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Responsibilities Better for Effective Oversight and Cleanup of 
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United States General Accounting Office: 
GAO: 

Report to Congressional Requesters: 

May 2002: 

Great Lakes: 

EPA Needs to Define Organizational Responsibilities Better for 
Effective Oversight and Cleanup of Contaminated Areas: 

GAO-02-563: 

Contents: 

Letter: 

Results in Brief: 

Background: 

Cleanup Progress Has Been Limited in Many Contaminated Areas: 

EPA Is Not Fulfilling the Nation’s Responsibility to Ensure the Cleanup 
of Contaminated Areas: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Environmental Protection Agency: 

Appendix III: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Status of Areas of Concern: 

Figures: 

Figure 1: CEM Funding Provided to EPA Regions for RAP and LaMP 
Activities Has Declined: 

List of Abbreviations: 

CEM: Costal Environmental Management: 

EPA: Environmental Protection Agency: 

GLNPO: Great Lakes National Program Office: 

IJC: International Joint Commission: 

LaMPs: Lakewide Management Plans: 

OIG: Office of Inspector General: 

RAPs: Remedial Action Plans: 

SOLEC: State of the Lakes Ecosystem Conferences: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

May 17, 2002: 

Congressional Requesters: 

Millions of people in the United States and Canada depend on the Great
Lakes as a source for drinking water, recreation, and economic 
livelihood. Over time industrial, agricultural, and residential 
development on lands adjacent to the lakes have seriously degraded the 
lakes’ water quality, posing threats to human health and the 
environment, and forcing restrictions on activities, such as swimming 
and fish consumption. 

In an effort to better protect the Great Lakes, and to address common
water quality problems, the governments of the United States and Canada
entered into the bilateral Great Lakes Water Quality Agreement in 1972. 
In 1978 the parties reached a new agreement, which, as amended in 1983 
and 1987, expanded the scope of the activities by prescribing 
prevention and cleanup measures intended to improve the lakes’ 
conditions. Specifically, the 1987 amendment committed the two 
countries to cooperate with state and provincial governments to ensure, 
among other things, the development and implementation of remedial 
action plans (RAPs) for designated areas of concern (areas) located in 
the Great Lakes Basin—areas contaminated for example with toxic 
substances known to cause deformities in fish or animals. The countries 
have agreed to use RAPs for managing the cleanup process and restoring 
contaminated areas to their beneficial use, such as swimming or 
fishing. The countries have identified 43 contaminated areas: 26 
located entirely within the United States, 12 in Canada, and 5 shared 
by both. The agreement obligates the International Joint Commission 
(IJC)—an international body charged with assisting the implementation 
of the agreement—to review the RAPs and provide comments on them. 

The Clean Water Act charges the U.S. Environmental Protection Agency 
(EPA) with leading the effort to meet the goals of the Great Lakes Water
Quality Agreement, which include RAP development and implementation.
The purpose of the section of the act addressing the Great Lakes is to
achieve the goals of the agreement through improved organization and
definition of the agency’s mission, funding of state grants for 
pollution control in the Great Lakes area, and improved accountability 
for implementation of the agreement. The act also establishes the Great 
Lakes National Program Office (GLNPO) within EPA, charging it with, 
among other things, cooperating with federal, state, tribal, and 
international agencies to develop and implement specific action plans 
to carry out the United States’ responsibilities under the various 
agreements. GLNPO is also charged with coordinating the actions of the 
agency, both in headquarters and in the regions, aimed at improving 
Great Lakes’ water quality. Specifically, under the act the 
administrator is to ensure that GLNPO enters into agreements with the 
various organizational elements within EPA specifically delineating 
duties and responsibilities of each element within the agency and the 
time and resources needed to carry out and complete them. 

According to EPA, the RAP process provides a forum for individuals,
organizations, and local governments to become actively involved in the
restoration of the Great Lakes ecosystems. As such, EPA provides states
certain flexibility in developing RAPs. In some areas, states have 
borne the responsibility for developing RAPs. In other areas, local 
citizens formed citizen advisory councils to assume this 
responsibility. The RAP process consists of three successive stages: 
(1) defining an area’s environmental problem, (2) selecting remedial 
and regulatory measures to address the problem, and (3) implementing 
the measures and restoring an area to its beneficial use, such as 
swimming. As part of the RAP process, the states submit their 
respective RAPs to the IJC for review and comment. When an area 
successfully completes all three stages of the RAP process, the area’s
name is removed from the list of contaminated areas, signifying that the
area is restored. 

Concerned with continued environmental problems in the lakes, you
asked us to (1) determine what progress has been made in developing and
implementing RAPs and (2) assess the effectiveness of EPA’s efforts to
ensure that RAPs are developed and implemented. The methodology that
we used to address these issues is presented in appendix I. 

Results in Brief: 

As of April 2002, none of the 26 contaminated areas in the Great Lakes
Basin for which the United States is responsible had completed all three
stages of the RAP process and been restored to beneficial use. 
Currently, all of the areas have defined their respective environmental 
problems (stage 1), but only approximately half of the areas selected 
remedial and regulatory measures to address these problems (stage 2). 
The slow progress of cleanup efforts reflects a general departure from 
the RAP process specified in the agreement. In a few areas, the state 
or local groups continue to follow the RAP process, although the 
ultimate remediation of the contaminated areas remains uncertain. In 
some areas, citizen advisory councils developed alternative cleanup 
plans that completely abandoned the RAP process. According to state and 
local officials, the councils abandoned the process because they lacked 
the technical expertise or financial resources to implement the RAPs. 
In other areas, the states or citizen groups assumed responsibility for 
the RAPs, modifying the process to conform to each area’s particular 
circumstances. Several areas forged ahead to address some of their 
environmental problems, with successes realized through other federal 
program activity, such as Superfund, or funding from state or nonprofit 
sources. 

