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entitled 'Great Lakes: EPA and States have Made Progress in
Implementing the BEACH Act, but Additional Actions Could Improve Public
Health Protection' which was released on May 24, 2007.
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
May 2007:
Great Lakes:
EPA and States Have Made Progress in Implementing the BEACH Act, but
Additional Actions Could Improve Public Health Protection:
GAO-07-591:
GAO Highlights:
Highlights of GAO-07-591, a report to Congressional Requesters
Why GAO Did This Study:
Waterborne pathogens can contaminate water and sand at beaches and
threaten human health. Under the Beaches Environmental Assessment and
Coastal Health (BEACH) Act, the Environmental Protection Agency (EPA)
developed limits on pathogens that states use to assess beach water
quality. EPA can also provide grants to states to develop water quality
monitoring and public notification programs.
GAO was asked to assess (1) the extent to which EPA implemented the
BEACH Act including how it allocated grants to the states, (2) the
monitoring and notification programs developed by Great Lakes states,
and (3) the effect of the BEACH Act on water quality monitoring and
contamination at Great Lakes beaches
What GAO Found:
EPA has taken steps to implement most of the provisions of the BEACH
Act but has missed statutory deadlines for two critical requirements.
While EPA has developed a national list of beaches and improved the
uniformity of state water quality standards, it has not (1) completed
the pathogen and human health studies required by 2003 or (2) published
the new or revised water quality criteria for pathogens required by
2005. Moreover, the formula EPA has used to distribute approximately
$51 million in BEACH Act grants from 2001-2006 does not accurately
reflect the monitoring needs of the states. This is because the formula
emphasizes the length of the beach season more than the other
factors—beach miles and beach use. These other factors vary widely
among the states, can greatly influence the amount of monitoring a
state needs to undertake, and can increase the public health risk.
All eight Great Lakes states have used BEACH Act grants to develop
beach monitoring and public notification programs. However, because
these programs vary among the states they may not provide consistent
levels of public health protection within and across Great Lakes
beaches. For example, GAO found that the states’ monitoring and
notification programs varied considerably in the frequency with which
beaches were monitored, the monitoring methods used, and how the public
was notified of potential health risks. For example, some states
monitor their high-priority beaches as little as one or two times per
week, while others monitor their high-priority beaches daily. In
addition, when local officials review similar water quality results,
some may choose to only issue a health advisory while others may choose
to close the beach. According to state and local officials, these
inconsistencies are in part due to the lack of adequate funding for
their beach monitoring and notification programs.
The frequency of water quality monitoring has increased at Great Lakes
beaches since the passage of the BEACH Act, helping states and
localities to identify the scope of contamination. However, in most
cases, the underlying causes of contamination remain unknown and
unaddressed. This is because some state and local officials reported
that they do not have the funds to investigate the source of the
contamination or take actions to mitigate the problem, and EPA has
concluded that BEACH Act grants generally may not be used for these
purposes. For example, local officials at 67 percent of Great Lakes
beaches reported that, when results of water quality testing indicated
contamination at levels exceeding the applicable standards during the
2006 beach season, they did not know the source of the contamination,
and only 14 percent reported that they had taken actions to address the
sources of contamination. State and local officials indicated that an
overall improvement in water quality throughout the Great Lakes will
require long-term collaborative efforts to address the underlying
causes of contamination, as well as increased funding.
What GAO Recommends:
GAO recommends that EPA distribute grant funds in a way that reflects
states’ monitoring needs and help states improve the consistency of
their monitoring and notification activities. In addition, Congress
should consider providing EPA more flexibility to allow states to use
BEACH Act grants to investigate and remediate contamination sources.
