNPO) and a newly created interagency task force have
coordination roles raising uncertainty as to how leadership and
coordination efforts will be exercised in the future. Second,
coordinating existing restoration goals and monitoring activities
among the many participating organizations within the United States,
and between the United States and Canada is a significant challenge.
Third, centralized information from monitoring activities is not yet
available, making it difficult to assess restoration progress. In
addition, an inventory system developed by EPA and Canada may not have
adequate controls on voluntarily provided information.
Great Lakes Basin Area in the United States and Canada:
[See PDF for image]
[End of figure]
What GAO Recommends:
GAO recommends EPA develop controls to ensure the Great Lakes
monitoring system inventory is complete, accurate, and consistent.
Also, the Congress may wish to consider clarifying if GLNPO or the
task force should lead restoration efforts and require development of
measurable basin-wide goals with a monitoring system for measuring
progress.
EPA agreed with GAO‘s recommendation regarding adequate inventory
monitoring controls. EPA believes responsibilities and relationships
for the task force and GLNPO are clearly stated in the executive order
and statute but did not address GAO‘s concerns about how GLNPO will
exercise its leadership and coordination responsibilities.
www.gao.gov/cgi-bin/getrpt?GAO-04-1024.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact John Stephenson (202)
512-3841 or stephensonj@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Current EPA Monitoring Efforts Do Not Provide Comprehensive Information
on the Condition of the Great Lakes and Monitoring by Other
Organizations Is Limited by Purpose and Scope:
Multiple Goals Exist for Monitoring Restoration Progress:
Significant Challenges Exist for Setting Basin-Wide Goals and
Developing a Monitoring System for the Great Lakes:
Conclusions:
Matter for Congressional Consideration:
Recommendation for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Federal, State, Canadian, and Other Organizations That
Provided Great Lakes Monitoring and Research Information:
Appendix III: Comments by Officials on Need for Indicators and
Monitoring in the Great Lakes Basin:
Appendix IV: State of Ohio Lake Erie Programs and Initiatives with
Monitoring Activities:
Appendix V: Observations on Goals and Monitoring Information Contained
in LaMPs for Four Great Lakes:
Appendix VI: Goals and Priorities Established by Three Great Lakes
Organizations:
Appendix VII: Comments from the Environmental Protection Agency:
Appendix VIII: GAO Contact and Staff Acknowledgments:
GAO Contact:
Staff Acknowledgments:
Table:
Table 1: Summary Comments by Officials on the Need for Indicators and
Comprehensive Monitoring in the Great Lakes Basin:
Figures:
Figure 1: Area Comprising the Great Lakes Basin:
Figure 2: GLNPO's Water Quality Survey Sampling Stations:
Figure 3: Differences in Characteristics of Lake Superior and Lake
Erie:
Abbreviations:
BEC: Binational Executive Committee:
EC: Environment Canada:
EPA: Environmental Protection Agency:
FWS: U.S. Department of Interior's Fish and Wildlife Service:
GLERL: Great Lakes Environmental Research Laboratory:
GLFC: Great Lakes Fishery Commission:
GLISP: Great Lakes International Surveillance Plan:
GLNPO: Great Lakes National Program Office:
GLWQA: Great Lakes Water Quality Agreement:
IADN: International Atmospheric Deposition Network:
IJC: International Joint Commission:
LaMP: Lakewide Management Plan:
NAWQA: National Water Quality Assessment:
NHEER: LNational Health Environmental Effects Research Laboratory:
NRRI: Natural Resources Research Institute:
NOAA: National Oceanic and Atmospheric Administration:
ORD: Office of Research and Development:
PCB: polychlorinated biphenyl:
SOLEC: State of the Lakes Ecosystem Conference:
TMDL: Total Maximum Daily Load:
USGS: U.S. Geological Survey:
USPC: U.S. Policy Committee:
United States Government Accountability Office:
Washington, DC 20548:
September 28, 2004:
Congressional Requesters:
The Great Lakes, the largest system of freshwater in the world, is
recognized by the United States and Canada as a natural resource that
is threatened on many environmental fronts. Recently discovered
conditions such as the reemergence in Lake Erie of a "dead zone"--an
area that has little or no dissolved oxygen and, therefore, cannot
support aquatic life--have renewed concerns about the overall
ecological health of the Great Lakes Basin, which includes the five
Great Lakes--Superior, Michigan, Huron, Erie, and Ontario--and a large
land area that extends beyond the lakes, including their watersheds,
tributaries, connecting channels, and a portion of the St. Lawrence
River. While the two countries have made some progress in protecting
and restoring the Great Lakes ecosystem--the air, water, land, and
living organisms within the basin--polluted beaches are frequently
closed to swimmers, fish are unsafe to eat for high-risk individuals,
and raw sewage is still being dumped into the lakes. While some
information on environmental conditions of the Great Lakes is
available, questions remain as to overall conditions and the progress
of restoration.
As concern increased over the contamination of the Great Lakes, the
United States and Canada signed the first international Great Lakes
Water Quality Agreement (GLWQA) in 1972. In the agreement, the United
States and Canada agreed to restore and maintain the chemical,
physical, and biological integrity of the Great Lakes Basin. The
overall goals of the GLWQA are to restore and enhance water quality in
the lakes. In 1978, the parties signed another Great Lakes Water
Quality Agreement that reaffirmed their determination to restore and
enhance water quality and called for increasing control of toxic
substances throughout the Great Lakes Basin. Subsequently, amendments
were made to the 1978 agreement in 1983 and 1987. The 1987 Protocol
amendments added several annexes that focused on specific environmental
concerns and amended one, Annex 11, on surveillance and monitoring.
Annex 11 requires the two countries to undertake a joint program to,
among other things, monitor restoration progress and assess the degree
to which the parties are complying with the requirements and objectives
of the agreement. Monitoring is accomplished through various sampling
methods, such as using air monitoring equipment to measure the
deposition of toxic chemicals. Monitoring may help identify the source
and extent of problems and aid decision makers in setting restoration
goals, taking action, and determining the extent to which goals are
being met. Goals should be stated in measurable terms in order to
monitor progress. In an effort to establish restoration strategies to
meet the overall goals of the GLWQA, the U.S. Policy Committee (USPC)æa
forum of senior level representatives from the federal, state, and
tribal government agencies that share responsibility for environmental
protection and resource management in the Great Lakesædeveloped the
Great Lakes Strategy 2002. EPA efforts in establishing goals also
include helping to develop Lakewide Management Plans (LaMP) for each of
the individual Great Lakes.
In addition, a joint effort by the two countries to assess and report
on environmental conditions in the Great Lakes began in 1994, with the
first State of the Lakes Ecosystem Conference (SOLEC). The conference
has convened every 2 years thereafter and its proceedings are used as a
basis for reporting on the state of the lakes. In the late 1990s, SOLEC
began developing a comprehensive set of indicators on the condition of
the Great Lakes ecosystem. SOLEC's reports have described indicators
such as chemical contaminants in edible fish tissue and toxic chemical
concentrations in offshore waters.
The Clean Water Act charges the U.S. Environmental Protection Agency
(EPA) with leading the effort to meet the requirements of the GLWQA.
The act also statutorily established 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 U.S.
responsibilities under the agreement. In addition to the various
governmental agencies involved in Great Lakes restoration, several
nongovernmental organizations have established restoration goals. In
2003, we reported that an overall strategy was needed to guide numerous
ongoing restoration activities and that indicators and a monitoring
system were needed to measure overall restoration progress.[Footnote 1]
You asked us to (1) determine the extent to which current EPA
monitoring efforts provide information for assessing overall conditions
in the Great Lakes Basin and what information is provided by other
organizations conducting monitoring in the Great Lakes, (2) identify
existing restoration goals and whether monitoring is done to track goal
progress, and (3) identify the major challenges to setting basin-wide
restoration goals and developing a monitoring system for the Great
Lakes.
To address the extent to which information derived from monitoring is
useful for assessing overall conditions in the Great Lakes Basin, we
reviewed information on monitoring activities conducted by U.S. and
Canadian federal agencies and the eight states and two Canadian
provinces that share the basin. We also examined the monitoring
requirements included in the GLWQA and compared these requirements with
ongoing monitoring and SOLEC activities. To identify existing
restoration goals, we reviewed the goals and monitoring efforts
contained in the Great Lakes Strategy 2002 and EPA's LaMPs for four of
the five Great Lakes. We also examined the restoration goals of several
organizations participating in the restoration of the Great Lakes. To
identify major challenges to setting restoration goals and developing a
monitoring system for the Great Lakes, we obtained and analyzed
information on several barriers to progress and focused on four major
challenges involving organizational leadership, coordinating goals and
monitoring, centralized information on monitoring activities, and
environmental differences between the lakes. We conducted our work from
August 2003 to May 2004 in accordance with generally accepted
government auditing standards. A more detailed discussion of our scope
and methodology is outlined in appendix I.
Results in Brief:
Current EPA monitoring does not provide the comprehensive information
needed to monitor restoration progress and assess the degree to which
the parties are complying with the requirements and objectives of the
agreement because the coordinated joint U.S./Canadian monitoring
program mandated under the GLWQA has not been fully developed. Other
federal and state organizations are conducting monitoring efforts but,
while useful, they are limited to specific purposes and geographical
scope. Rather than developing a basin-wide monitoring system to assess
overall conditions in the Great Lakes, EPA focused its efforts on
supporting SOLEC in developing a comprehensive set of environmental
indicators and using some of the indicators for reporting on overall
conditions in the Great Lakes Basin. While SOLEC has identified and
evaluated a large number of indicators, both Canadian and U.S.
officials have questioned the value of the information reported by
SOLEC from these indicators because, among other things, it is not
based on their decision-making needs. Specifically, SOLEC attempts to
describe overall conditions based on information voluntarily provided
and maintained by others, and it does not assess whether conditions are
improving or deteriorating based on measurable restoration goals.
Additionally, most of the information collected from monitoring
activities by other federal and state organizations does not, by
design, provide an overall assessment of restoration progress in the
Great Lakes Basin because it is collected to meet specific program
objectives or limited to specific geographic areasæ such as monitoring
water quality to determine whether some beaches are safe for swimming
or monitoring to support research in a particular area of the Great
Lakes. State organizations generally conduct monitoring in the inland
and nearshore areas while federal monitoring extends to the open lake
water areas.
EPA and other organizations have proposed multiple restoration goals;
however, few have monitoring activities to track restoration progress
called for in the goals. EPA developed basin-wide goals through its
Great Lakes Strategy 2002 and devised goals for individual lakes in
LaMPs. Monitoring progress toward achieving goals is generally limited
to tracking action items proposed in the Great Lakes Strategy 2002; the
LaMPs discuss indicators and monitoring, but they are not often linked
to goals or do not show how progress toward goals will be measured.
Other organizations concerned with Great Lakes restoration, such as the
Council of Great Lakes Governors, have also identified basin-wide
restoration goals and priorities. Several of the organizations' goals
are similar, representing a relative consensus among the groups. While
these goals are useful in communicating what specific issues the groups
believe are important to the Great Lakes, these organizations may not
have the resources or capacity to engage in basin-wide monitoring, and
additional specifics may be needed to determine whether the goals are
being achieved.
Those involved in protecting and restoring the Great Lakes face four
significant challenges in setting measurable goals and developing a
basin-wide monitoring system: the lack of clearly defined
organizational leadership, the inherent difficulty associated with
coordinating existing goal setting and monitoring activities among the
many participating organizations in the United States and between the
United States and Canada, the lack of centralized information from
monitoring activities to assess restoration progress, and the unique
environmental dynamics of each of the lakes. First, responsibility for
leading and coordinating U.S. efforts to meet GLWQA requirements rests
with EPA and GLNPO, according to the Clean Water Act. However, this
role has never been completely filled by GLNPO because it has not fully
exercised its coordination authority. Other organizations have
attempted to fill the void. Most recently, this executive order created
a new interagency task force within EPA to coordinate Great Lakes
activities, but its long-term effectiveness is unclear because
executive orders may be changed or rescinded by future administrations,
and this executive order cannot be enforced in court as is often the
case with statutes. In addition, the future role of GLNPO and other
organizations in relation to the task force is unclear. Second,
existing restoration goals and monitoring activities in the United
States and within Canada need to be coordinated if basin-wide goals are
to be established and a joint monitoring system developed as called for
in the GLWQA. Given the extensiveness of Canada's efforts, and
agreements between Canada and the provinces of Ontario and Quebec, it
will be a challenge to coordinate with Canada in developing basin-wide
goals for measuring restoration progress. Third, the lack of an
accurate, complete, and centralized source of existing monitoring
information for coordinating activities and assessing basin-wide
conditions is a significant challenge. GLNPO and Environment Canada
have developed an Internet-based inventory for existing monitoring
systems, but this inventory will rely on voluntarily provided
information, which will not ensure enough control over the information
so that it will result in an inventory with complete, accurate, and
consistent information. Fourth, because each of the five Great Lakes
has unique environmental conditions, setting measurable goals that
reflect these differences and yet provide consistent basin-wide
information will be difficult.
To help ensure the coordination of the U.S. efforts in developing
basin-wide measurable restoration goals with a monitoring system, we
recommend that the Congress may wish to consider clarifying whether
GLNPO or the interagency task force should lead restoration efforts for
the United States and require the entity it selects to develop and
prioritize measurable goals for the Great Lakes Basin and develop and
implement a monitoring system to measure progress toward attaining
goals along with identifying actions that could assist in achieving
goals.
In addition, we are recommending that the EPA Administrator direct
GLNPO to develop controls for the automated inventory to ensure that
the information it contains is complete, accurate, and consistent.
