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entitled 'Great Lakes: Organizational Leadership and Restoration Goals 
Need to Be Better Defined for Monitoring Restoration Progress' which 
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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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