EPA generally agreed with GAO’s recommendations but stated that states
may resist making substantial changes to the funding formula because of
their tight budgets.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-591].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Anu K. Mittal at (202)
512-3841 or mittala@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
EPA Has Taken Steps to Implement the BEACH Act, but Its Grant
Distribution Formula Does Not Adequately Reflect States' Monitoring
Needs:
Great Lakes States' Beach Monitoring and Public Notification Programs
Vary Across Localities and May Not Provide Consistent Levels of Public
Health Protection:
The BEACH Act Has Helped Identify the Scope of Contamination, but
Underlying Causes Remain Unaddressed:
Conclusions:
Matter for Congressional Consideration:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Map of 35 States and Territories with Coastal Recreational
Waters:
Appendix III: GAO's Calculations for an Alternative BEACH Act Grant
Distribution Formula:
Appendix IV: Comments from the Environmental Protection Agency:
Appendix V: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: BEACH Act Grant Distribution Formula:
Table 2: BEACH Act Funding Formula Inputs for Great Lakes States:
Table 3: Number of Great Lakes Beaches Identified, Number and
Percentage of Beaches Being Monitored for the 2006 Beach Season:
Table 4: Great Lakes Prioritized Beaches Reported by States for
Monitoring Using BEACH Act Grant Funds as of October 2006:
Table 5: Monitoring Frequency of Great Lake Beaches by Priority:
Table 6: Variation in Great Lakes States' Pathogen Indicator (E. coli)
Thresholds and Responses to Water Quality Exceedances:
Table 7: Great Lakes Beaches Reported Monitored by EPA in 2005, GAO
Sample, and Sample Disposition by State:
Table 8: EPA Beach Season Length Factor and States Associated Funding
Levels:
Table 9: EPA's Formula for Distributing $30 Million in BEACH Act
Grants:
Table 10: EPA's Formula for Distributing $10 Million in BEACH Act
Grants:
Table 11: Factors Used in BEACH Act Formula Allocations and Resulting
2006 Grants by State and Territory:
Table 12: Difference in Allocations Using Current and Alternative
Formulas:
Figures:
Figure 1: Map of the Five Great Lakes and Eight Great Lakes States with
Population Density by County:
Figure 2: Potential Sources of Fecal Contamination at Beaches in the
Great Lakes:
Figure 3: Time Lag Associated with Current Water Quality Monitoring and
Public Notification Methods:
Figure 4: Reported Depth of Water Quality Sampling at Great Lakes
Beaches:
Figure 5: Variation in Public Notification Signs at Great Lakes
Beaches:
Figure 6: Number of Identified Beaches and Number of Identified Beaches
Monitored in the Great Lakes from 1999 to 2005:
Figure 7: Estimated Changes in Frequency of Monitoring at Great Lakes
Beaches Since Passage of the BEACH Act:
Figure 8: Number of Great Lakes Identified Beaches Monitored and
Monitored Beaches with at Least One Closure or Advisory from 1999 to
2005:
Figure 9: Estimated Change in Ability to Make Decisions Based on Water
Quality Data Since Passage of the BEACH Act:
Figure 10: Changes to Beach Grooming Process at a Racine, Wisconsin,
Beach:
Figure 11: Estimated Change in Public Awareness of Personal Actions on
Water Quality at Great Lakes Beaches Since Passage of the BEACH Act:
Abbreviations:
BEACH Act: Beaches Environmental Assessment and Coastal Health Act:
EPA: Environmental Protection Agency:
NOAA: National Oceanic and Atmospheric Administration:
USGS: United States Geological Survey:
United States Government Accountability Office:
Washington, DC 20548:
May 1, 2007:
Congressional Requesters:
There are hundreds of beaches along the 5,000 miles of Great Lakes'
shoreline that spans eight states: Illinois, Indiana, Michigan,
Minnesota, New York, Ohio, Pennsylvania, and Wisconsin. These beaches
provide recreational opportunities to more than 30 million residents
and visitors each year. However, waterborne pathogens--bacteria,
viruses, and parasites that live in the gastrointestinal tract of
humans and other warm-blooded animals--can contaminate the water and
sand at these beaches and threaten human health. The key contributors
to this contamination are partially treated discharges from wastewater
treatment plants; droppings from wildlife, such as gulls and geese; and
agricultural and municipal waste that is often transported to beach-
area waters by rain and storm water runoff. Contact with or accidental
ingestion of contaminated water can cause vomiting, diarrhea, and other
illnesses, and may be life-threatening for susceptible populations such
as children, the elderly, and those with impaired immune systems. State
and local health officials may issue health advisories or close beaches
when they believe levels of waterborne pathogens are high enough to
threaten human health. The Natural Resources Defense Council reported
that, in 2005, the Great Lakes beaches had at least 2,740 days of
health advisories or beach closures.