Background:
The Great Lakes contain over 95 percent of the nation's surface
freshwater supply for the contiguous 48 states and more than 20 percent
of the world's freshwater supply. The lakes provide water for drinking,
transportation, power, recreation--such as swimming and fishingæand a
host of other uses for more than 30 million people who live in the
Great Lakes Basin, roughly 10 percent of the U.S. population and more
than 30 percent of the Canadian population. Spanning more than 750
miles from west to east, the basin encompasses nearly all of the state
of Michigan and parts of Illinois, Indiana, Minnesota, New York, Ohio,
Pennsylvania, Wisconsin, and the Canadian province of Ontario. Parts of
the St. Lawrence River, the connecting channel between Lake Ontario and
the Atlantic Ocean, flow through the provinces of both Ontario and
Quebec.
Figure 1: Area Comprising the Great Lakes Basin:
[See PDF for image]
[End of figure]
Recognizing their mutual interests in the Great Lakes and other
boundary waters, the United States and Great Britain signed the
Boundary Waters Treaty in 1909, which provided the United States and
Canada with a framework for dealing with future issues along the
border. The treaty established the International Joint Commission
(IJC), comprising three commissioners each from the United States and
from Canada, to help the two governments resolve and prevent disputes
concerning their shared boundary waters. Among other things, the IJC
also assists the governments in the implementation of the GLWQA,
reports every 2 years on implementation progress, and offers nonbinding
recommendations to the two governments. Signed in 1972, the GLWQA
focused on restoring and enhancing water quality in the lakes and
controlling phosphorous as a principal means of dealing with
eutrophication in the lakes. Under the terms of the GLWQA, the two
governments are required to conduct a comprehensive review of the
operation and effectiveness of the agreement every 6 years. The next
review is scheduled to begin in 2004, and based upon the results, the
two countries may decide to amend the agreement. The last review in
1999 found that certain sections of the agreement were outdated and
revisions were needed.
As amended, the GLWQA has 17 annexes that define in detail the specific
programs and activities that the two parties have agreed upon and
committed to implement. Most of the annexes specify pollution
prevention strategies. Annex 11 of the GLWQA calls for the parties to
implement a joint surveillance and monitoring program that, among other
things, evaluates water quality trends, identifies emerging problems,
and supports the development of remedial action plans for contaminated
areas---referred to as areas of concern---and LaMPs for the open waters
of each of the five lakes to reduce critical pollutants and to restore
and protect beneficial uses.[Footnote 2] Specifically, Annex 11 calls
for the monitoring program to include baseline data collection, sample
analysis, and evaluation and quality assurance programs to assess such
things as whole lake data including that for open waters and nearshore
areas of the lakes as well as fish and wildlife contaminants; inputs
from tributaries, point source discharges, atmosphere, and connecting
channels; and total pollutant loadings to and from the Great Lakes
system.
The monitoring program under Annex 11 is to be based on the Great Lakes
International Surveillance Plan (GLISP) developed before the current
requirements for a surveillance and monitoring system. Developing the
surveillance plan, which involved developing a separate plan for each
lake, required extensive efforts by U.S. and Canadian officials over
several years. However, according to one Canadian official involved in
the process, the plans were not completed to the point where they could
be implemented. The IJC's Water Quality Board was involved in the
management and development of the GLISP, but according to a binational
review of the GLWQA in 1999, the IJC's role was reduced after the GLQWA
amendments of 1987 placed more of the responsibility for data analysis
and reporting on the state of the Great Lakes environment with the two
governments. IJC's role today is one of assisting in the implementation
of the agreement and evaluating the actions of the two governments in
meeting the objectives of the GLWQA. After the GLISP effort, the
governments reduced support for the surveillance and monitoring called
for in the agreement, and abandoned the organizational structure
created to implement the monitoring plan, leaving in place only one of
the plan's initiatives, the International Atmospheric Deposition
Network (IADN), a network of 15 air-monitoring stations located
throughout the basin developed in response to the GLWQA requirement of
a monitoring program to allow assessment of inputs from the atmosphere
affecting the Great Lakes. In addition, under a separate annex in the
GLWQA (Annex 2), LaMPs are required to include, among other things, a
description of the surveillance and monitoring to be used to track the
effectiveness of remedial measures and the elimination of critical
pollutants. The agreement requires that updates to the LaMPs be
submitted to the IJC for review and comment. IJC is considering whether
to conduct a review of the LaMPs in 2004.
The Water Quality Act of 1987 amended the Clean Water Act to state that
EPA should take the lead and work with other federal agencies and state
and local authorities to meet the goals in the agreement. It also
established within EPA, GLNPO, to among other things, coordinate EPA's
actions aimed at improving Great Lakes water quality both at
headquarters and at the affected EPA regional offices, and to
coordinate EPA's actions with the actions of other federal agencies. As
of 2003, GLNPO's budget was $16 million, including $5 million allocated
for program costs, which includes 47 full-time EPA staff and 13 non-EPA
staff. The remaining costs included about $4.3 million per year for
monitoring and monitoring-related reporting, which included about $1.4
million to operate GLNPO's research vessel, the Lake Guardian. For
Canada, Environment Canada (EC) is the lead agency, which works in
cooperation with the provinces of Ontarioæin which parts of four of the
lakes are locatedæand Quebec, which administers the St. Lawrence River.
Coordination between EPA and EC is achieved through the Binational
Executive Committee (BEC). Subsequent to the GLQWA amendments of 1987,
the BEC was formed to coordinate programs and policies of the two
parties to facilitate GLWQA implementation. BEC, co-chaired by EPA and
EC, meets twice a year and membership includes federal, state, and
provincial officials from organizations involved in Great Lakes
activities. The BEC does not have authority to direct that projects or
programs be implemented but rather makes recommendations regarding
certain activities, such as the development of SOLEC. Funding provided
for BEC operations is limited, and it relies on funding from other
organizations to implement its recommendations.
In addition to the BEC, several organizations serve coordinating roles,
offer policy perspectives, or financially support restoration
activities for the Great Lakes, including the following:
* Council of Great Lakes Governors, a partnership of governors from the
eight Great Lakes states and the Canadian provinces of Ontario and
Quebec, encourages and facilitates environmentally responsible
economic growth throughout the Great Lakes region.
* Great Lakes Commission, an organization promoting the orderly,
integrated, and comprehensive development, use, and conservation of
water and related natural resources of the Great Lakes Basin and the
St. Lawrence River, includes representatives from the eight Great Lakes
states and the Canadian provinces of Ontario and Quebec.
* Great Lakes United, an international coalition group dedicated to
preserving and restoring the Great Lakes-St. Lawrence River ecosystem,
promotes effective policy initiatives, carries out education programs,
and promotes citizen action and grassroots leadership for Great Lakes
environmental activities. The coalition's member organizations
represent environmentalists, conservationists, hunters and anglers,
labor unions, communities, and citizens of the United States, Canada,
and First Nations and Tribes.
* United States Policy Committee, a group of senior level
representatives from federal, state, and tribal government agencies
with environmental protection or natural resource responsibilities in
the Great Lakes Basin. The group meets semiannually to coordinate
agency actions and commitments associated with the Great Lakes Strategy
2002.
* Great Lakes Fishery Commission, a binational commission created by
the Convention on Great Lakes Fisheries between the United States and
Canada in 1955, whose primary objectives are to coordinate fisheries
management and research, and to control sea lamprey. The U.S.
Department of State and Canada's Department of Fisheries and Oceans
provide funding for the commission.
* Great Lakes Interagency Task Force, an organization created within
EPA by executive order to provide coordination of federal activities
and promote regional collaboration within the Great Lakes Basin and
among other things, to develop outcome based goals for the Great Lakes
system. Assisting the task force is a working group composed of
regional federal officials with GLNPO providing resources for both
groups.
Current EPA Monitoring Efforts Do Not Provide Comprehensive Information
on the Condition of the Great Lakes and Monitoring by Other
Organizations Is Limited by Purpose and Scope:
Current EPA monitoring efforts do not provide comprehensive information
on the condition of the Great Lakes, and the coordinated joint
surveillance and monitoring program called for in the GLWQA has yet to
be fully developed. Other ongoing monitoring efforts by federal and
state agencies yield information that is limited to specific purposes
and geographical scope. The joint efforts by the United States and
Canada to develop information on Great Lakes indicators through the
SOLEC process does not fulfill the monitoring requirements of the GLWQA
or adequately assess basin-wide conditions of the lakes. Further, the
information reported from SOLEC is of questionable value to officials
making restoration decisions because it is not based on their decision-
making needs. Additionally, current monitoring efforts of federal and
state organizations do not, by design, provide comprehensive
information on the overall conditions of the Great Lakes. Most of the
information collected under these monitoring activities is designed to
meet specific program objectives or is limited to specific geographic
areas as opposed to providing an overall assessment of the Great Lakes
Basin.
Current Efforts Do Not Fulfill Monitoring Requirements of the GLWQA:
Annex 11 of the GLWQA calls for the United States and Canada to develop
a joint Great Lakes system-wide surveillance and monitoring program to,
among other things, provide information on restoration progress and
whether the objectives of the agreement are being achieved. This
program, however, has not been fully developed. Instead, officials from
GLNPO look upon SOLEC as the process by which indicators will be
developed to monitor environmental conditions and measure restoration
progress in the Great Lakes. However, as we reported in 2003, the SOLEC
process of holding conferences every 2 years to develop Great Lakes
indicators and monitor environmental conditions for subsequent
reporting on the state of the lakes falls short in several
areas.[Footnote 3] First, indicators assessed through the process do
not provide an adequate basis for making an overall assessment of Great
Lakes restoration because they rely on limited quantitative data and
subjective judgments. Second, the SOLEC process is dependent on the
voluntary participation of officials from federal and state agencies,
academic institutions, and other organizations. As a result, their
future commitment to providing information on indicators and monitoring
results, along with their future participation, is not assured.
Finally, most of the stated objectives for SOLEC do not align with the
surveillance and monitoring program envisioned in the GLWQA. The stated
objectives of SOLEC are to:
* assess the state of the Great Lakes ecosystem based on accepted
indicators,
* strengthen decision making and management,
* inform local decision makers of Great Lakes environmental issues,
and:
* provide a forum for communication and networking among stakeholders.
Other than the objective for assessing the state of the ecosystem based
on accepted indicators, the SOLEC objectives do not address issues
related to monitoring. GLNPO officials stated that the objective of
SOLEC is not to be a monitoring program but rather a reporting venue
for conditions in the Great Lakes. However, it is the only ongoing
effort to provide an overall assessment of the Great Lakes and,
according to 23 federal, state, and other environmental program
officials, a surveillance and monitoring system is still needed. For
example, a Michigan state official explained that a monitoring system
developed with the involvement of all stakeholders and focused on the
differences in individual lakes is needed. Appendix III contains the
specific comments from the officials we contacted regarding the need
for a monitoring system.
SOLEC's Monitoring Information Is of Questionable Value in Decision
Making:
The monitoring information developed and reported by SOLEC is of
questionable value to officials responsible for making restoration
decisions for several reasons. First, the information is not based on
their decision-making needs. State and federal agency officials stated
that the SOLEC process is not connected with the policy-making process.
For example, a Minnesota Pollution Control Agency official stated that
the SOLEC process is oriented toward the needs of researchers and has
not connected with the policy-making process for which indicators are
needed. A Michigan Department of Environmental Quality official stated
that SOLEC provides information based on data from only one or two
sampling locations and is not relevant from a state program
perspective. Canadian program officials shared these opinions, and one
official added that SOLEC data does not address local community
questions or program objectives.
The comments by program officials are supported by results from a peer
review of SOLEC in 2003 by an international panel of experts in large
indicator systems. While the panel had many favorable observations of
SOLEC, they noted a disconnect between the development of the
indicators and their usefulness to policy makers. The peer review
stated that, to be effective, the actual users must define indicators,
with policy makers and environmental managers involved in the early
stages of indicator development. In addition to these observations, in
the latest report on the state of the Great Lakes, one of the
management challenges discussed is how to better assist managers given
the large number of indicators.[Footnote 4] Specifically, the challenge
is to find a method of indexing indicators that better assists managers
and leads to more useful, informed decision making. The disconnect
between SOLEC and decision makers is further illustrated by the fact
that only two of the eight Great Lakes states we contacted were
reporting information from local monitoring efforts to support the
SOLEC process and that none of the states reported using the monitoring
information published by SOLEC to describe conditions of its local
water bodies or to measure restoration progress. One Minnesota official
stated that the former head of the state environmental agency viewed
SOLEC information as irrelevant to describe conditions within the
state.
A GLNPO official working on SOLEC stated that developing effective
indicators requires that you first ask what is to be measured, what the
best indicator is for this measurement, how much data are needed, who
will collect and handle the data for consistency, and how often the
measurement will take place. He stated that the need to ask these
questions dates back to the early 1980s, but actions to implement this
indicator-monitoring program never materialized. Instead, different
indicators and monitoring programs are being conducted by various
agencies using different sampling methodologies and protocols, and this
inconsistent local program information cannot, after the fact, be used
to make decisions about system-wide needs or environmental conditions.