EPA is not effectively fulfilling the nation’s responsibility under the 
Great Lakes Water Quality Agreement of 1978 to ensure that RAPs are 
developed and implemented in the contaminated areas. Even though EPA 
has been charged with leading the effort to meet the goals of the 
agreement, it has not clearly delineated responsibility for oversight 
of RAPs within the agency, and, citing resource constraints and the 
need to tend to other Great Lakes priorities, reduced its staff and the 
amount of funding it allocates to states for the purpose of RAP 
development and implementation. For example, in 1992, EPA transferred 
the oversight responsibility for RAPs from GLNPO to the agency’s 
regional offices, which it believed to be more familiar with funding 
and managing such programs. The regional offices provided initial 
support and oversight for the RAP process, but then significantly 
reduced the number of assigned staff and the amount of federally 
allocated funds devoted to RAP development and implementation. Now, no 
EPA office claims responsibility for overseeing this effort. Moreover, 
reductions in staff and funding limited the number of areas that EPA 
can effectively monitor. According to EPA officials, the agency reduced 
its support for RAPs under the assumption that states would continue to 
fund the RAP efforts. Instead, the states followed EPA’s lead and 
reduced their support as well. Subsequently, EPA shifted its attention 
to other priorities in the Great Lakes Basin that are required under 
the agreement. We are recommending that the EPA administrator clarify 
which office within EPA is directly responsible for ensuring the 
implementation of RAPs and identify the actions, time periods, and 
resources needed to help EPA fulfill its RAP oversight 
responsibilities. 

Background: 

Recognizing their mutual interests in the Great Lakes and other boundary
waters, the United States and Canada signed the Boundary Waters Treaty
in 1909, giving both countries equal rights to use the waterways that 
cross the international border. Accordingly, the treaty established the
International Joint Commission (IJC), comprised of three commissioners
from each country, to help the two governments resolve and prevent
disputes concerning boundary waters. With increased concern over the 
contamination of the Great Lakes, the two countries signed the first 
international Great Lakes Water Quality Agreement in 1972 to improve the
environmental conditions in the lakes. The agreement focused on 
controlling phosphorous as a principal means of dealing with 
eutrophication in the lakes. The parties signed a new agreement in 1978
that called for increased control of toxic substances and restoring 
water quality throughout the Great Lakes Basin. Subsequent amendments 
were made to the agreement in 1983 and 1987. The 1987 amendments added
several annexes that focused on specific environmental concerns, such as
contaminated sediment. 

The 1978 agreement as amended contains 17 annexes that define in detail
the specific programs and activities that the two governments agreed 
upon and committed to implement. Although most of the annexes specify
pollution prevention strategies, Annex 2 calls for the preparation of 
RAPs to address the restoration and protection of beneficial uses in 
specific contaminated areas designated as areas of concern and the 
other open waters of the Great Lakes. Such areas may include areas 
along the Great Lakes’ shoreline and areas that drain into the lakes 
that states and provinces identified as contaminated areas requiring 
cleanup. The agreement binds the United States and Canada to cooperate 
with state and provincial governments to designate such areas of 
concern, with the IJC reviewing progress by each government in 
addressing actions to restore water quality in the lakes. The agreement 
as amended also directs that the public be consulted in the RAP process 
and that each RAP: 

* define the environmental problems and the causes of these problems in
the areas, 

* provide an evaluation of remedial measures, 

* select remedial measures, 

* provide an implementation schedule, 

* identify organizations or individuals responsible for implementation, 

* include a process for evaluating remedial implementation and
effectiveness, and; 

* provide a description of monitoring to track effectiveness and
confirmation that the areas are restored. 

In defining the environmental problems, RAPs determine the applicability
of 14 adverse environmental conditions to the area. Such impairments
include beach closings, tainting of fish and wildlife flavor, and bird 
or animal deformities or reproduction problems. 

In addition, the Water Quality Act of 1987 amended the Clean Water Act 
to provide that EPA should take the lead in coordinating with other 
federal agencies and state and local authorities to meet the goals in 
the agreement. The act also established GLNPO within EPA to fulfill the
United States’ responsibilities under the agreement and to coordinate
EPA’s actions both at headquarters and in the affected regional offices.
The Great Lakes Critical Programs Act of 1990 amended the Clean Water
Act further defining GLNPO’s role and requiring the submission of all
RAPs to the office and also requiring each plan be submitted to the IJC 
for review and comment. The 1990 Act designated states as the primary
parties for developing and implementing plans, although ensuring
successful completion of the plans remains the responsibility of the 
United States and EPA under the agreement and the Clean Water Act. When
Coastal Environmental Management (CEM) funding first became available
in 1992, and because the Water Divisions administered other water
program funding, EPA officials made the decision to transfer oversight 
of the RAP process from GLNPO to the Water Division in EPA Regions II, 
III, and V, which border the Great Lakes. 