Under the Clean Water Act, the Environmental Protection Agency (EPA) is
responsible for publishing water quality criteria that establish
thresholds at which contamination--including waterborne pathogens--may
threaten human health. States are required to develop standards, or
legal limits, for these pathogens by either adopting EPA's recommended
water quality criteria or other criteria that EPA determines are
equally protective of human health. The states then use these pathogen
standards to assess water quality at their recreational beaches.
However, because many pathogens are difficult and costly to detect,
state and local officials have typically used more easily identified
organisms that indicate that pathogens may be present. During the 1960s
and 1970s, EPA evaluated several types of bacteria for use as pathogen
indicators and recommended using fecal coliforms--bacteria found in the
intestines of humans and warm-blooded animals--as a pathogen indicator
for states' recreational water quality standards. By 1986, new research
questioned the reliability of using fecal coliforms as a pathogen
indicator, prompting EPA to recommend new criteria using E.coli and
enterococci as pathogen indicators. However, as of 2000, only 11 states
had adopted EPA's recommended 1986 criteria for testing their
recreational waters.
Recognizing the need for consistent water quality criteria at
recreational beaches, Congress passed the Beaches Environmental
Assessment and Coastal Health (BEACH) Act of 2000 to improve states'
beach monitoring programs and processes for notifying the public of
potential health risks from contamination at beaches. The BEACH Act
amended the Clean Water Act to require the 35 eligible states and
territories--including the 8 Great Lakes states--to update their
recreational water quality standards using EPA's 1986 criteria for
pathogen indicators. In addition, the BEACH Act required EPA to (1)
complete studies on pathogens in coastal recreational waters and how
they affect human health, including developing rapid methods of
detecting pathogens by October 2003, and (2) publish new or revised
water quality criteria by October 2005, to be reviewed and revised as
necessary every 5 years thereafter.
The act also authorized EPA to award grants to states, localities, and
tribes to develop comprehensive beach monitoring and public
notification programs for their recreational beaches. To be eligible
for BEACH Act grants, states are required to (1) identify their
recreational beaches, (2) prioritize their recreational beaches for
monitoring based on their use by the public and the risk to human
health, and (3) establish a public notification program. EPA grant
criteria give states some flexibility on the frequency of monitoring,
methods of monitoring, and processes for notifying the public when
pathogen indicators exceed state standards, including whether to issue
health advisories or close beaches. The BEACH Act authorized EPA to
provide $30 million in grants annually for fiscal years 2001 through
2005.[Footnote 1] However, since fiscal year 2001, congressional
conference reports accompanying EPA's appropriations acts have directed
about $10 million annually for grants under the act. EPA has followed
this congressional direction when allocating funds to the program.
In the context of continuing health advisories and beach closures at
Great Lakes beaches since passage of the BEACH Act, you asked us to (1)
determine the extent to which EPA has implemented the act and evaluate
EPA's formula for allocating BEACH Act grants, (2) describe and
evaluate the monitoring and notification programs the eight Great Lakes
states have developed using BEACH Act grants, and (3) determine the
effect that the BEACH Act has had on water quality monitoring and
contamination at Great Lakes beaches.
To determine the status of EPA's implementation of the BEACH Act, we
analyzed the act, obtained and analyzed relevant agency documentation,
and interviewed officials from EPA headquarters and Region 5 (Chicago)
offices. To evaluate EPA's formula for allocating BEACH Act grants, we
obtained and analyzed EPA data on funding levels, interviewed officials
that developed the allocation formula, and conducted simulations to
demonstrate how alterations of the formula would shift funding and
potentially affect current allocations. To evaluate the programs the
eight Great Lakes states have developed using their BEACH Act grants,
we conducted a survey of a random sample of 140 of the 563 beaches EPA
identified as being monitored in the Great Lakes in 2005. Information
obtained through this survey was used to produce estimates[Footnote 2]
of beach monitoring and notification activities at monitored Great
Lakes beaches for the 2006 beach season. We distributed an electronic
questionnaire via e-mail to local officials at a random sample of 140
beaches, and 93 percent of those surveyed responded to our
questionnaire. Information obtained through this survey was used to
produce estimates of beach monitoring and notification activities for
the entire population of monitored Great Lakes beaches for the 2006
beach season. In addition, we interviewed BEACH Act administrators from
each of the Great Lakes states. To determine the effect the BEACH Act
has had on Great Lakes beach monitoring and contamination levels, we
analyzed the results of our questionnaire and the information provided
by the eight state BEACH Act administrators. We also met with and
gathered information from other agencies and nonprofit organizations
working on Great Lakes issues, such as the National Oceanic and
Atmospheric Administration (NOAA), the U.S. Geological Survey (USGS),
the Metropolitan Water Reclamation District of Greater Chicago, and the
Natural Resources Defense Council. We took steps to assess the
reliability of EPA data on monitored beaches. Appendix I includes more
information about our scope and methodology. We conducted our work from
June 2006 through March 2007 in accordance with generally accepted
government auditing standards.