Second, SOLEC information is based on limited data that further
detracts from its usefulness to decision makers. For example, of the 80
SOLEC indicators reported to describe the Great Lakes Basin in 2003,
evaluative data were only available for 43 of them. Often this data was
geographically limited and did not address conditions within the entire
basin. Additionally, the IJC reported in its 2002 biennial report that
sufficient data were not being collected from around the Great Lakes
and that the methods of collection, the data collection time frames,
the lack of uniform protocols, and the incompatible nature of some data
jeopardized their use as indicators.[Footnote 5]
Third, there is no guarantee that SOLEC information will be
consistently collected or will be available in the future. As we
reported earlier, the SOLEC process involves individuals providing
information on a voluntary basis with the indicator data residing in a
diverse number of sources with limited control by SOLEC
organizers.[Footnote 6] Therefore, there is no assurance that the
information will continue to be collected or consistently reported over
time. Environmental program officials from federal, state, and
provincial agencies stated that the process lacks sufficient and
consistent monitoring information to measure environmental restoration
progress. The SOLEC peer review group found that the SOLEC process has
serious flaws regarding lack of repeatability and transparency.
According to GLNPO officials, SOLEC organizers attempted to address the
issue of repeatability and transparency in 2003 by issuing a technical
report, which provides additional information on data sources. Further,
the process is lacking in standard methodology, and SOLEC has yet to
establish standard protocols to improve data comparability and
reliability.
One attempt to measure restoration progress in the basin using SOLEC
indicators is presented in EPA's fiscal year 2005 budget justification.
To measure progress, a single quantitative score is derived based on a
formula using eight SOLEC indicators. Each indicator is given a score
from 1 to 5 based on the professional judgments of individuals
providing the indicator information. A score of 1 is considered poor,
and 5 is considered good. Totaling the individual indicator scores
resulted in a score of 20 based on a total 40-point scale for the Great
Lakes. While this is an attempt to measure overall progress, the
scoring process is based on a limited number of indicators, and the
point scores are based on subjective judgment. Further, the indicators
described in the budget justification do not align with the ones used
in developing the scores. According to GLNPO officials, this may have
resulted from information being submitted at different times during the
development of the budget justification.
Information from Other Federal and State Monitoring Efforts Is Limited
by Purpose and Geographic Scope:
In addition to EPA's efforts, several federal and state agencies
conduct monitoring for specific purposes within the open waters,
nearshore, and inland areas of the Great Lakes Basin.[Footnote 7]
Monitoring is done in these areas for assessing environmental
conditions, as part of ongoing federal or state programs, or for
research purposes. The geographic areas monitored are generally limited
and only specific conditions are monitored. In a few cases, such as
monitoring the air deposition of toxic substances, monitoring of
specific conditions covers an extensive area. Monitoring by state
organizations is generally limited to federal or state program purposes
and conducted in the nearshore or inland areas of the basin, such as
identifying impaired waterways that may be tributaries to the lakes
under the Clean Water Act. Open lake monitoring is generally done by
federal agencies, like GLNPO, for specific research or program purposes
and not as part of an overall assessment of the Great Lakes.
Monitoring by Federal Agencies:
Four federal agencies, EPA, National Oceanic and Atmospheric
Administration (NOAA), U.S. Geological Survey (USGS), U.S. Department
of Interior's Fish and Wildlife Service (FWS), and one international
commission, the Great Lakes Fishery Commission (GLFC), have ongoing
monitoring activities for specific purposes within limited areas of the
Great Lakes Basin. EPA's GLNPO conducts four monitoring activities.
First, GLNPO conducts annual monitoring of open lake water areas for
the specific purpose of gathering information on water quality and
biological conditions. The information gathered includes toxic
pollutant levels of persistent substances, such as phosphorous. These
sampling efforts are generally conducted twice each year, once in
spring and once in summer, when the Lake Guardian travels to various
fixed sampling sites on each of the lakes (see fig. 2). Sampling
information collected during these assessments is stored in an
automated database and is limited to assessing long-term trends in open
lake waters. GLNPO officials stated that it takes about 6 to 7 years of
data before enough information is available to identify a long-term
trend.
Figure 2: GLNPO's Water Quality Survey Sampling Stations:
[See PDF for image]
[End of figure]
Second, GLNPO conducts monitoring of sediment contaminants in the
nearshore areas of the Great Lakes that involves biological and
chemical sampling for benthic-bottom soil-contamination. Data is
collected from several sampling stations throughout the lakes to
assess, among other things, the presence of small invertebrates in
bottom sediments.[Footnote 8] These data are assessed with open lake
data to determine possible adverse impacts on the food web that
ultimately pose a human health risk. The scope of sediment monitoring
is limited to certain areas, and GLNPO officials stated that they
believe their main responsibility is open lake monitoring under the
GLWQA and that the Great Lakes states are responsible for inland and
tributary monitoring. Third, GLNPO conducts the U.S. portion of IADN
for the specific purpose of monitoring toxic substances deposited
through the air. Monitored toxic substances include polychlorinated
biphenyls (PCB) and trace metals, such as lead and cadmium, that have
entered the watershed. While GLNPO is responsible for monitoring in the
United States, EC is responsible for Canadian locations. IADN consists
of 5 master sampling stations and 10 satellite stations located
throughout the basin and is limited to identifying substances deposited
through the air. Fourth, GLNPO conducts an annual fish program to
monitor concentrations of contaminants in Great Lakes fish. GLNPO has
agreements with the Universities of Minnesota, Indiana, and Wisconsin,
along with USGS, to collect specific fish species from each lake and
grind them into paste to analyze for contaminants that might pose a
risk to humans if consumed.
In addition to GLNPO's monitoring efforts, EPA's Office of Research and
Development (ORD) funds research activities involving developing
indicators and Great Lakes monitoring. There are four divisions within
ORD's National Health Environmental Effects Research Laboratory
(NHEERL), and one of theseæthe Mid-Continent Ecology Division located
in Duluth, Minnesotaæconducts research related to fresh water issues
involving human health, which includes the Great Lakes. In addition to
the research conducted by this office, ORD, through its National Center
for Environmental Research, has an ongoing cooperative agreement with
the Natural Resources Research Institute (NRRI) of the University of
Minnesota, Duluth, to develop environmental indicators specifically for
the nearshore areas of the Great Lakes. Once NRRI develops indicators
for all of the nearshore areas, the results will be published and
submitted to ORD for developing an implementation plan measuring
environmental conditions in the Great Lakes, according to NRRI
researchers.
Two other federal agencies, NOAA and USGS, conduct monitoring for
specific purposes within the basin. NOAA's Great Lakes Environmental
Research Laboratory (GLERL) located in Ann Arbor, Michigan, has 15
specific legislative mandates for research or monitoring, according to
a GLERL official. Specific research efforts by NOAA are in areas such
as water quality, quantity, and levels. NOAA is also developing an
experimental Great Lakes Observing network. This network will consist
of observation buoys that are linked to satellites, strategically
located throughout the five Great Lakes, for collecting specific
chemical, physical, and biological information needed for ecosystem
forecasting. A NOAA prototype system is deployed in Lake Erie, using
three buoy sites, and focused on gathering information on the
reemergence of the lake's dead zone.
USGS conducts monitoring in the Great Lakes through its Great Lakes
Science Center located in Ann Arbor, Michigan. This monitoring is
conducted in the open lake areas as part of its fish assessment
program. The center operates five research vessels, one for each of the
five Great Lakes, to conduct research and monitoring for specific
purposes, such as determining the volume and presence of predator fish.
USGS also conducts monitoring in the Great Lakes Basin through its
National Water Quality Assessment (NAWQA) program to determine the
presence of pesticides, nutrients, volatile organic compounds, and
other contaminants in streams, groundwater, and aquatic ecosystems. Of
the 42 NAWQA studies conducted nationwide, 2 are within the Great Lakes
Basin.
Finally, FWS and other organizations conduct monitoring to determine
the sea lamprey impact on specific fish species, such as the lake
trout. This monitoring is funded by the GLFC and according to several
restoration officials, is the most comprehensive, coordinated, and
consistently funded monitoring efforts ongoing in the Great Lakes. The
commission receives about $16 million annually from the United States
and Canada to carry out activities to control the sea lamprey
population and monitoring activities to measure the success of these
control efforts. In addition to monitoring the sea lamprey, each of the
Great Lakes states monitors fish populations and their habitats as a
major component of the fish monitoring program. The primary objective
of the fish monitoring program is to assess changes in fish populations
for the purpose of restocking to meet local community and angler
objectives. The fish monitoring programs are generally initiated and
funded by state agencies, with monitoring results coordinated by the
GLFC.
Monitoring by State Organizations:
In each state, monitoring in the Great Lakes Basin is a mix of
activities done for both federal and state requirements. Each of the
Great Lakes states conducts monitoring for federal program
requirements, which include identifying impaired water bodies within
the state, including the Great Lakes Basin, and developing Total
Maximum Daily Load (TMDL) limits for identified pollutants as required
under the Clean Water Act. However, because each state uses its own
criteria and time schedule for identifying impaired water bodies, the
process is not done consistently throughout the United States or the
Great Lakes Basin.[Footnote 9] Another example of a federal program
involving state monitoring is the Beach Monitoring Program under the
Beach Act. This program involves sampling of only the nearshore waters
of state beaches for the presence of bacteria to determine if the water
is safe for swimming.
In addition, states conduct monitoring in the Great Lakes Basin for
state requirements. For example, in Ohio, two state agencies--the Ohio
Environmental Protection Agency and the Ohio Department of Natural
Resourcesæconduct routine monitoring in Lake Erie's nearshore and
inland areas for several state and federal programs. These agencies
conduct monitoring to assess water quality in the state's streams and
rivers, ambient groundwater quality, tributary quality, and changes in
fish and wildlife populations. Appendix IV contains information on nine
programs involving monitoring activities in Ohio. In addition to
federal program monitoring, some states fund and conduct their own
monitoring activities in the Great Lakes Basin. The extent to which
states conduct their own monitoring activities beyond federal
requirements is closely tied to available state funding for monitoring.
State organizations generally conduct monitoring activities in the
nearshore or inland areas. For example, Michigan has a state program to
address water quality issues with funding specifically devoted to
monitoring. Voters approved a special state bond issue authorityæthe
Clean Michigan Initiativeæin 1998, which provided funding to the
Michigan Department of Environmental Quality for surface water quality
monitoring. Supported by initial Clean Michigan Initiative funding in
2000, the Michigan program funds monitoring activities in the state's
rivers, streams, tributaries, and Great Lakes water bodies. Among other
things, monitoring is conducted to assess contaminant levels in fish
and other wildlife, as well as water and sediment.
Multiple Goals Exist for Monitoring Restoration Progress:
Multiple restoration goals have been proposed by EPA and other
organizations that could be a basis for monitoring restoration
progress. EPA developed basin-wide goals in its Great Lakes Strategy
2002 and goals for individual lakes in LaMPs. Other organizations
concerned with Great Lakes restoration, such as the Council of Great
Lakes Governors, have also identified basin-wide restoration goals and
priorities. Monitoring progress toward achieving goals is generally
limited to tracking specific action items contained in the Great Lakes
Strategy 2002; other proposed goals do not have associated monitoring
activities or monitoring plans to determine progress. Additional
specifics for many of the proposed goals and monitoring plans may be
needed if the goals are to be used in determining whether progress is
being achieved.
EPA's Efforts Have Produced Basin-Wide and Lake-Wide Goals:
EPA's efforts in developing the Great Lakes Strategy 2002 and LaMPs
have resulted in proposed goals for the overall basin and for
individual lakes. USPCæa group of mainly federal and state officials
from the Great Lakes states coordinated by GLNPOædeveloped and
published the Great Lakes Strategy 2002, which sets forth 4 overarching
goals, 33 subgoals, 23 objectives, and 103 key actions for the Great
Lakes. For example, one goal is "to protect human health and restore
and maintain stable, diverse, and self-sustaining populations of
plants, fish and other aquatic life, and wildlife in the Great Lakes
ecosystem." A key action under this goal is to continue human health
studies under the Great Lakes Human Health Effects Research Program and
make the results available to environmental managers and the public.
For monitoring the progress in achieving the strategy's goals, GLNPO is
tracking the implementation status of the actions in the strategy and,
as of May 2003, seven actions were reported by GLNPO as completed.
In addition, EPA has participated in developing LaMPs that are the
primary means for coordinating and planning ecosystem projects for each
lake, according to the Great Lakes Strategy 2002. The GLWQA requires
that LaMPs be developed for each lake, with the United States and
Canada responsible for preparing the plans in consultation with
relevant states and provincial governments.[Footnote 10] A GLNPO
manager for each LaMP coordinates EPA's efforts to develop the plans.
In developing LaMPs, the parties have agreed that they will report
progress every 2 years and that updates to each LaMP will be submitted
to the IJC for review and comment.
LaMPs have been prepared for four of the five Great LakesæErie,
Michigan, Ontario and Superioræand they present overviews of lake
conditions and general restoration needs.[Footnote 11] For example, the
Lake Michigan LaMP sets forth one overall goalæto restore and protect
the integrity of the Lake Michigan ecosystem through collaborative
partnerships--and 11 subgoals. These subgoals are stated as general
questions, such as "can we drink the water," or "can we swim in the
water." The LaMPs also generally discuss indicators and monitoring, but
they are not often linked to goals or how progress toward goals will be
measured. For example, the Lake Erie LaMP states that a working group
discussed indicators, but none were selected. While each LaMP describes
monitoring efforts to some extent, they usually do not define how
progress to achieve goals will be tracked. An exception to this is a
section of the Lake Superior LaMP addressing critical pollutants. See
appendix V for goals and monitoring information contained in LaMPs for
four of the Great Lakes.
Other Organizations Have Developed Basin-Wide Goals:
Three organizationsæthe Council of Great Lakes Governors, Great Lakes
Commission, and Great Lakes Unitedæhave independently of EPA developed
goals for the Great Lakes Basin. The goals are presented in general
terms, such as stopping the spread of invasive species or cleaning up
contaminated areas. Several of the organizations' goals are similar,
representing a relative consensus among the organizations. While the
goals are useful in communicating what specific issues the groups
believe are important to the Great Lakes, additional specifics, such as
which invasive species are to be controlled or by what time frame, may
be needed to determine whether the goals are being achieved. It should
be noted that these organizations do not have the resources of federal
or state agencies to address proposed goals and priorities and must
rely on others to take action. For some of the priorities, specific
federal agencies are identified to take actions. The goals or
priorities developed by the three organizations are summarized in
appendix VI.