For the past several years, we and others have reported on slow progress
of the Great Lakes cleanup activities, making particular reference to 
the fact that neither GLNPO nor any other EPA office had devoted the
necessary responsibility, authority, and resources to effectively 
coordinate and oversee cleanup efforts in the Great Lakes Basin. In 
1990, we reported that the development of the RAPs and Lakewide 
Management Plans (LaMPs)[Footnote 1] called for in the agreement had 
fallen far behind schedule and recommended that EPA better coordinate 
GLNPO and EPA’s headquarters offices to improve the process.[Footnote 
2] Likewise, EPA’s Office of Inspector General (OIG) reported in 1999, 
that EPA officials were not as effective as they could be in working 
with states and local officials on RAPs and recommended that one 
official coordinate these activities.[Footnote 3] The IJC, in its most 
recent biennial report, identified the RAP process as an area needing 
improvement and reported that the process for preparing RAPs and LaMPs
was no longer being followed, in some cases resulting in an ad hoc 
modification of the annex. The IJC also reported that information on RAP
implementation is not readily available in a standardized, consolidated
format.[Footnote 4] Overall, the IJC concluded that although some 
progress had been made in the Great Lakes, the governments had not 
committed adequate funding or taken decisive actions to restore and 
protect the lakes. Citing the public’s right to know (and in an effort 
to get the program back on track), the IJC recommended a results-
oriented approach, suggesting that the governments of the United States 
and Canada prepare one consolidated progress report that lists 
accomplishments, expenditures, what remains to be done, and the amount 
of funding and time needed to restore the contaminated areas to 
beneficial use. 

Cleanup Progress Has Been Limited in Many Contaminated Areas: 

Progress in cleaning up the Great Lakes and restoring the contaminated
areas to their beneficial uses has fallen behind where the parties 
hoped it would be. As of April 2002, most of the RAPs for which the 
United States was responsible were in the second stage of having 
remedial and regulatory measures selected; none has completed all three 
stages indicating completion of cleanup. (See table 1.) 

Table 1: Status of Areas of Concern: 

Area of Concern: Ashtabula River; 
State: Ohio; 
Date Reported to IJC, Stage 1: 1991; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Black River; 
State: Ohio; 
Date Reported to IJC, Stage 1: 1994; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Buffalo River; 
State: New York; 
Date Reported to IJC, Stage 1: 1989; 
Date Reported to IJC, Stage 2: 1989; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Clinton River; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1988; 
Date Reported to IJC, Stage 2: 1995; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Cuyahoga River; 
State: Ohio; 
Date Reported to IJC, Stage 1: 1992; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Deer Lake; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1987; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Eighteenmile Creek; 
State: New York; 
Date Reported to IJC, Stage 1: 1997; 
Date Reported to IJC, Stage 2: 1997; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Fox River; 
State: Wisconsin; 
Date Reported to IJC, Stage 1: 1998; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Grand Calumet River; 
State: Indiana; 
Date Reported to IJC, Stage 1: 1991; 
Date Reported to IJC, Stage 2: 1997; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Kalamazoo River; 
State: Michigan; 
Date Reported to IJC, Stage 1: [Empty]; 
Date Reported to IJC, Stage 2: 1998; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Lower Menominee River; 
State: Michigan/Wisconsin; 
Date Reported to IJC, Stage 1: 1991; 
Date Reported to IJC, Stage 2: 1996; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Manistique River; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1987; 
Date Reported to IJC, Stage 2: 1997; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Maumee River; 
State: Indiana/Ohio; 
Date Reported to IJC, Stage 1: 1992; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Milwaukee Estuary; 
State: Wisconsin; 
Date Reported to IJC, Stage 1: 1994; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Muskegon Lake; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1987; 
Date Reported to IJC, Stage 2: 1994; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Oswego; 
State: New York; 
Date Reported to IJC, Stage 1: 1990; 
Date Reported to IJC, Stage 2: 1991; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Presque Isle Bay; 
State: Pennsylvania; 
Date Reported to IJC, Stage 1: 1993; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: River Raisin; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1987; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Rochester Embayment; 
State: New York; 
Date Reported to IJC, Stage 1: 1993; 
Date Reported to IJC, Stage 2: 1997; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Rouge River; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1989; 
Date Reported to IJC, Stage 2: 1994; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Saginaw River/Bay; 
State: Wisconsin; 
Date Reported to IJC, Stage 1: 1988; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Sheboygan River; 
State: Wisconsin; 
Date Reported to IJC, Stage 1: 1989; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: St. Louis Bay/River; 
State: Minnesota/Wisconsin; 
Date Reported to IJC, Stage 1: 1992; 
Date Reported to IJC, Stage 2: 1995; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Torch Lake; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1987; 
Date Reported to IJC, Stage 2: [Empty]; 
Date Reported to IJC, Stage 3: [Empty]. 

Area of Concern: Waukegan Harbor; 
State: Illinois; 
Date Reported to IJC, Stage 1: 1993; 
Date Reported to IJC, Stage 2: 1995; 
Date Reported to IJC, Stage 3: 1999. 

Area of Concern: White Lake; 
State: Michigan; 
Date Reported to IJC, Stage 1: 1987; 
Date Reported to IJC, Stage 2: 1995; 
Date Reported to IJC, Stage 3: [Empty]. 

Source: EPA Great Lakes Ecosystem Report 2000. 

[End of table] 

No area of concern in the United States has had its designation removed—
that is, been delisted—although the Great Lakes Strategy 2002 plan, 
which was developed by representatives of federal, state, and tribal 
governments in the Great Lakes area, lists as one of its objectives the 
removal of 3 areas from the list by 2005, and 10 by 2010. 

The RAP process envisioned in the agreement is not being consistently 
used as a model for cleanup activities occurring at the areas. While 
cleanup activities have occurred in many areas, such activities have
generally resulted from other environmental programs or initiatives. The
RAP process has essentially been abandoned for some areas, modified for
others, and for a limited number of areas the process is being followed 
to address the environmental impairments. According to state officials, 
a major reason that the RAP process is not being followed is the lack of
general funding, including funding from EPA. Whether or not the process
is being followed at an area often depends in part on state involvement 
in the process and whether there is local interest. As a result, 
implementation of the agreement is uneven across the areas and, in 
areas where the process has been abandoned, the initial investment in 
the process may have been largely wasted. 