One recent set of priorities was prepared by the Great Lakes Governors'
Priorities Task Force, which consisted of governors' representatives
for the eight Great Lakes states. After deliberating for approximately
2 years, this group reached consensus in 2003, on nine priorities to
guide Great Lakes restoration and protection efforts. These priorities
addressed a range of issues including protecting human health and
enhancing information collection and standardization. The priorities
are defined in general terms, such as "control pollution from diffuse
sources into water, land, and air." Details on the type and causes of
pollution to be assessed and the desired outcomes are not further
defined. After the priorities were reported, public sessions were held
in Great Lakes states to obtain reaction and input on the Governors'
goals. These sessions, however, are not expected to result in further
refinement of the priorities.
Similarly, the Great Lakes Commission, which includes representatives
from the eight Great Lakes states and the Canadian provinces of Ontario
and Quebec, established seven priorities for the Great Lakes such as
cleaning up toxic hot spots, controlling nonpoint source pollution, and
preventing the introduction or limiting the spread of invasive species.
Its report outlining the seven major priorities identifies an overall
goal for each priority.[Footnote 12] Each of the goals contains
recommendations for actions, and many goals are stated in general terms
with funding requests for a particular federal agency or organization
for implementation. For example, one action item under the goal for
cleaning up toxic hot spots recommends "ensure that polluters
responsible for sediment contamination pay their fair shareæ$5 million
annually to the U.S. Fish and Wildlife Serviceæfor Great Lakes
projects." While the Great Lakes Commission lists their seven
priorities, it is unclear what specific actions are necessary to
achieve the priorities.
Great Lakes United, a binational coalition that promotes citizen action
and grassroots leadership for Great Lakes environmental activities,
published a citizen's action agenda for the Great Lakes in 2003. This
document, and its summary version, describes what members consider to
be the seven major challenges to be addressed in the Great Lakes, such
as toxic cleanup, protecting and restoring species, and sustaining and
restoring water flows.[Footnote 13] Under each challenge, the agenda
recommends several action items for restoring the Great Lakes Basin.
Some of these action items have established time frames.
Significant Challenges Exist for Setting Basin-Wide Goals and
Developing a Monitoring System for the Great Lakes:
Coordinating the establishment of measurable goals and developing a
monitoring system for tracking progress in the Great Lakes are
difficult tasks that face significant challenges. Of great importance,
no single organizational entity has exercised leadership responsibility
for coordinating the establishing of specific goals and a monitoring
system. As we reported previously, under the Clean Water Act, GLNPO has
coordination authority over many Great Lakes activities but has not
fully exercised it. Further, it is uncertain whether the Executive
Order issued in May 2004, creating a Great Lakes Interagency Task
Force, will provide the needed stability in leadership.[Footnote 14]
Second, the restoration goal setting and monitoring efforts ongoing by
numerous governmental and nongovernmental organizations in the United
States and Canada will create a challenge for coordinating within and
between the two countries. Specific obstacles include coordinating the
goal setting efforts of the various Great Lakes organizations and
accounting for ongoing agreements within Canada when developing the
joint monitoring system called for in the GLWQA. Third, coordinating
information derived from the various monitoring activities of the
numerous groups involved in the Great Lakes is a significant challenge.
The lack of a centralized repository of monitoring information makes it
difficult to assess restoration progress. Fourth, because each of the
five Great Lakes has unique environmental conditions, it will be
difficult to establish measurable goals that reflect these differences
and yet provide consistent basin-wide information. One restoration
effort, the Chesapeake Bay Program, has developed measurable goals and
a defined organizational structure that may offer valuable lessons for
restoration efforts in the Great Lakes.
Great Lakes Restoration Efforts Lack Clearly Defined Organizational
Leadership:
Organizational leadership for setting goals and developing a monitoring
system has yet to be realized for the Great Lakes. Several attempts at
providing organizational leadership have not resulted in a stable
structure for leading Great Lakes restoration efforts. We previously
reported that, within the Great Lakes several entities are involved in
coordinating and planning, which has resulted in confusion by federal
and state officials as to which entity bears ultimate
responsibility.[Footnote 15] We further reported that the
responsibility for leading the U.S.'s Great Lakes efforts rests with
GLNPO and that it is not fully exercising its authority under the Clean
Water Act for coordinating Great Lakes restoration programs. We
recommended GLNPO fulfill its coordinating responsibilities and develop
an overarching Great Lakes restoration strategy. EPA promised to
provide a detailed response to our recommendations, but has not yet
done so. However, in 2003 an EPA official stated in congressional
testimony that the Clean Water Act does require EPA, and more
specifically GLNPO, to serve as the lead entity for coordinating the
protection and restoration of the Great Lakes system. The same official
stated in 2004 congressional testimony that our recommendations are
answered by the Executive Order and again promised a detailed response
to these recommendations. However, the Executive Order does not address
our recommendations.
As a result of the Executive Order issued in May 2004, which created a
Great Lakes Interagency Task Force within EPA, how GLNPO's leadership
role and coordination responsibilities will be exercised in the future
is unclear. Task force members include representatives from EPA, eight
other federal agencies with Great Lakes program responsibilities, and
the Council on Environmental Quality. Under the Executive Order, one of
the purposes of the task force is to coordinate government action
associated with the Great Lakes. The EPA Administrator chairs the task
force that is also charged with developing outcome-based goals and
collaborating with Canada and its provinces and with other binational
bodies involved in the Great Lakes region regarding policies,
strategies, projects, and priorities for the Great Lakes. The head of
GLNPO, the Great Lakes National Program Manager, chairs the working
group, and GLNPO staff are to assist both the task force and the
working group in performing their duties. While the Executive Order
addresses GLNPO's role with respect to the task force and working
group, it does not address GLNPO's existing responsibilities under the
Clean Water Act for coordinating EPA's activities with other federal
agencies and state and local authorities to meet GLWQA goals. The
coordination role for the task force under the Executive Order is very
similar to GLNPO's coordination role under the Clean Water Act.
However, because the Executive Order does not affect the statutory
obligations of federal agencies, GLNPO is still under a statutory
obligation to fulfill its coordination role. Moreover, under the Clean
Water Act, GLNPO is required to not only develop but also implement
specific action plans to carry out the responsibilities under GLWQA.
However, according to the Executive Order, GLNPO will participate on a
Great Lakes Regional Working Group that is responsible for coordinating
and making recommendations for implementing the task force polices and
strategies, but it will be the task force that actually implements
recommendations.
Existing coordination activities of USPC are also uncertain in light of
the Executive Order. The USPC is focused on coordinating federal,
state, and tribal government activities related to fulfilling the
GLWQA, and it developed the Great Lakes Strategy 2002 to set
restoration goals and actions. Membership on the USPC is similar to the
newly formed working group in that it includes regional federal
officials, and the GLNPO program manager chairs both groups and also
serves as the Acting Assistant Administrator for EPA's Office of
Enforcement and Compliance Assurance. According to the Director of
GLNPO, as of July 2004, when the last USPC semiannual meeting was held,
there were no plans to change the role of the USPC. Therefore, the
USPC, the task force working group, and GLNPO all seemingly are engaged
in coordinating federal regional activities in the Great Lakes Basin.
Coordinating Great Lakes research is another responsibility provided to
the task force under the Executive Order, but other organizations have
research responsibilities by statute. Specifically, NOAA's Great Lakes
Research Office, acting through the GLERL and other entities, is
responsible under the Clean Water Act for conducting Great Lakes
research and monitoring activities and annually reporting issues, on
which Great Lakes research is needed, to the Congress.[Footnote 16]
Each year GLERL and GLNPO are to prepare a joint research plan and to
provide a health research report to the Congress. Thus far, GLERL and
GLNPO have not prepared these plans or reported to the Congress because
funds were not requested or provided for the coordination and reporting
activities, according to agency officials. The GLERL Director stated
that they have about 15 specific legislative mandates involving Great
Lakes research. Coordinating and prioritizing research is also an
activity of the IJC's binational Council of Great Lakes Research
Managers. This council, established in 1984, proposes priority research
areas for the Great Lakes, and some of the proposals are priorities for
GLERL, in part, because the council is currently co-chaired by the
GLERL Director. Future councils, however, may not be co-chaired by the
GLERL Director, and priority research areas may not be addressed
because research managers are not bound to follow council priorities.
Finally, the creation of the task force and working group by the
Executive Order also raises questions about the permanency of this
organizational structure for addressing the long-term restoration needs
of the Great Lakes. Executive orders, such as the one creating the task
force, stay in effect despite changes in administrations, but they may
be amended or rescinded by a subsequent President. Moreover, the
Executive Order cannot be enforced in court, unlike statutory
provisions that can often be judicially enforced. Therefore, the task
force may prove to be a temporary rather than a permanent attempt at
coordinating and developing goals for the Great Lakes. Legislation was
proposed in 2004 to enact the provisions of the Executive Order into
law, but this legislation remains pending in the Congress.
Coordinating Restoration Goals and Monitoring Activities within the
United States and Canada Poses Challenges for a Basin-Wide Approach:
Many organizations participating in the restoration of the Great Lakes
have independently developed goals for the Great Lakes Basin. However,
these organizations have tended to develop goals independently of EPA
and one another, resulting in duplicative efforts and the lack of
prioritization of goals. We previously reported that the numerous
restoration strategies containing goals developed by various
organizations did not provide an overarching approach that can be used
as a blueprint to guide overall restoration activities.[Footnote 17]
The situation remains the same today with several organizations
developing strategies and goals, without clearly defined leadership
responsibilities to bring together or coordinate the various efforts.
In some cases, the goals developed are very similar to each other. For
example, the Council of Great Lakes Governors and the Great Lakes
Commission both have similar goals relating to cleaning up of areas of
concern[Footnote 18] and stopping the spread of invasive species. Yet,
consensus has not been reached by the various organizations as to
specifically how such goals should be measured.
The leadership to coordinate goal setting efforts has not yet
materialized. There is no one organization or group of organizations
that is recognized as the leader. For example, at a Senate hearing on
Great Lakes restoration efforts in 2003, the hearing chairman asked a
panel of federal agency officials, including the Great Lakes National
Program Manager, if there was an orchestra leader for the efforts in
the Great Lakes, and none of the panel members volunteered a response.
Similarly, during an IJC conference session in 2003, where the
leadership for the various Great Lakes organizations was addressed, the
Great Lakes National Program Manager stated that because of the number
of groups involved in the Great Lakes, there is a need to find a way to
work together toward goals; however, he was reluctant to lead this
effort. The recently created Great Lakes Interagency Task Force was
charged with establishing a process for collaboration among task force
members to, among other things, develop outcome-based goals for the
Great Lakes system. The desired outcomes are conditions such as cleaner
water or sustainable fisheries.
Federal and state program officials acknowledge that limited
coordination of monitoring activities now exists and that there is no
single organization in place to direct the coordination of monitoring
efforts. One attempt to coordinate monitoring involving research
vessels on the Great Lakes began in 1997, by the IJC's Council of Great
Lakes Research Managers. The impetus for this effort was that over 60
research vessels were operating independently in the basin without
coordination or collaboration and with limited monitoring funds. Since
that time the IJC has been developing an inventory of Great Lakes
research vessels that was placed on a Web site designed to identify the
ships, scientific equipment, general research schedules, and points of
contact to aid in coordinating operations and sharing resources. The
extent that this inventory has facilitated coordination has yet to be
determined, however, coordination has begun through sharing of
information on research vessels, according to an IJC official.
Further, existing agreements on restoration goals and monitoring
between Canada and its provincial governments of Ontario and Quebec
will need to be considered in developing basin-wide goals if a joint
U.S.-Canada monitoring system is to be developed as required under the
GLWQA. Four of the five Great Lakes are shared by the United States and
Canada and share many of the same environmental problems. The
restoration goals and monitoring efforts developed in Canada to address
these problems are important for a coordinated effort by the two
countries. One set of goals to consider are in an agreement reached in
2002, between the governments of Canada and Ontario on overall goals
and actions to be taken to protect, restore, and conserve the Great
Lakes Basin ecosystem. This agreementæthe Canada-Ontario
agreementæcontains four annexes that address areas of concern, harmful
pollutants, lakewide management, monitoring, and information
management. Each annex contains overall goals to be achieved over a 5-
year period and results that the parties have agreed to achieve
together or individually. For example, one result under the lakewide
management annex is "reductions in the release of harmful pollutants on
a lake-by-lake basis."
Another agreement containing goals that should be considered involves
restoring the St. Lawrence River. This agreement--the St. Lawrence
Action Plan--was reached in 1988, between officials of Canada and the
province of Quebec and was a 5-year plan to address major problems of
industrial pollution threatening natural habitats. While the St.
Lawrence River is not geographically part of the Great Lakes Basin, it
is the connecting channel from Lake Ontario to the Atlantic Ocean, and
Quebec representatives participate in several of the organizations and
activities involving the Great Lakes such as the BEC, SOLEC, and the
Council of Great Lakes Research Managers. Since the first 5-year plan
in 1988, subsequent 5-year agreements, referred to as phases, have
focused on specific environmental priorities. The most recent
agreement, Phase III, also referred to as the St. Lawrence Vision 2000,
has three major objectives: protecting ecosystem and human health,
involving riverside communities in the process of helping to make the
St. Lawrence more accessible, and recovering its former uses. An
updated agreement, Phase IV, was being developed as of July 2004.
In addition to agreements, Canada and the two provinces have ongoing
monitoring activities that provide information on environmental
conditions in the Great Lakes Basin that will need to be considered in
developing a joint basin-wide monitoring system. For example, the
Ministry of the Environment, Ontario, conducts a Great Lakes nearshore
monitoring and assessment program that contains five monitoring
efforts. One of these involves sampling water quality at 66 sites
within the basin on a rotating basis to determine how water quality is
changing over time. Another component of the Ontario program is
monitoring of Great Lakes tributaries for toxic contaminants. This
monitoring is done to identify those tributaries to each lake having
significant concentrations of persistent bioaccumulative substances,
such as pesticides. In addition to monitoring conducted by the province
of Ontario, monitoring and reporting is done by Conservation
Authorities within the province. The Authorities consist of 36 local
community-based organizations established by provincial legislation
that manage watersheds throughout Ontario. The Authorities' monitoring
efforts are concentrated on tributary, stream, and inland areas of the
Great Lakes Basin, and reports are issued to the public on the state of
the watersheds.
For the St. Lawrence River in Quebec, a monitoring component for the
St. Lawrence Vision 2000 plan was developed by two Canadian federal
agencies, the Quebec Ministry of Environment and a nongovernmental
organization, to provide information on the environmental conditions in
the St. Lawrence River Basin. The program began in 2003, with the four
parties agreeing to conduct 21 monitoring activities until 2010, to
analyze and report on the results. The 21 activities are ongoing
activities by governmental organizations and were selected based on the
descriptive information provided on St. Lawrence conditions. Several
environmental issues are addressed, such as contamination of water,
sediments, and biological resources by toxic substances. To better
integrate the ongoing monitoring activities of the different
organizations, the parties agreed to improve the spatial and temporal
coverage of certain indicators, develop new indicators, and strive for
better collaboration.
In addition to efforts conducted by the provinces and others, EC
conducts monitoring in open lake waters, connecting channels, and
tributaries of the Great Lakes Basin. Open lake monitoring is conducted
at various sites for ensuring compliance with GLWQA water quality
objectives, evaluating trends, and identifying emerging issues. The
monitoring focuses on two lakes each year, with the exception of Lake
Michigan where it is the responsibility of the United States, to gather
information on contaminants, nutrients, metals, and physical parameters
at specific locations in each lake. Other monitoring programs involve
pesticides and emerging chemicals monitoring in selected watersheds and
embayments, and water quality monitoring of the Niagara, St. Lawrence,
St. Clair, and Detroit Rivers. For example, the monitoring of the
Niagara River is done as part of an agreement reached between EC, EPA,
Ontario Ministry of Environment, and the New York Department of
Environmental Conservation to reduce toxic chemical pollutants in the
Niagara River. Monitoring is done at an upstream location near Lake
Erie and downstream near Lake Ontario.
Lack of Centralized Information from Monitoring Activities Makes
Coordination to Assess Restoration Progress Difficult:
There is currently no centralized repository of information on
monitoring activities. As a result, it is difficult to coordinate
existing data and determine what additional information is needed to
establish baseline conditions and assess progress toward restoration
goals. Two related efforts are, however, under way to develop
inventories of the existing monitoring programs within the Great Lakes.
One effort is being led by the Great Lakes Commission, funded by grants
from the Joyce Foundation and GLNPO, to develop a comprehensive
inventory of environmental monitoring programs in the Great Lakes
Basin. Information is being gathered from existing sources and through
surveys and interviews with program officials. The information will be
placed in a database, analyzed to identify monitoring gaps in existing
programs, and used by the BEC to develop a monitoring coordination
framework, according to Great Lakes Commission officials. This project,
however, was funded on a one-time basis and does not include plans for
updating the inventory of monitoring data.
A related effort is being conducted by GLNPO and EC under the direction
of the BEC and is focused on developing an Internet-based inventory of
existing monitoring systems. The inventory will not contain monitoring
data, but rather a database of monitoring sources, referred to as
metadata by GLNPO officials.[Footnote 19] The inventory of existing
monitoring sources will rely on common data fields and terminology for
standardization of information, and GLNPO plans to manage the database.
To create the database, the BEC will request the various federal and
state agencies and other organizations conducting monitoring activities
to input information into the database, according to GLNPO officials.
Ultimate responsibility for data completeness and quality rests with
the BEC. However, it is unclear how this will be accomplished since the
BEC has limited resources to carry out this responsibility. Further,
since the input and annual update of monitoring information is
voluntary, it is unclear how a complete and accurate inventory can be
assured since there is no independent verification of the data. GLNPO
officials stated that, as of July 2004, the Web-based system is
developed, and they are awaiting organizations to enter information on
monitoring systems into the database.
Unique Environmental Conditions for Each Lake Makes Setting Basin-Wide
Goals Difficult:
While basin-wide goals are useful, existing goal-setting efforts are
complicated by the unique characteristics of each lake. The physical
magnitude of the basin is often recognized as a daunting challenge for
setting measurable restoration goals. Although the Great Lakes are
connected through rivers and channels, they are not one contiguous
water body but rather distinct lakes with unique environmental
conditions. The Great Lakes Basin area spans 750 miles and has multiple
environmental challenges. This presents challenges to setting goals and
developing a monitoring system that can be used to describe restoration
progress across the basin and also capture the uniqueness of each lake.
The distinct physical characteristics of the lakes are illustrated by
the differences between Lakes Superior and Erie. (See fig. 3.)
Figure 3: Differences in Characteristics of Lake Superior and Lake
Erie:
[See PDF for image]
[End of figure]
Lake Superior is a larger, deeper lake with a relatively sparse human
population within its watershed. Most of the shoreline of Lake Superior
is forested and not host to the extensive urban development along its
shores that Lake Erie has. For Lake Superior, the overarching concern
is to preserve current conditions and keep pollutants and invasive
species from entering the lake. Lake Erie has other unique
environmental problems, the most recent being the reemergence of a dead
zone in the central basin of the lake that is void of oxygen and cannot
support aquatic life. Recently, the phosphorus levels of the lake have
exceeded acceptable levels as the result of unknown causes. Research
efforts are now focused on determining the cause of the rise in
phosphorous levels, which cause harmful algae blooms. Because Lake Erie
is the shallowest of the Great Lakes and is subject to urban pressures,
it is sometimes cited as the lake that first develops environmental
problems within the Great Lakes Basin.
The differences between the Great Lakes pose a challenge to setting
basin-wide goals. While goals are needed to determine basin-wide
progress, goals for each lake are also needed to address specific
problems or public concerns for each lake. For Lake Superior, a major
concern is stopping pollutants from entering the lake, which is
addressed through a program that established a goal of zero-discharge
for point source pollutants.[Footnote 20] For Lake Erie, goals
developed by the Lake Erie Commission address other problems, such as
how remediating contaminated sediments in Lake Erie's harbors and
tributaries. The future challenge will be how to build on the existing
goal-setting efforts for each lake in developing measurable goals for
the Great Lakes Basin as a whole.
Chesapeake Bay Program May Offer Lessons Learned for Developing an
Organizational Structure and Setting Restoration Goals:
The Chesapeake Bay Program, a restoration effort lead by EPA, has
demonstrated that quantifiable and prioritized goals with definitive
time frames can be developed for measuring restoration progress. While
the Great Lakes have unique challenges, such as coordination with
Canada, the bay program also provides an example of how an
organizational structure can be created to successfully coordinate goal
setting.
Unlike the restoration goals prepared for the Great Lakes, the
Chesapeake Bay Program has specific, measurable goals with definitive
time frames that are linked to indicators and a monitoring and modeling
program.[Footnote 21] Overall goals developed for the program are
stated in a general fashion similar to many developed for the Great
Lakes and are to (1) address water quality and clarity problems caused
by excess nutrients, sediments, and toxics; (2) maintain and restore
living resources of the bay, such as controlling exotic species and
protecting crabs and oysters; (3) protect and restore vital habitats,
such as wetlands and submerged aquatic vegetation; (4) make sound land
use decisions, such as land conservation; and (5) engage the community
through education and outreach. However, the general goals are further
defined as specific commitments that are used to measure program
progress.
As of December 2003, the program was endorsing over 40 measurable
environmental commitments for the watershed. The program has
prioritized commitments included in the most recent bay agreement,
Chesapeake 2000, by identifying the 10 most important "keystone
commitments" for the bay for focusing their efforts on critical needs
and making the best use of resources and capabilities. For example, one
keystone commitment for the overall goal of maintaining and restoring
living resources in the bay, is that by 2010, at a minimum, a tenfold
increase in native oysters should be achieved in the Chesapeake Bay,
using a 1994 baseline. In addition, this commitment involves developing
appropriate research and management strategies for attaining this
increase.
According to program officials, defining measurable goals and
commitments up front is the key to the success of the Chesapeake Bay
Program. If the goals are developed first, then they can be linked to
the appropriate measurement and tracking activities and indicators to
evaluate progress. Once program officials analyze the data collected
from monitoring, modeling, and tracking programs to determine progress,
they can decide on the appropriate actions to take to maintain or
improve conditions. Officials from organizations involved in the
restoration and protection of the bay agree that defining goals up
front is important to the restoration effort and that the Chesapeake
Bay Program has done a good job in this regard. For example, an
official from the Chesapeake Bay Foundationæthe largest conservation
organization dedicated to saving the Chesapeake Bay watershedæstated
that the Chesapeake Bay Program does a good job in establishing clearly
defined goals and commitments and linking them to indicators and
monitoring to reflect the current overall conditions of the bay. In
addition, State of Maryland officials from the Department of
Environment and Department of Natural Resources stated that the goals
and commitments of the program mirror those established by the state
and that they are adequately linked to the monitoring and indicators
used by the program. Recently, however, concerns were raised regarding
how accurately the program's computer model estimates projected
reductions in nutrients. According to one program official, the
controversy highlights the need for reaching consensus on appropriate
measurement approaches and the need for peer review of all monitoring
and modeling protocols.
Finally, the program is an example of how a permanent organizational
structure was established to set measurable goals and to coordinate
restoration efforts. The organizational structure of the Chesapeake Bay
Program is founded on an agreement between three states, the District
of Columbia, and EPA with an executive council leading the program.
This council consists of three governors, the Mayor of the District of
Columbia, EPA's Administrator, and a representative from the Chesapeake
Bay Commission. The council establishes measurable program goals and
commitments in such areas as water clarity after receiving input from
several program committees and subcommittees. Restoration and
monitoring efforts are coordinated by a number of written agreements
between federal agencies and other organizations to focus resources in
certain areas, such as an agreement between the FWS and EPA to provide
technical assistance for various activities including habitat
classification and mapping, resource assessments, and field surveys and
inventories.
Conclusions:
A clearly defined organizational leadership structure is needed for
restoring the Great Lakes and in particular for developing measurable
basin-wide goals and a monitoring system as called for in the GLWQA and
the Clean Water Act. Several organizations have offered basin-wide
goals over the years, but none are guiding restoration efforts and
measurable progress remains an elusive information component. The
required monitoring system has not been fully developed and the vision
of having information to guide restoration efforts remains unfulfilled.
While the recent Executive Order creates a Great Lakes Interagency Task
Force within EPA to develop measurable goals and coordinate federal
activities, it is uncertain whether this task force will provide
definitive, stable leadership needed over time because it may be
readily changed by future executive orders. Additionally, while GLNPO
has existing statutory responsibility for coordinating Great Lakes
activities, it is unclear how its responsibilities and those of other
organizations fit with the coordination activities of the new task
force. EPA is now taking steps to implement the Executive Order;
however, it is unclear whether this fulfills its responsibilities under
the Clean Water Act. Absent a clearly defined leadership structure,
setting measurable goals and monitoring progress in the Great Lakes is
unlikely to be accomplished, and duplicative responsibilities for
coordination, goal setting, and monitoring may be inevitable. EPA has
recently demonstrated leadership on monitoring by developing an
inventory of all monitoring activities in the Great Lakes. While we
believe this is a worthwhile effort, controls should be in place to
ensure the completeness and accuracy of the data in the inventory.
Matter for Congressional Consideration:
In light of the uncertainty regarding how GLNPO's responsibilities fit
with the newly created Great Lakes Interagency Task Force and to help
ensure the coordination of U.S. efforts in developing basin-wide
measurable restoration goals for the Great Lakes, as well as the
development of a joint monitoring system based on those goals, the
Congress may want to consider:
* clarifying whether GLNPO or the task force should lead the U.S.
efforts in restoring the Great Lakes and requiring this entity, in
consultation with Canada, the governors of the Great Lakes states,
federal agencies, and other organizations, to develop and prioritize
specific measurable restoration goals for the Great Lakes Basin within
a certain time frame; and:
* requiring the entity to develop and implement monitoring activities
to measure progress toward attaining goals and identify actions that
could assist in achieving these goals.
If the Congress decides that the task force should have the leadership
role, it may also want to consider whether additional Great Lakes Basin
stakeholders should be task force members, such as representatives of
states and other organizations.
Recommendation for Executive Action:
To facilitate the coordination of monitoring activities by the various
federal, state, and other organizations within the Great Lakes Basin,
we recommend that the EPA Administrator direct GLNPO to develop
adequate controls for the inventory of monitoring systems to ensure
that inventory data is accurate, current, and complete so as to
facilitate users' efforts to coordinate monitoring activities.