Each of the eight Great Lakes states—Illinois, Indiana, Ohio, Michigan,
Minnesota, New York, Pennsylvania, and Wisconsin—has approached the
RAP process in a somewhat different manner after EPA reduced its
funding, but in general the volume of resources they devoted to the
process has diminished in the past 10 years, according to state 
officials. 

* The state of Michigan, which contains 14 areas, completed the first 
stage of the RAP process—defining the environmental problems—in 1987 and
1988. In the preparation stage, the state funded a group of state
coordinators, who spent part or all of their time on RAPs. Today, the
coordinators spend only a small fraction of their time on RAPs and serve
mainly as an area’s informational point of contact. In addition, the 
state decided that it would no longer follow the three-stage process 
set forth in the agreement. Responsibility for the Michigan RAP process 
rests primarily with local groups known as public advisory councils, 
and while none of these groups have abandoned their work, state 
officials indicated that two groups are on the verge of quitting and 
that others had significantly decreased their activities. The officials 
further stated that, while RAPs may be a catalyst, they are not driving 
the implementation of the areas’ cleanup activities. Instead, officials 
noted, other federal programs, such as Superfund, and state and 
nonprofit programs provide funding for cleanup and restoration 
activities. An organization representing the public advisory councils 
recently recommended that the state play a more aggressive role in 
supporting their efforts by providing funding and technical support. 

* The state of New York, which has six contaminated areas, employs a 
part-time coordinator for each area. According to state officials, over 
the years the overall activity in the RAP process has decreased, but 
the state retains oversight and commitment to the process. However, the 
RAP process is not the impetus for cleanup activities at the areas. 
Instead, other programs, such as EPA’s Resource Conservation and 
Recovery Act, have been used to clean up contaminated areas. 

* In Wisconsin, which has five contaminated areas, the work on the RAP
process for the areas was stopped after EPA decreased funding for RAP 
activities. As with other states, cleanup work continues at the areas
through other programs, although the state only completes projects
consistent with a RAP when it has the time and funds to do so, according
to a state official. The state does not monitor RAP progress, and
community groups are no longer actively involved in the process. 

* In Ohio, which has four contaminated areas, the RAP process evolved
differently in each area. For example, a structured process exists to
address the environmental impairments in one area, but the process is 
less structured in two other areas and significantly modified in 
another, according to a state official. Community organizations are 
involved in three of the four areas. The state has also modified the 
three-stage process specified in the agreement, saying that the RAPs 
could never be used to cleanup an area because they are not 
implementation documents, according to the official. 

* In Minnesota, Illinois, Pennsylvania, and Indiana, which have one
contaminated area each, any work underway in the areas is largely the
result of other programmatic activity, such as the removal of 
contaminated sediment in Waukegan Harbor, Illinois, as part of the 
Superfund program. There is local involvement in the RAP process in the 
areas in Illinois, Pennsylvania, and Indiana. In Minnesota, a nonprofit 
group sponsors environmental projects in the region where the area is 
located, but it is not directly involved in the RAP process. 

EPA and others often present environmental cleanup activities that 
relate to the goals of the RAP process as evidence that progress is 
being made at the areas, but these activities often relate to the goals 
of other programs, such as Superfund. Such reporting makes it difficult 
to determine what progress is being made in eliminating the impairments 
identified in the individual RAPs. In this connection, the members of 
the IJC responsible for reviewing the progress of the areas have 
reported their frustration in assessing RAP progress because EPA has 
not provided meaningful information to them. 

EPA Is Not Fulfilling the Nation’s Responsibility to Ensure the Cleanup 
of Contaminated Areas: 

EPA is not effectively fulfilling the nation’s responsibilities to 
ensure that RAPs are developed and implemented in the contaminated 
areas. Several EPA actions, such as diffusing RAP responsibility within 
the agency, reducing federal funding and staff support for the RAP 
process, and shifting the agency’s attention to other cleanup 
priorities in the Great Lakes Basin have all contributed to the uneven 
progress in RAP development and implementation. For example, in 1992, 
EPA transferred the responsibility for overseeing the RAP process from 
GLNPO to its Water Divisions in Regions II, III, and V. GLNPO retained 
responsibility for certain RAP-related activities, such as preparing 
progress reports and funding research that affected the contaminated 
areas. The Water Divisions provided initial support and oversight for 
the RAP process, but following several sequential cutbacks in process-
related state funding and staff, their capacity to oversee the RAP 
process was diminished to the point where EPA could no longer ensure 
the ultimate restoration of the contaminated areas. As support for the 
RAP process waned, EPA shifted its attention to other environmental 
problems in the Great Lakes, such as completing plans to address 
lakewide environmental problems. Although important, these activities 
did not supplant the need for RAPs to address the contaminated areas. 

Oversight Responsibility Within EPA for Contaminated Areas Is Unclear: 

Responsibility for oversight of the RAP process within EPA has changed
over time and today no office claims that responsibility. Amendments to
the Clean Water Act in 1987 named EPA as the lead agency and charged
GLNPO with coordinating EPA’s actions aimed at improving the water
quality of the Great Lakes. The act was amended in 1990 to, among other
things, require GLNPO to ensure the submission of RAPs for each area of
concern. The EPA administrator is responsible under the act for ensuring
that GLNPO specifically delineate the duties and responsibilities, the 
time commitments, and resource requirements with respect to Great Lakes
activities when entering into agreements with other organizational
elements within EPA. Shortly after the 1990 amendments were enacted,
EPA officials transferred oversight of the RAP process from GLNPO to its
Water Divisions in Regions II, III, and V, which border the Great Lakes.
While this decision was not formally documented, an EPA official 
familiar with the decision stated that EPA headquarters considered 
GLNPO’s primary focus to be on research and basin-wide activities. 
Furthermore, the official did not think that, as an office, GLNPO had 
the organizational mindset or capacity to oversee the RAP process. 
According to GLNPO officials, EPA believed the Water Divisions were 
more familiar with funding and managing similar programs. GLNPO, 
however, continued to track the status of RAPs and provide technical 
assistance and grant funds for projects associated with RAPs. 