Agency Comments and Our Evaluation:
GAO 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 stated that the inventory of
monitoring activities is a critical component for monitoring and
reporting efforts, and adequate controls are needed to ensure that data
are accurate, current, and complete in order to facilitate users'
efforts to coordinate monitoring activities. Accordingly, EPA stated it
has begun taking steps to develop these controls. Specifically, GLNPO
will lead the U.S. efforts to track entries into the inventory database
to ensure that data from all agencies are included. GLNPO will also
request annual verification and updating by organizations of their
information to ensure that the database is accurate and current. If
effectively implemented, these steps should help ensure the accuracy
and usefulness of the inventory for coordination purposes. Regarding
our matter for the Congress to consider clarifying leadership
responsibilities, EPA stated that it believes the responsibilities for
organizational leadership in the Great Lakes for both GLNPO and Great
Lakes Interagency Task Force are clearly stated in the Clean Water Act
and the Executive Order, respectively. While EPA describes the overall
structure and responsibilities of the task force and GLNPO to support
its position, it does not address our concern that similar coordination
responsibilities are assigned to different organizations under the
Executive Order and the Clean Water Act. EPA states that the Executive
Order appoints the Great Lakes National Program Manager as chair of the
Great Lakes Regional Working Group and that this will enhance GLNPO's
ability to meet its statutory obligation to coordinate federal
restoration activities. However, this does not address our point that
the Clean Water Act assigns GLNPO the responsibility of implementing
specific action plans to carry out U.S. responsibilities under the act,
while under the Executive Order, it is the task force, not GLNPO that
will implement recommendations of the working group. Further, EPA did
not address our concern that the task force does not provide the
definitive, stable leadership that is needed over time given that its
responsibilities may be changed by future executive orders. The full
text of EPA's comments is included in appendix VII.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to appropriate Congressional Committees; the EPA Administrator; various
other federal departments and agencies; and the International Joint
Commission. We also will make copies available to others upon request.
In addition, the report will be available at no charge on the GAO Web
site at http://www.gao.gov.
If you or your staff have any questions, please call me at (202) 512-
3841. Key contributors to this report are listed in appendix VIII.
Signed by:
John B. Stephenson:
Director, Natural Resources and Environment:
List of Congressional Requesters:
The Honorable Mike DeWine:
United States Senate:
The Honorable Russell Feingold:
United States Senate:
The Honorable Carl Levin:
United States Senate:
The Honorable Debbie Stabenow:
United States Senate:
The Honorable George Voinovich:
United States Senate:
The Honorable John Conyers, Jr.:
House of Representatives:
The Honorable John Dingell:
House of Representatives:
The Honorable Rahm Emanuel:
House of Representatives:
The Honorable Vernon Ehlers:
House of Representatives:
The Honorable Marcy Kaptur:
House of Representatives:
The Honorable Dale Kildee:
House of Representatives:
The Honorable Ron Kind:
House of Representatives:
The Honorable Mark Kirk:
House of Representatives:
The Honorable Dennis Kucinich:
House of Representatives:
The Honorable Steven LaTourette:
House of Representatives:
The Honorable Sander Levin:
House of Representatives:
The Honorable Candice Miller:
House of Representatives:
The Honorable James Oberstar:
House of Representatives:
The Honorable Jack Quinn:
House of Representatives:
The Honorable Bart Stupak:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To determine the extent to which information derived from monitoring is
useful for assessing overall conditions in the Great Lakes Basin, we
gathered and analyzed information on efforts to develop indicators
through the State of the Lakes Ecosystem Conferences (SOLEC), which is
a jointly sponsored effort by EPA's Great Lakes National Program Office
(GLNPO) and Environment Canada (EC). We also gathered and analyzed
information on monitoring activities obtained from state agency
officials in each of the eight Great Lakes statesæIllinois, Indiana,
Ohio, Michigan, Minnesota, New York, Pennsylvania, and Wisconsin; eight
federal agencies; two Canadian federal agencies; and provincial
agencies in Ontario and Quebec, Canada. For each agency, we obtained
information about ongoing monitoring efforts including the purpose of
the monitoring efforts, type of information collected during
monitoring, how the information was analyzed and used, and how
monitoring was coordinated with other federal or state agencies. A
detailed listing of the federal, state, and Canadian agencies that
provided monitoring information is included as appendix II. We reviewed
the monitoring requirements contained in the Great Lakes Water Quality
Agreement (GLWQA) and compared these requirements with the ongoing
monitoring activities.
To identify existing restoration goals and whether monitoring is done
to track goal progress, we obtained and analyzed Great Lakes
restoration goals prepared by several organizations including the
Council of Great Lakes Governors, Great Lakes Commission, Great Lakes
United, and U.S. Policy Committee. We analyzed the goals contained in
the Great Lakes Strategy 2002 and reviewed information on monitoring
the progress in achieving the goals. We further reviewed the
restoration goals and monitoring efforts contained in Lakewide
Management Plans (LaMP) prepared for four of the five Great Lakes. We
interviewed LaMP managers to determine the process followed for setting
goals and related monitoring activities. We also interviewed officials
conducting the monitoring for the Great Lakes Strategy 2002 and
reviewed monitoring progress reports.
To identify major challenges to setting restoration goals and
developing a monitoring system for the Great Lakes, we identified
barriers to accomplishing these tasks and gathered information on four
major challenges involving organizational responsibilities,
coordination of monitoring activities with Canada, centralized
information on monitoring activities, and unique lake environmental
conditions. We gathered and analyzed information on existing
organization responsibilities, including those established by the
GLWQA, statutes, and administrative decisions, along with the
organizational responsibilities set forth in a May 2004 executive
order. We interviewed officials and gathered information from EC, the
Ontario Ministry of Natural Resources and Ministry of the Environment,
and the Quebec Ministry of Environment to identify their ongoing
monitoring activities and challenges to Canada's participation in
developing and implementing a comprehensive monitoring system for the
Great Lakes. We identified and analyzed efforts for inventorying and
coordinating monitoring activities in the Great Lakes Basin and
obtained and analyzed information on a proposed Web based inventory of
monitoring efforts from GLNPO officials. We obtained and analyzed
documentation about the environmental conditions for each of the Great
Lakes and discussed with federal and state officials the difficulties
in developing a basin-wide monitoring system. Finally, we gathered
information on goals, monitoring, and the organizational structure for
the Chesapeake Bay Program. We interviewed program, state, and
nonprofit officials about how goals were developed, monitored, and
results communicated.
We performed our work from August 2003 to May 2004 in accordance with
generally accepted government auditing standards.
[End of section]
Appendix II: Federal, State, Canadian, and Other Organizations That
Provided Great Lakes Monitoring and Research Information:
Federal Agencies:
Environmental Protection Agency:
* Great Lakes National Program Office:
* Office of Research and Development:
* Chesapeake Bay Program:
* Region V:
Department of Interior:
* U. S. Fish and Wildlife Service:
* U. S. Geological Survey:
Department of Commerce:
* National Oceanic and Atmospheric Administration:
Department of Agriculture:
* Forest Service:
State Agencies:
Illinois:
* Illinois Environmental Protection Agency:
Indiana:
* Indiana Department of Environmental Management:
Ohio:
* Ohio Environmental Protection Agency:
* Ohio Department of Natural Resources:
Michigan:
* Michigan Department of Environmental Quality:
Minnesota:
* Minnesota Pollution Control Agency:
New York:
* New York State Department of Environmental Conservation:
Pennsylvania:
* Pennsylvania Department of Environmental Protection:
Wisconsin:
* Wisconsin Department of Natural Resources:
Canadian Agencies:
* Environment CanadaæOntario Region:
* Environment CanadaæQuebec Region:
* Ontario Ministry of Natural Resources:
* Ontario Ministry of the Environment:
* Ontario Great Lakes Fisheries Management:
* Conservation Ontario:
* Quebec Ministry of the Environment:
Other Organizations:
* Great Lakes Commission:
* The Nature Conservancy:
* Great Lakes Cities Initiative:
* International Joint Commission:
* University of Minnesota's Natural Resources Research Institute:
[End of section]
Appendix III: Comments by Officials on Need for Indicators and
Monitoring in the Great Lakes Basin:
Nearly all of the officials we contacted endorsed the need for a
comprehensive surveillance and monitoring system and their comments
include why a system is needed or factors to consider in developing a
system. See table 1 for a summary of these comments.
Table 1: Summary Comments by Officials on the Need for Indicators and
Comprehensive Monitoring in the Great Lakes Basin:
Agency/organization: Department of Interior: U. S. Geological Survey
(USGS);
Comments:
* A comprehensive surveillance and monitoring system with indicators is
needed and should be developed cooperatively between federal and state
agencies;
* No one agency has the capability to adequately monitor and assess the
Great Lakes ecosystem;
* The Environmental Protection Agency's (EPA) Great Lakes National
Program Offices' (GLNPO) strength is in open lake surveillance
monitoring, but the other agencies like USGS that have expertise in
tributary, wetland, and groundwater issues should come together to
develop a monitoring system.
Agency/organization: USGS--Great Lakes Science Center;
Comments:
* A comprehensive surveillance and monitoring system and indicators are
necessary for the Great Lakes;
* The Great Lakes Science Center integrates monitoring systems and
indicators with scientifically based proactive research;
a similar approach should be used to develop a comprehensive system.
Agency/organization: Department of Commerce: National Oceanic and
Atmospheric Administration (NOAA);
Comments:
* It is strongly believed that a comprehensive surveillance and
monitoring system, with indicators, is needed for the Great Lakes;
* The International Joint Commission's (IJC) Science Advisory Board
recommended that the U.S. and Canadian governments, while considering
revisions to the Great Lakes Water Quality Agreement (GLWQA), consider
requiring implementation of a systematic, science-based program that
has data quality objectives and data collection plans driven by
ecosystem behavior and contaminant fate and develop binational
surveillance programs for water quality management similar to the
Integrated Atmospheric Deposition Network.
Agency/organization: Department of Interior: Fish and Wildlife Service;
Comments:
* A well-coordinated, comprehensive basin-wide surveillance and
monitoring system with indicators for the Great Lakes is needed to
measure outcomes of programs, public investment, and status of
ecosystem health, while targeting actions strategically and allowing
for informed environmental decisions;
* A real-time comprehensive system of mapping, modeling, and
statistical assessment is needed to evaluate conservation and
restoration efforts.
Agency/organization: Department of Agriculture: Forest Service;
Comments:
* It would be valuable to have comprehensive monitoring of social,
economic, and environmental conditions in the Great Lakes Basin;
* Data of this kind, consistently collected at regular intervals, is
rare;
* Comprehensive monitoring could cover the range of economic sectors;
be grounded in suitable scientific disciplines;
and address information needs of city, county, state, and federal
governments, as well as other agencies, organizations, and individuals
that invest resources for public benefit.
Agency/organization: Environmental Protection Agency: GLNPO;
Comments:
* A comprehensive surveillance and monitoring system, with associated
environmental indicators, is necessary for the Great Lakes if we are to
be able to track environmental trends, understand emerging threats to
the ecosystem, implement appropriate control strategies, and assess the
effectiveness of our programs;
* With programs such as the State of the Lakes Ecosystem Conference
(SOLEC), the Binational Executive Committee's inventory of monitoring
programs, and the Presidents' recently signed an executive order
calling for a Great Lakes Interagency Task Force to plan and coordinate
Great Lakes activities, improvements are expected.
Agency/organization: Illinois Environmental Protection Agency;
Comments:
* A comprehensive surveillance and monitoring system with indicators is
needed and should be developed as a joint effort of the Great Lake
states, GLNPO, the Great Lakes Commission, and others, including
university researchers, to identify current and future potential
problems, develop and implement monitoring strategies, and seek options
for both short-term and long-term problem resolution.
Agency/organization: Indiana Department of Environmental Management;
Comments:
* A comprehensive surveillance and monitoring system with indicators is
needed. It should be developed in a cooperative effort by EPA Region 5
and GLNPO, the International Joint Commission, the Great Lakes
Commission, Environment Canada, and the EPA Region 5 states.
Agency/organization: Michigan Department of Environment Quality;
Comments:
* A comprehensive monitoring system for the Great Lakes is needed;
however, such a system must be developed with involvement from all
parties that have a stake in what happens in the Great Lakes;
* Each lake must be looked upon individually when it comes to
indicators because of their differences. One set of indicators will not
fit all the lakes;
* To address environmental conditions and know if things are getting
better or worse requires quantitative answers to specific problems
related to each individual lake.
Agency/organization: Minnesota Pollution Control Agency;
Comments:
* A comprehensive system is needed, but it must address both ambient
indicators such as fish, water, and beaches and the source indicators
needed to assess regional progress. The system should also be flexible
since there is no single set of indicators that apply to all the lakes;
* A lake trout indicator for Lake Superior might not be appropriate for
Lake Erie, and a yellow perch indictor well suited for Lake Erie would
not make sense for Lake Superior. The system should also use existing
monitoring and indicator systems as much as possible.
Agency/organization: New York State Department of Environment
Conservation;
Comments:
* A comprehensive system is needed, but it must be mandated by law and
adequately funded to support staff and equipment resourcing, analytical
analysis, and reporting over a long-term period.
Agency/organization: Ohio Environmental Protection Agency and Ohio
Department of Natural Resources;
Comments:
* It is important for the Great Lakes to have a long-term surveillance
and monitoring system with indicators. Appropriate indicators are
probably the most important things needed;
* A carefully chosen set of indicators that provide the best
information on the state of the lakes should be established before the
monitoring program is designed. We need to know the reasons why we
should monitor;
* Comprehensive monitoring for surface and groundwater in the Great
Lakes basin is needed to understand the availability, limits and
impacts of water withdrawals, as well as to support science-based
decision making under the agreement.