In 1995, EPA’s Region V Office reorganized and created teams responsible
for the Great Lakes including their contaminated areas. These teams are
focusing on developing and updating the LaMPs for each lake. The 
directors for GLNPO and the Region V Water Division share responsibility
for the teams. In addition to the CEM funds provided for RAPs by the
Water Divisions, GLNPO’s base budget has averaged about $14.5 million
annually since 1993. During that same period GLNPO awarded about $3.2 
million annually to states, tribes, local organizations, and academic
institutions to fund Great Lakes activities related to the areas such as
sediment research and pollution prevention. 

In a September 1999 report on EPA’s Great Lakes Program, the EPA OIG 
recommended that the EPA’s Region V administrator clarify the role of
GLNPO as it relates to RAPs and LaMPs. The administrator agreed with 
this recommendation and stated that GLNPO’s roles and responsibilities
would be addressed during the development and implementation of a Great 
Lakes strategy. At that time, regional officials expected this strategy
to be completed by April 2000. EPA released its Great Lakes strategy on
April 2, 2002; however, this strategy did not clarify GLNPO’s roles and
responsibilities for RAPs, nor did it include provisions for specific 
funding to carry out the strategy. GLNPO officials stated that they 
decided not to include this clarification in the strategy because it 
required more specifics than could be included in the document. Still, 
as of April 2002, the agency had not clarified GLNPO’s role in any 
other document. 

GLNPO officials have stated that state and local governments are 
primarily responsible for implementation of RAPs through their local 
pollution control programs, except when federal programs and 
authorities, such as Superfund, are in the lead for a particular 
effort. Further, other EPA officials have noted that the financial 
assistance provided states for developing RAPs was intended only to be 
seed money and that the states were expected to continue funding the 
process. State and other EPA officials, including GLNPO officials, 
maintain that the federal government is ultimately responsible for the 
RAPs and cleaning up the areas. According to the director of the Water 
Division in Region V, there needs to be clear delineation of oversight 
responsibility for RAPs, which are, in the end, a federal 
responsibility. 

EPA Cut Funding and Staffing for Program-Related Activities: 

Over the past 10 years EPA has taken several steps that have reduced its
ability to sustain the RAP process, such as reducing the amounts of RAP-
related funding allocated to the states and reducing the number of 
agency staff assigned to oversee RAP activities. To assist states in 
preparing RAPs for the contaminated areas, EPA provided funding to the 
states from the CEM program. States used the funding to hire staff to 
focus on the planning process and organize community involvement to 
develop the RAPs. The funding was allocated to the three EPA Regions 
and then provided to the states. EPA decreased its regional CEM funding 
from $9.2 million in fiscal year 1992 to $2.5 million in fiscal year 
2002. (See figure 1.) 

Figure 1: CEM Funding Provided to EPA Regions for RAP and LaMP 
Activities Has Declined: 

[Refer to PDF for image] 

This figure is a vertical bar chart depicting CEM funding provided to 
EPA regions for RAP and LaMP activities during the time period of 
fiscal years 1992 through 2002 with approximated funding as follows: 

Fiscal year: 1992; 
CEM funding: $9.2 million. 

Fiscal year: 1993; 
CEM funding: $8.5 million. 

Fiscal year: 1994; 
CEM funding: $6.1 million. 

Fiscal year: 1995; 
CEM funding: $7.0 million. 

Fiscal year: 1996; 
CEM funding: $7.0 million. 

Fiscal year: 1997; 
CEM funding: $5.5 million. 

Fiscal year: 1998; 
CEM funding: $5.5 million. 

Fiscal year: 1999; 
CEM funding: $4.5 million. 

Fiscal year: 2000; 
CEM funding: $2.5 million. 

Fiscal year: 2001; 
CEM funding: $2.5 million. 

Fiscal year: 2002; 
CEM funding: $2.4 million. 

Source: EPA operating budget plans. 

[End of figure] 

Approximately 75 percent of the CEM funding was provided to Region V in
fiscal years 1992 through 2002. The director of the Water Division for 
EPA Region V stated that when the CEM funding was first available for 
work on both RAPs and LaMPs, 7 or 8 staff positions were provided for 
each of the 6 states in the region. The decrease in funding resulted in 
reducing the staff committed to RAPs in the three states that we 
visited—Ohio, Michigan, and Wisconsin. For example, in Wisconsin, as 
the funding for RAPs and other Great Lakes activities was reduced, the 
state reduced its staff working on RAPs and LaMPs from 9 full-time to 
one full-time and one part-time position. As a result, the state could 
no longer provide support for the local RAP committees or updates for 
the RAPs and stopped doing remedial action work at the contaminated 
areas, unless it related to some other program, such as Superfund. 

EPA also reduced its staffing levels for the RAPs. The agency had funded
RAP liaison positions to facilitate and coordinate work on RAPs. In 
EPA’s Region V, which encompasses most of the areas of concern, there 
were 21 RAP liaisons with at least one assigned to each area in 1999. 
As of 2001 this staffing had been reduced to two part-time and one full-
time liaison. An EPA official responsible for the liaisons stated that 
work on RAPs was no longer a priority and priorities had shifted to 
LaMPs. In fiscal year 2002, one person was assigned to work full-time 
on the RAP for the Detroit River area, but neither Region V nor EPA 
headquarters had any staff responsible for monitoring RAP progress. 
GLNPO has provided grant funding to the Great Lakes Commission, a 
binational agency promoting information sharing among Great Lakes 
states, to update information on the contaminated areas and the RAPs on 
GLNPO’s web site. The information provides an overview of the status of 
RAPs with updated information provided by state or local officials. The 
information, however, does not present an analysis of the progress in 
cleaning up areas or time frames for expected completion. 

EPA Has Shifted Its Focus to Other Great Lakes Activities: 

EPA has reduced support for the RAP process and redirected its efforts 
to several other Great Lakes initiatives, many of which are required in 
the agreement and either directly or indirectly affect the areas. 
Specifically, the Water Divisions have focused resources on the 
development of LaMPs. LaMPs address overall concerns in the open lake 
waters, such as reduction in loadings of critical pollutants, but they 
do not replace the RAPs, which are intended to clean up the shoreline 
where most of the contamination occurs. GLNPO has been involved in 
several other initiatives, including coordinating the development of a 
Great Lakes strategy. The strategy was developed by the U.S. Policy 
Committee, which is comprised of representatives from federal, state, 
and tribal organizations responsible for the actions specified in the 
agreement. The strategy sets forth certain goals, objectives, and 
actions the parties agree to address, including the following. 

* The reduction of toxic substances in the Great Lakes Basin ecosystem.
[The reduction of mercury and dioxin emissions from medical waste
incinerators was one objective under this goal. A key action for this 
goal is that Minnesota will achieve a 70 percent reduction of its 1990 
mercury emissions by 2005.] 

* The development of environmental indicators for the Great Lakes 
through a series of State of the Lakes Ecosystem Conferences (SOLEC) at 
which indicators are discussed and agreed upon. These biennial 
conferences, jointly sponsored by GLNPO and Environment Canada, bring 
together representatives from federal, state, and provincial 
organizations, and the general public. The latest conference, held in 
October 2001, approved 33 of 80 indicators being proposed to assess 
conditions in the Great Lakes. 

* Maintaining a ship for research and monitoring on the Great Lakes and
providing another vessel for sampling contaminated sediment. 

The strategy also addresses cleaning up areas through RAPs and sets 
forth objectives to cleanup and delist three areas by 2005, and 10 by 
2010 and an acceleration of sediment remediation efforts leading to the 
cleanup of all sites by 2025. In addition, the strategy calls for 
delisting guidelines for the areas, which were completed in December 
2001. The guidelines include tasks such as requiring monitoring data 
for achieving restoration goals and addressing impairments caused by 
local sources within the areas. While the strategy sets forth numerous 
environmental objectives state environmental officials have questioned 
how the objectives will be achieved without additional funding. 

Conclusions: 

The process now being used to develop and implement RAPs for many of
the contaminated areas in the Great Lakes Basin has deviated from the
process outlined in the agreement between the United States and Canada.
Momentum for RAP activity waned since EPA diffused the responsibility
for ensuring RAP progress among its various offices, began reducing its
staff and process-related funding to the states, and shifted its 
priorities to completing other activities in the Great Lakes Basin. As 
a result, states and local communities have had to seek funding from 
other federal programs or other sources in order to continue their 
cleanup activities. Although EPA’s initial investment in the process 
yielded some results in terms of planning documents and public 
involvement, EPA is not in a position to provide assurance that such 
involvement will continue in the future or that the RAPs will be 
implemented. Without a clear delineation of oversight responsibilities 
within EPA for RAP implementation, all preliminary efforts and 
expenditures may have been largely wasted. Absent EPA’s support, 
involvement, and consistent oversight, states and local communities 
will have difficulty keeping the process moving forward. 

Recommendations for Executive Action: 

To help EPA more effectively oversee the RAP process and meet the
United States’ commitment under the Great Lakes Water Quality
Agreement, we are recommending that the EPA administrator: 

* clarify which office within EPA is responsible for ensuring RAP
implementation, and; 

* identify the actions, time periods, and resources needed to help EPA 
fulfill its RAP oversight responsibilities. 

Agency Comments: 

We provided EPA with a draft of this report for its review and comment. 
The agency generally agreed with the findings and recommendations in 
the report. EPA maintained that significant progress was being made at
the areas of concern with most RAPs having completed Stage 2 and one 
having completed Stage 3. However, we and the IJC believe that this does
not represent significant progress, and no area of concern within the
United States has been delisted. EPA also stated that the RAP process
does not fairly represent environmental improvements that are being made
at the areas of concern. We recognize that some cleanup activities are
being taken within the areas of concern that relate to other program
requirements, but maintain that the RAP process is still the primary
cleanup vehicle. The agency also stated that it has been actively 
involved in ensuring that RAPs are developed and it is reviewing the 
RAP process to create a more effective program. While this may have 
been true initially, EPA significantly reduced this support and 
currently provides only limited support for the process. We commend EPA 
for developing delisting principles and guidelines, but this effort 
does not directly address the need to improve the overall effectiveness 
of the RAP process. EPA agreed with our recommendations to clarify 
which office within EPA is responsible for ensuring RAP implementation, 
and it will seek to clarify these responsibilities within EPA. As to 
our recommendation to identify actions, time periods, and resources 
needed for fulfilling its RAP oversight responsibilities, EPA commented 
that this would be a difficult task because of the wide spectrum and 
scale of environmental problems within the areas of concern and other 
priorities and responsibilities within EPA. We recognize that this task 
may be difficult, but it is critical if EPA is to fulfill its oversight 
responsibility. The full text of EPA’s comments is included as appendix 
II. 