Agency/organization: Pennsylvania Office of Environmental Protection;
Comments:
* There are a number of systems already in place to survey and monitor
environmental parameters within the Great Lakes, such as SOLEC and
Lakewide Management Plans (LaMP);
* The bigger problem is in coordinating the surveillance and monitoring
and having enough resources to do a comprehensive job. A lot of
resources go into monitoring and surveillance, but the results are not
always shared with those who need the information.
Agency/organization: Wisconsin Department of Natural Resources;
Comments:
* One environmental official believes existing systems are adequate to
accomplish the stated tasks. Instead, better acceptance is needed by
concerned agencies and a willingness to provide funds for efficient and
technically credible monitoring efforts;
* Another environmental official believes some surveillance and
monitoring is needed;
however, it should involve a limited number of indicators and
biological measures established by system ecologists as a starting
point. More in-depth comprehensive surveillance and monitoring should
be targeted to problem areas and resource management concerns across
the Great Lakes.[A].
Agency/organization: Great Lakes Commission;
Comments:
* There is a great need for a comprehensive monitoring plan for the
Great Lakes, but to be effective it must have buy-in from all federal
state and local organizations with responsibility for activities in the
Great Lakes;
* The GLWQA is believed to be the tool needed to harmonize the U.S. and
Canadian governments' objectives for the Great Lakes;
however, a comprehensive indicator and monitoring system is required to
accomplish this.
Agency/organization: Nature Conservancy;
Comments:
* The lack of monitoring activity is a problem throughout the
ecosystem, and the development of a comprehensive monitoring system is
becoming more and more important each day. However, monitoring must be
based on documented and tested scientific information because of the
turnover of staff personnel in environmental and conservation areas.
Agency/organization: Great Lakes Cities Initiatives;
Comments:
* Because of philosophical differences and complexities among Great
Lakes Governors, monitoring at the state level is even more difficult
and requires the input of city mayors. There is a grave need for
someone to set priorities for restoration activities;
* With tight state budgets, there must be a collective body to set
priorities and oversee projects to prohibit duplicative spending. There
is a need for indicators and monitoring to say whether things are
getting better or worse in the Great Lakes;
* Currently, people are deciding independently what is most important,
and sufficient and accurate information is not available to assess
conditions.
Agency/organization: Environment Canada--Ontario Region;
Comments:
* Developing indicators for the Great Lakes is a work in progress, and
it is essential that these efforts continue. Appropriate indicators
must be developed and they must have linkage;
* A comprehensive monitoring system with indicators is needed, but
everyone with a vested interest in the Great Lakes must take part in
developing the indicators and the surveillance process to monitor them.
Agency/organization: Ontario Ministry of Natural Resources;
Comments:
* A comprehensive monitoring strategy and indicators are needed for the
Great Lakes;
however, the development of such a strategy will be a significant
challenge. There has been significant progress made in restoration of
the Great Lakes by various federal, state, and provincial
organizations;
* The problem is that there are too many different people with
different interests who do not always talk to each other. The sum of
the parts from various Great Lakes projects has been good, but the
results are by fluke, not by plan. There must be a process where
everyone participates and talks to each other.
Agency/organization: Ontario Great Lakes Fisheries Management;
Comments:
* A comprehensive monitoring system is needed. Threats to the
biological, physical, and chemical integrity of the Great Lakes require
an ecosystem and collaborative approach to objective setting, indicator
development, monitoring, and reporting.
Agency/organization: Environment Canada-- Quebec Region;
Comments:
* Such a program is definitely needed to report on the state and
evolution of the ecosystem. Considering the size of the drainage basin,
such a program should answer questions at the lake, river, and basin
levels. It should be based on a wide array of environmental indicators
and not just on a few highlighted ones;
* These indicators need to be useful and significant for government and
nongovernment managers and interested communities in order to have a
lasting impact. The indicators and monitoring must support the
decision-making process.
Agency/organization: Quebec Ministry of the Environment;
Comments:
* There is a need to monitor all the Great Lakes and the St. Lawrence
to determine progress toward restoring these watersheds. We must know
where we are and where we want to go before we can know if things are
getting better;
* There must be a relationship between the state of the environment and
the pressures placed on it from various contaminants and users. We
can't just monitor the lakes for the sake of monitoring;
* Monitoring in and of itself is not a good goal. Monitoring must be
done to answer specific management questions and make decisions about
what needs to be done.
Agency/organization: IJC;
Comments:
* A system of monitoring to measure indicators of ecosystem health is
essential for the Great Lakes. Without it we have no way of knowing
either the state of the lakes or whether our policies and programs are
effective in protecting the Great Lakes and those who rely on them for
drinking water, commerce, and quality of life;
* We need a coordinated approach across a multiplicity of institutions
to include EPA;
Environment Canada; fisheries and natural resource agencies; and
federal, state, and provincial governments;
* Presently there is growing enthusiasm for a Great Lakes observing
system, possibly lead by NOAA and coordinated with help from the IJC's
Council of Great Lakes Research Managers.
Sources: USGS, NOAA, FWS, FS, EPA, IL, IN, MI, MN, NY, OH, PA, WI,
Great Lakes Commission, Nature Conservancy, Great Lakes Cities
Initiatives, Environment Canada, Ontario Ministry of Natural Resources,
Quebec Ministry of the Environment, Ontario Great Lakes Fisheries
Management, International Joint Commission, and GAO.
[A] There was no definitive yes or no response from Wisconsin
officials, see the comment box.
[End of table]
[End of section]
Appendix IV: State of Ohio Lake Erie Programs and Initiatives with
Monitoring Activities:
Programs and initiatives with monitoring activities: Fish Consumption
Advisory Program;
Program objectives or focus: Analysis of sport fish caught in Ohio
waters for toxins;
results are basis for fish consumption advisories;
Program objectives or focus: State funded program, state administered.
Programs and initiatives with monitoring activities: Clean Water Act,
Section 305 (b);
Program objectives or focus: Biennially assess Ohio's water bodies and
report the status of impaired waters;
Program objectives or focus: Federally requirement, jointly funded by
federal and state;
administered by state.
Programs and initiatives with monitoring activities: Clean Water Act,
Section 303 (d);
Program objectives or focus: Protect impaired or threatened waters by
developing total maximum daily load limits by 2013;
Program objectives or focus: Federally requirement, jointly funded by
federal and state;
administered by state.
Programs and initiatives with monitoring activities: Ohio Department of
Natural Resources Coastal Urban Streams Program;
Program objectives or focus: Conduct nonpoint pollution abatement
program with focus on urban, residential, and commercial sources;
Program objectives or focus: State initiated, jointly funded by federal
and state.
Programs and initiatives with monitoring activities: Phosphorus
Reduction Strategy;
Program objectives or focus: Long-term program to reduce phosphorus
loading into Lake Erie;
Program objectives or focus: Joint federal and state funded program;
administered by state.
Programs and initiatives with monitoring activities: Ohio Department of
Natural Resources Bald Eagle Management Program;
Program objectives or focus: Program to reestablish the bald eagles
throughout Ohio;
Program objectives or focus: State initiated and funded.
Programs and initiatives with monitoring activities: Biological Indices
Program;
Program objectives or focus: Indices measuring the health of streams
based on health and diversity of aquatic communities;
Program objectives or focus: State initiated jointly funded by federal
and state.
Programs and initiatives with monitoring activities: Bacterial Beach
Monitoring Program;
Program objectives or focus: Monitor swimming beaches for fecal
bacteria contamination using E. coli as test organism;
Program objectives or focus: Joint federal and state funded program;
administered by state.
Programs and initiatives with monitoring activities: Ohio Tributary
Monitoring Program;
Program objectives or focus: An analysis of water samples collected
within the Lake Erie basin to assess sediment, nutrient, and metal
compositions;
Program objectives or focus: State initiated and funded.
Sources: Ohio Lake Erie Protection and Restoration Plan and GAO.
[End of table]
[End of section]
Appendix V: Observations on Goals and Monitoring Information Contained
in LaMPs for Four Great Lakes:
Lake Erie:
The Lake Erie Lakewide Management Plan (LaMP) contains goals stated as
four ecosystem management objectives focused on land use, nutrients,
aquatic and terrestrial species, and contaminants. For example, one
objective addressing contaminants is that toxic chemical and biological
contaminant loadings within the basin must decline to a level that
would permit sustainable use of natural resources. Each of the
objectives have two to four subobjectives that along with the
objectives, are not expressed in quantitative terms, priorities, or
with established time frames. One subobjective under the contaminants
objective is that toxic substances shall not exist in amounts
detrimental to human health or wildlife and that exotic species should
be prevented from colonizing the ecosystem, controlled where feasible,
and reduced to a point where they do not impair the ecological function
of Lake Erie. The plan does not state how progress in achieving these
objectives will be tracked or when the objectives should be met.
According to the plan, indicators were discussed but not selected by a
LaMP working group, and tracking progress toward goals will not begin
until indicators are selected. While indicators were not selected for
the LaMP, the LaMP stated that extensive monitoring activities were
ongoing and that an inventory conducted by Environment Canada showed
that there were over 90 independent monitoring programs under way
within the Lake Erie Basin. According to the LaMP, the indicators
ultimately chosen will determine whether current monitoring will
continue or new monitoring efforts will be initiated.
Lake Michigan:
The Lake Michigan LaMP sets forth one overall goalæto restore and
protect the integrity of the Lake Michigan ecosystem through
collaborative partnerships--and 11 subgoals. These subgoals are stated
as general questions, such as "can we drink the water," or "can we swim
in the water," with additional detail on the status of reaching the
subgoal, challenges, and key steps to be taken to achieve the subgoal's
target. However, while these subgoals and key steps do contain some
quantitative information and time frames, they are not prioritized and
cannot be linked to indicators and monitoring so that progress under
the subgoal can be measured. For example, under the subgoal "can we
swim in the water," the LaMP states that there were 206 beach closures
in 2000, and progress toward reaching the goal is "mixed." It further
identifies a challenge to develop real-time beach monitoring and that,
in 2004, the Great Lakes states should adopt criteria, standards, and
monitoring programs for beach bacteria. The LaMP acknowledges that
goals need to be linked to indicators and then to a monitoring strategy
for tracking restoration progress. However, according to the LaMP
Program Manager, the selection of indicators for Lake Michigan is still
in process, and the scope of monitoring efforts being conducted in the
Lake Michigan basin needs to be determined and coordinated. As a first
step in developing a coordinated strategic monitoring plan, a
monitoring groupæthe Lake Michigan Monitoring Coordination Councilæhas
an effort under way to determine ongoing monitoring activities in Lake
Michigan at the state and federal levels, according to the official.
Lake Ontario:
For Lake Ontario, U.S. and Canadian officials derived the LaMP's three
overall ecosystem goals from an earlier planæthe Lake Ontario Toxics
Management Planæthat was prepared in the late 1980s. For example, one
goal derived from the plan for the LaMP is "to maintain the Lake
Ontario ecosystem, and as necessary, restore or enhance it to support
self-reproducing and diverse biological communities." Under the three
overall ecosystem goals, the LaMP also included the management plan's
ecosystem objectives in five areas: aquatic communities, wildlife,
human health, habitat, and stewardship. These objectives describe in
general terms the conditions necessary to achieve the overall ecosystem
goals, but they are not stated in quantitative terms, prioritized, and
do not contain time frames. The Lake Ontario LaMP also contains 11
indicators based on the Lake Ontario Toxics Management Plan and State
of the Lakes Ecosystem Conference indicator work. According to the
LaMP, most indicator monitoring needs are being met with existing
monitoring programs, but further monitoring efforts are planned to
provide a more complete assessment of lake conditions. The LaMP states
that now that indicators have been adopted, U.S. and Canadian officials
will work to develop a "cooperative monitoring" approach for promoting
increased communication and coordination between their monitoring
programs.
Lake Superior:
The Lake Superior LaMP differs from other LaMPs in that it was
developed from an ongoing programæthe Lake Superior Binational Program.
This program was established in 1991 to restore and protect Lake
Superior, and it is a partnership between the United States; Canada;
the states of Minnesota, Wisconsin and Michigan; and the province of
Ontario and tribal government representatives that develop policies
through a number of task forces, workgroups, and committees. The LaMP
is one of the products developed by the program. The LaMP focuses on
six areas: critical pollutants, habitat, terrestrial wildlife
communities, aquatic communities, human health, and lake basin
sustainability. While these areas are not prioritized, for critical
pollutants, the LaMP provides specific, measurable goals for reducing
nine bioaccumulative toxic chemicals.[Footnote 22] For each chemical, a
1990 baseline amount was established, along with targets, for chemical
load reductions to be achieved every 5 years. For example, reducing
mercury sources 60 percent by 2000, 80 percent by 2010, and a 100
percent by 2020. Similar goals are set for the other pollutants. While
the goals are specific, the description of the monitoring process to
measure progress is less specific with little detail on the monitoring
required to measure progress toward goals. For the critical pollutants,
a menu of possible monitoring activities is mentioned, and the LaMP
states that more work is needed to develop a coordinated monitoring
program to evaluate progress toward goals and that data from state
sources is needed for measuring progress. According to Minnesota
officials responsible for tracking progress, they have difficulty
collecting information from state regulatory agencies and, therefore,
do not have sufficient information to measure progress toward reaching
goals. They added that funds are not available for the monitoring
needed to measure progress.
The goals for the other five areas in the Lake Superior LaMP are not as
specific and do not link indicators and monitoring to goals leaving
unclear how progress toward goals will be measured. For example, the
LaMP lists several strategies for pursuing sustainability, such as
developing recycling programs and attracting industries that use
recycled material but no quantitative information, prioritization, or
time frames are given for these strategies. The LaMP mentions several
indicators that have been developed to track progress in promoting
sustainability, however, these are not linked to specific measurable
goals. Sustainability indicators will be used, according to the LaMP,
to assess how fully the Binational Program's vision statement is being
realized. Ecosystem indicators for aquatic and terrestrial species are
still under development.
[End of section]
Appendix VI: Goals and Priorities Established by Three Great Lakes
Organizations:
Council of Great Lakes GovernorsæPriorities Task Force:
* Ensure the sustainable use of water resources while confirming that
the Great Lakes states retain authority over water use and diversion of
Great Lakes waters.
* Promote programs to protect human health against adverse effects of
pollution in the Great Lakes ecosystem.
* Control pollution from diffuse sources into the water, land, and air.
* Continue to reduce the introduction of persistent bioaccumulative
toxics into the Great Lakes ecosystem.
* Stop the introduction and spread of non-native aquatic invasive
species.
* Enhance fish and wildlife by restoring and protecting coastal
wetlands, fish, and wildlife habitats.
* Restore to environmental health the areas of concern identified by
the International Joint Commission as needing remediation.
* Standardize and enhance the methods by which information is
collected, recorded, and shared within the region.
* Adopt sustainable use practices that protect environmental resources
and may enhance the recreational and commercial value of our Great
Lakes.
Great Lakes Commission--The Great Lakes Program to Ensure Environmental
and Economic Prosperity:
* Restore and maintain beneficial uses in each of the 31 U.S. and
binational areas of concern or "toxic hot spots," with a special
emphasis on remediation of contaminated sediment.
* Restore and protect the ecological and economic health of the Great
Lakes by preventing the introduction of new invasive species and
limiting the spread of established ones.
* Improve Great Lakes water quality and economic productivity by
controlling nonpoint source pollution from water, land, and air
pathways.
* Restore 100,000 acres of wetlands and critical coastal habitat while
protecting existing high quality fish and wildlife habitat in the Great
Lakes Basin.
* Ensure the sustainable use and management of Great Lakes water
resources to protect environmental quality and provide for water-based
economic activity in the Great Lakes states.
* Meet domestic and international Great Lakes commitments through
adequate funding for, and the efficient and targeted operation of,
federally funded and management and research agencies.
* Maximize the commercial and recreational value of Great Lakes
waterways and other coastal areas by maintaining and constructing
critical infrastructure and implementing programs for sustainable use.
Great Lakes UnitedæA Citizens Action Agenda for Restoring the Great
Lakes and St. Lawrence River Ecosystem:
* Toxic Cleanup Action Agenda:
Lists five areas where action is needed, such as funding toxic
cleanups, coordinating cleanup efforts, and treating contaminants.
* Clean Production Action Agenda:
Lists seven areas where action is needed, such as design of
manufacturing products, minimizing resource extraction, and planning
and managing food production and agriculture in relation to the
surrounding ecosystem.
* Green Energy Action Agenda:
List five areas where action is needed, such as promoting energy
efficiency, conservation, and renewable energy sources.
* Sustainable Water Quantities and Flows Action Agenda:
Lists eight areas where action is needed such as implementing water
withdrawal reform and restoring basin ecosystem functions damaged or
lost due to harmful water withdrawal practices.
* Protecting and Restoring Species Action Agenda:
Lists 13 areas where action is needed to address invasive aquatic and
terrestrial species, and protect threatened species.
* Protecting and Restoring Habitats Action Agenda:
Lists 24 areas where action is needed to protect and restore aquatic,
forest, urban, and interconnecting habitats; and limit sprawl.
[End of section]
Appendix VII: Comments from the Environmental Protection Agency:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY:
OFFICE OF WATER:
WASHINGTON, D.C. 20460
SEP 20 2004:
Mr. John B. Stephenson:
Director:
Natural Resources and the Environment:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear John,
Thank you for the opportunity to review and comment on the Government
Accountability Office (GAO) draft report entitled Great Lakes:
Organizational Leadership and Restoration Goals Need to Be Better
Defined for Monitoring Restoration Progress. We appreciate GAO's
understanding of the dynamics of monitoring issues in the Great Lakes
and the complexities of coordinating among Federal, State, Provincial
and local monitoring programs. We have reviewed the report carefully
giving full consideration to the facts, conclusions and
recommendations. Below are the Environmental Protection Agency's (EPA)
comments that focus on the Matter for Congressional Consideration and
the Recommendation for Executive Actions.
Matter for Congressional Consideration:
The Matter for Congressional Consideration (pages 38-39) concerns a
perceived uncertainty between the relationship and responsibilities of
EPA's Great Lakes National Program Office (GLNPO) and the Great Lakes
Task Force. Contrary to the report's findings, EPA believes that the
relationships and responsibilities of each are clear as stated in the
Clean Water Act and the Executive Order 13340 (EO) signed by President
Bush on May 18, 2004. By establishing a Cabinet-level Task Force, the
EO focuses attention on the Great Lakes region, expands the scope of
collaboration among Federal entities, and establishes a forum for high-
level coordination of Federal Great Lakes restoration and protection
efforts.
The EO also establishes a structure of Federal coordination at the sub-
cabinet level. It establishes a Great Lakes Regional Working Group
(Working Group) composed of the appropriate regional administrator or
director with programmatic responsibility for the Great Lakes system
for each agency represented on the Task Force. The Working Group will
coordinate and make recommendations on how to implement the policies,
strategies, projects, and priorities of the Task Force. The EO appoints
the Great Lakes National Program Manager as chair of this Working
Group. This will enhance GLNPO's ability to meet its statutory
obligation to coordinate activities among the Federal agencies
responsible for contributing to the environmental restoration and
natural resource protection in the Great Lakes Basin.
The EO also directs the Task Force to convene and establish a process
for collaboration among the Task Force and Working Group members with
the Great Lakes States, local communities, tribes, regional bodies, and
other interests in the Great Lakes region. Just as in the Chesapeake
Bay, which you mention as a model in your report, there are multiple
entities with jurisdiction in the Great Lakes. The Executive Order
recognizes that there is a need for broader coordination in the Great
Lakes. By building a coalition in the region, the Task Force will
further the opportunities for coordination of basin-wide efforts.
Development of the Regional Collaboration is underway and a tenet of
the organizing group is the need to build upon the existing consensus
and progress in the region. As such, the issue of monitoring, which has
been identified by a number of regional groups as a consensus priority,
will be one of the issues addressed by this region-wide effort.
Recommendation for Executive Actions:
The Recommendation for Executive Actions (page 39) addresses the
development of adequate controls for the inventory of monitoring
systems to ensure that data are accurate, current and complete. We
agree with the recommendation and have taken steps to plan, coordinate,
monitor and develop indicators for measuring the health of the Great
Lakes.
The Parties to the Great Lakes Water Quality Agreement (GLWQA) --the
governments of Canada and the U.S. --established the Binational
Executive Committee (BEC) to coordinate the efforts of Federal, State
and Provincial environmental and natural resource agencies to restore
and maintain the chemical, physical and biological integrity of the
Great Lakes Basin ecosystem. Restoration goals are listed in the GLWQA
and detailed in the Lakewide Management Plans, the Great Lakes Strategy
2002 and the Canada-Ontario Agreement. Other organizations, such as the
International Joint Commission (UC), Great Lakes Commission, and
Council of Great Lakes Governors have also proposed goals, objectives
and milestones for the restoration efforts.
To track progress toward the goals and objectives, BEC has endorsed an
integrated system of monitoring and reporting that includes the
following ongoing and future actions:
1. Indicators: A comprehensive suite of Great Lakes Basin indicators
was developed under BEC direction and first proposed at the State of
the Lakes Ecosystem Conference (SOLEC) in 1998. Since then, the suite
has been updated and revised every two years. During 2003 and 2004, the
indicators were reviewed by two peer review panels, and recommendations
for improvements resulted in several adjustments to the indicators. The
indicators were developed based on information needed about Great Lakes
ecosystem components, not on currently existing monitoring programs.
2. Monitoring Inventory: To develop a comprehensive integrated system
to collect vital information on the Great Lakes, BEC and other agencies
want to evaluate the existing monitoring programs, what important
information is not collected currently, and what information could be
collected with the availability of additional resources. The binational
Monitoring Inventory is a critical component to the restoration of the
Great Lakes.
3. Cooperative Monitoring Program: The intent of the BEC direction is
to collect critical information about the Great Lakes ecosystem to make
better management decisions in an efficient and effective manner. The
Monitoring Inventory will provide data on duplicative efforts between
programs to correct potential inefficiencies. Environment Canada and
EPA are leading multi-agency discussions toward more integrated,
cooperative monitoring and data sharing based on information as
identified in the suite of Great Lakes indicators.
4. Reporting: A data collection program is useful if the data and the
subsequent information derived from the analysis are accurate and
provided in a timely manner. SOLEC provides regular, consistent
reporting on the state of the Great Lakes ecosystem components. The
State of the Great Lakes reports provide information by each indicator
and a synthesis of the data in a Great Lakes ecosystem context.
The binational Monitoring Inventory is a critical component for
monitoring and reporting efforts. BEC has a long-standing interest in
the accuracy, timeliness and completeness of the inventory data. GLNPO
will lead U.S. efforts to track the entries to the database and ensure
that the data from BEC agencies are included.
GLNPO will work with organizations to assure that the inventory data is
accurate, current and complete. As part of this effort, GLNPO will
request annually that organizations verify and update their information
to ensure that the database is accurate and current. Furthermore, GLNPO
will coordinate with Environment Canada to maintain and enhance the
capabilities of the Monitoring Inventory database.
EPA is committed to the restoration and protection of the Great Lakes.
Through the efforts of the U.S. and Canadian governments, we have
improved the environmental conditions of the Great Lakes. I appreciate
the efforts of GAO to review and report on this important matter and
EPA will consider the issues and recommendation presented in the
report.
I appreciate the opportunity to review and comment on the draft report.
Once released to EPA, we will respond to the report recommendation, as
appropriate.
Mr. Gary Gulezian, Director of the Great Lakes National Program Office,
is available to provide additional information and clarify issues
identified in the report. He may be reached at 312-886-4040.
Sincerely,
Signed by:
Benjamin H. Grumbles:
Acting Assistant Administrator:
[End of section]
Appendix VIII: GAO Contact and Staff Acknowledgments:
GAO Contact:
John B. Stephenson (202) 512-3841 (stephensonj@gao.gov):
Staff Acknowledgments:
In addition to the individual named above, Willie Bailey, Greg Carroll,
Nancy Crothers, John Delicath, Michael Hartnett, Karen Keegan, Amy
Webbink, and John Wanska made key contributions to this report.
FOOTNOTES
[1] GAO, Great Lakes: An Overall Strategy and Indicators for Measuring
Progress Are Needed to Better Achieve Restoration Goals, GAO-03-515
(Washington, D.C.: Apr. 30, 2003).
[2] We reported no the progress made on remedial action plans in GAO,
Great Lakes: EPA Needs to Define Organizational Responsibilities Better
for Effective Oversight and Cleanup of Contaminated Areas, GAO-02-563
(Washington, D.C.: May 17, 2002).
[3] GAO-03-515.
[4] Environment Canada and U.S. Environmental Protection Agency, State
of The Great Lakes 2003, EPA 905-R-03-004.
[5] IJC, 11th Biennial Report on Great Lakes Water Quality, (Sept. 12,
2002).
[6] GAO-03-515.
[7] Inland areas include rivers, tributaries, and streams flowing into
the lakes; nearshore includes the shoreline out to where the open lake
begins, which is where water is 30 feet deep or a distance of 2 miles
from the shoreline, according to GLNPO officials.
[8] Small invertebrates in sediments are bottom-dwelling organisms that
can become contaminated and consumed by birds or fish, which can
adversely affect the food web once humans eat these birds or fish.
[9] GAO, Water Quality: Inconsistent State Approaches Complicate
Nation's Efforts to Identify Its Most Polluted Waters, GAO-02-186
(Washington, D.C.: Jan. 11, 2002).
[10] Lake Michigan lies entirely within the United States and,
therefore, EPA is solely responsible for the Lake Michigan LaMP under
the GLWQA and the Clean Water Act.
[11] Lake Huron currently has an initiative action plan, which is
similar but is not considered a LaMP.
[12] Great Lakes Commission, Great Lakes Program to Ensure
Environmental and Economic Prosperity (March 2004).
[13] Great Lakes United, Citizen's Action Agenda for Restoring the
Great LakesæSt. Lawrence River Ecosystem, and Great Lakes Green Book
(June 2003).
[14] Exec. Order No. 13340, 69 Fed. Reg. 29043 (May 18, 2004).
[15] GAO-03-515.
[16] 33 U.S.C. § 1268(d).
[17] GAO-03-515.
[18] Areas of concern are specific areas of contamination in the Great
Lakes.
[19] Metadata are data about databases describing various attributes
such as who is responsible for the database and the data content.
[20] Point source pollutants are those that contribute pollutants
directly to a body of water from a pipe or other discrete conveyance.
[21] The Chesapeake Bay Agreement in 1983 established the Chesapeake
Executive Council to assess and oversee the implementation of
coordinated plans to improve and protect the water quality and living
resources of the Chesapeake Bay estuarine systems. Subsequent
Chesapeake Bay agreements in 1987, 1992, and 2000 defined the agenda
for the Chesapeake Bay Program setting forth strategic plans with
measurable goals and objectives for the bay watershed.
[22] The targeted critical pollutants are dioxin, mercury,
polychlorinated biphenyls, hexachlorobenzene, octachlorostyrene, and
the pesticides chlordane, DDT, dieldrin/aldrin, and toxaphene.
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