We conducted our review from September 2001 through April 2002 in
accordance with generally accepted government auditing standards. (See
appendix I for a detailed description of our scope and methodology.) 

As arranged with your offices, we plan no further distribution of this
report until 30 days after the date of this letter unless you publicly
announce its contents earlier. At that time, we will send copies to 
other appropriate congressional committees, the EPA administrator, and 
the International Joint Commission. We will also make copies available 
to others upon request. 

Should you or your staff need further information, please contact me on
(202) 512-3841. Key contributors to this report are listed in appendix 
III. 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

List of Congressional Requesters: 

Honorable Evan Bayh: 
United States Senate: 

The Honorable Mike DeWine: 
United States Senate: 

Honorable Carl Levin: 
United States Senate: 

Honorable Debbie Stabenow: 
United States Senate: 

Honorable James Oberstar: 
House of Representatives: 

Honorable Vernon Ehlers: 
House of Representatives: 

Honorable Steven LaTourette: 
House of Representatives: 

Honorable John Dingell: 
House of Representatives: 

Honorable Louise Slaughter: 
House of Representatives: 

Honorable Sherwood Boehlert: 
House of Representatives: 

Honorable Sherrod Brown: 
House of Representatives: 

Honorable Bart Stupak: 
House of Representatives: 

Honorable Marcy Kaptur: 
House of Representatives: 

Honorable Robert Borski: 
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

To assess what progress had been made in developing and implementing
cleanup plans for the contaminated areas around the Great Lakes, we
reviewed the Great Lakes Water Quality Agreement of 1987, which set
forth the United States’ obligation to cooperate with state governments 
to ensure the cleanup of the contaminated areas and described the 
process for developing and implementing the cleanup plans. We also used 
Internet web site information that described the cleanup status at the 
contaminated areas of concern. In addition, we visited areas of concern 
(areas) in the Milwaukee Wisconsin Estuary and Ashtabula, Ohio, where 
we discussed cleanup efforts, implementation plans, and assistance 
provided by federal, state and local agencies. Further, we gathered and 
analyzed information obtained through interviews with officials from 
the International Joint Commission (IJC), the Great Lakes Commission, 
the Northeast Midwest Institute, EPA Headquarters and Region V Office 
of Water, and the Great Lakes National Program Office (GLNPO), the U.S. 
Army Corps of Engineers, the Wisconsin Department of Natural Resources, 
the Ohio Environmental Protection Agency, and local community advisory 
groups responsible for cleanup activities at the selected areas. 

To determine how the cleanup plans were being used at other areas, we
visited the Michigan Department of Environmental Quality, which manages 
the greatest number of contaminated areas (14), and solicited telephone 
and written comments from each of the other five Great Lakes states 
concerning their cleanup activities and the remedial action plan 
process. To further assess EPA efforts to provide oversight for the
contaminated area cleanup process, we reviewed EPA’s legislative 
responsibilities for providing oversight under the Clean Water Act and
discussed with EPA, state, and other federal agencies EPA’s success in
fulfilling these responsibilities. 

[End of section] 

Appendix II: Comments from the Environmental Protection Agency: 

United States Environmental Protection Agency: 
Great Lakes National Program Office: 
77 West Jackson Boulevard: 
Chicago, IL 60604-3590: 

May 15, 2002: 

John B. Stephenson: 
Director, Natural Resources and the Environment: 
U.S. General Accounting Office: 
Washington, DC 20548: 

Dear Mr. Stephenson: 

Thank you for the opportunity to review the proposed General Accounting 
Office (GAO) Report; Great Lakes: EPA Needs to Define Organizational 
Responsibilities Better for Effective Oversight and Cleanup of 
Contaminated Areas. We appreciate your staffs efforts to understand the 
complexities of the Remedial Action Plan (RAP) Program for the Great 
Lakes Areas of Concern (AOCs) and we are giving careful consideration 
to your recommendations. Our initial comments are outlined below, with 
the understanding that EPA will be given an additional opportunity to 
comment on the report after it is submitted to Congress. 

Your first charge was to determine what progress has been made in 
developing and implementing RAPs. I want to reaffirm the U.S. Great 
Lakes Program's strong and ongoing commitment to the Great Lakes Water 
Quality Agreement (the Agreement), and to the RAP process for the U.S. 
AOCs. Since the 1987 signing of the Protocol to the Agreement, the U.S. 
Great Lakes Program has focused a large amount of effort and resources 
to restore these areas. And while we can always improve on the process, 
I can confirm that much progress has been made toward restoring the 
beneficial uses in these areas. We are committed to doing as much as 
possible to meet all our responsibilities under the Agreement. As an 
example, the recently released Great Lakes Strategy, a product of the 
U.S. Policy Committee, focuses multi-agency resources and commitments 
on the AOCs to help achieve the Strategy's goals of delisting at least 
three AOCs by 2005 and a cumulative goal of ten by 2010. 

The implementation of the identified remedial actions in the RAPs can 
be complicated due to the multi-media nature of the problems 
encountered and the inter-agency and inter-jurisdictional coordination 
required to implement these actions. In addition, the very substantial 
costs involved in many of these activities have slowed the rate of 
progress in many AOCs. But this situation has not deterred the 
achievement of significant progress in the AOCs. From a process 
standpoint, most of the RAPs have completed Stage 2 documents, and one 
has completed a Stage 3. Recently, the Presque Isle Bay, Pennsylvania 
AOC Citizens Action Group has requested that the AOC be redesignated as 
the first U.S. AOC to be an Area of Recovery. 

While very important, these highlights of progress in the RAP process 
do not fairly represent the actual on the ground improvements which are 
being continuously implemented in all 31 U.S. AOCs. Numerous 
contaminated sediment remediations, enforcement actions, infrastructure 
improvements, habitat restoration projects, pollution prevention 
programs, and educational opportunities are more accurate measures of 
progress in achieving the restoration of the beneficial uses in the 
AOCs and, eventually, to their formal delisting. 

EPA is committed to tracking and reporting on progress achieved in the 
AOCs: We have created and are actively maintaining a website for the 
U.S. AOCs at [hyperlink, http://www.epa.gov/glnpo/aoc/]. 

In addition, we recently released a summary document entitled AR 
Overview of U.S. Great Lakes Areas of Concern which is available from 
EPA's Great Lakes National Program Office (GLNPO). This document will 
be updated and released on a regular basis. 

Your second charge was to assess the effectiveness of EPA's efforts to 
ensure that RAPs are developed and implemented. 

Section 118(3)(A) of the Clean Water Act calls for the Program Office 
(GLNPO) to ensure that each Great Lakes State in which an AOC is 
located submits a RAP for each AOC to the Program Office and to the 
International Joint Commission. Through Coastal Environmental 
Management (CEM) funding which provides resources for managing and 
coordinating the RAP program, through the U.S. Policy Committee (which 
includes federal and state agencies) that assists in overseeing the RAP 
program, and by commitments included in the U.S. Great Lakes Strategy 
(as mentioned above), EPA has been actively ensuring that RAPs are 
being developed for all 31 U.S. AOCs and that the remedial actions 
identified in the RAPs are being implemented under appropriate 
environmental statutes and programs, and as resources are made 
available. 

To build upon this record of progress, EPA is actively reviewing the 
RAP process to create a more effective program. We have been holding 
internal discussions and working with our State partners to help refine 
and redirect our efforts. One significant outcome of this effort has 
been the completion of the federal/state authored paper entitled 
Restoring U.S. Areas of Concern: Delisting Principles and Guidelines. 
This document gives RAP practitioners important tools for insuring 
progress and maintaining momentum in the AOCs. The U.S. RAP program 
will continue to identify opportunities to improve the program and to 
accelerate the rate of remedial activities and environmental 
restoration. 

It is important to remember that RAPs are only one of many requirements 
that the U.S. has under the Agreement. The RAPs were not intended to 
track and report on the many other provisions of the Agreement which 
have substantial and immediate benefits for the AOCs. 

Response to Recommendations: 

Your first recommendation is that the EPA Administrator clarify which 
office within EPA is responsible for ensuring RAP implementation. 

As described in the GAO report, EPA's management responsibilities for 
the RAP program has been modified over the life of the program. At the 
moment, these responsibilities are divided between the Water Divisions 
in EPA Regions 2, 3, and 5 and GLNPO. EPA will seek to clarify these 
responsibilities in discussions with representatives from these three 
Regions, GLNPO, and EPA headquarters. 

Your second recommendation is that the EPA Administrator identify the 
actions, time periods, and resources needed to help EPA fulfill its RAP 
oversight responsibilities. 

The identification of actions, time periods, and resources needed would 
help the Agency fulfill its RAP oversight responsibilities. Reliably 
assessing and fulfilling these needs, however, is very difficult, given 
the wide spectrum and scale of the environmental problems which need to 
be addressed to restore the AOCs, and the other important priorities 
and programs that fall within EPA's responsibilities. EPA will discuss 
this recommendation in detail and identify, where possible, the steps 
needed to implement this recommendation. 

It is important to understand that the RAP Program was never structured 
or envisioned to provide the funding required to initiate all the 
remedial actions identified during the RAP process. Rather, the limited 
RAP funding was initially provided to assess and recommend the remedial 
actions required to restore the AOCs and to manage and implement the 
program. It should also be recognized that the required actions are 
dependent upon the use of authorities across many agencies and many 
levels of government and the full use of these authorities across 
governmental agencies must be thoroughly considered. 

In closing, I want to reiterate EPA's strong commitment to the RAP 
Program for cleaning up and restoring Great Lakes AOCs. We have many 
significant accomplishments that have bettered environmental conditions 
in the AOCs, but we also recognize that the RAP process can be 
significantly improved and that the GAO's conclusions and 
recommendations can help ensure that even more environmental 
improvements are made. 

I appreciate the opportunity to coordinate with your staff on this 
project and look forward to the final report. Should you need 
additional information or have further questions, please contact Mr. 
Gary Gulezian, Director of EPA's Great Lakes National Program Office, 
at 312-886-4040. 

Very truly yours, 

Signed by: 

Thomas V. Skinner: 
Great Lakes National Program Manager: 

[End of section] 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

John Wanska (312) 220-7628: 

Staff Acknowledgments: 

Key contributors to this report were Willie E. Bailey, Jonathan S.
McMurray, Rosemary Torres-Lerma, Stephanie Luehr, and Karen Keegan. 

[End of section] 

Footnotes: 

[1] LaMPs are management plans for the open waters of each lake to 
reduce loadings of critical pollutants in order to restore beneficial 
uses. 

[2] See U.S. General Accounting Office, Water Pollution: Improved 
Coordination to Clean Up the Great Lakes, [hyperlink, 
http://www.gao.gov/products/GAO/RCED-90-197] (Washington: D.C.: Sept. 
28, 1990). 

[3] U.S. Environmental Protection Agency, EPA’s Great Lakes Program 
EPA/OIG Rept. 99P00212 (Washington, D.C.: Sept. 1, 1999). 

[4] International Joint Commission, Tenth Biennial Report on Great 
Lakes Water Quality, (June 29, 2000). 

[End of section] 

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