Results in Brief:
EPA has implemented seven of the BEACH Act's nine requirements and
provisions. For example, EPA promulgated water quality standards for
the 21 states and territories that had not adopted EPA's 1986 water
quality criteria and developed a national list of beaches. However, EPA
has not (1) completed the pathogen and human health studies that were
required by 2003 or (2) published new or revised water quality criteria
for pathogens or pathogen indicators that were required by 2005. EPA
told us that the required studies are ongoing, but may take an
additional 4 to 5 years to complete, and that the development of new
pathogen indicators would follow completion of the studies. Although
EPA has distributed approximately $51 million in BEACH Act grants
between 2001 and 2006 to the 35 eligible states and territories, EPA's
formula for distributing BEACH Act grant funds does not reflect the
states' varied monitoring needs. EPA considered the BEACH Act's
emphasis on beach use and risk to human health in developing the
formula, which is based on three factors--length of beach season; beach
miles, as measured by length of shoreline; and beach use, as measured
by coastal population. If the program had received its full funding of
$30 million, each of the three factors would have had approximately the
same level of influence on the amount of BEACH Act grant funds
allocated to the states. However, because funding allocations have only
been about $10 million annually, the beach season factor has had a
greater influence (about 82 percent) on the total BEACH Act grants each
state received, while beach miles and beach use, which vary widely
among the states and can impact the public health risk, have had a
significantly smaller impact (about 9 percent each). As a result, while
the Great Lakes state's beach monitoring needs vary widely because of
their differing coastlines and coastal populations, the amount of each
state's BEACH Act grant is almost the same. For example, Indiana, which
has 45 miles of shoreline and a coastal population of 741,468, received
about $205,800 in 2006 while Michigan, which has 3,224 miles of
shoreline and a coastal population of 4,842,023, received about
$278,450 in 2006.
Each of the eight Great Lakes states has used its BEACH Act grant
funding to develop beach monitoring and public notification programs,
but these programs vary across states and localities and may not
consistently protect public health. Prior to the BEACH Act, only five
of the eight Great Lakes states had water quality monitoring programs,
and now all eight have a program in place. However, the Great Lake
states' monitoring and notification programs vary considerably in the
frequency with which they monitor their beaches, their monitoring
methods, and their means of notifying the public of health risks. For
example, some states monitor beaches they have designated as high
priority as little as one or two times per week, while others monitor
their high-priority beaches daily. These differences are due, in part,
to the current BEACH Act funding levels, which some Great Lakes state
officials reported are inadequate for sufficient monitoring. In
addition, when local officials review water quality results, they may
make different decisions on whether or not to issue a health advisory
or close a beach even though the results show the same level of
contamination. This happens because, according to Great Lakes states
BEACH Act administrators, two states only issue health advisories, two
states only close beaches, and four states may take either of these
actions when water quality standards have been exceeded.
Since the passage of the BEACH Act, the frequency of water quality
monitoring at Great Lakes beaches has increased, helping states and
localities to identify the scope of contamination; however, in most
cases, the underlying causes of the contamination remain unknown and
unaddressed. Local officials reported that the frequency of monitoring
had increased at 45 percent of Great Lakes beaches since the passage of
the BEACH Act. The increased monitoring has helped state and local
officials determine which beaches are more likely to be contaminated.
However, in most cases, local officials do not know the causes of
contamination and, consequently, have not been able to take actions to
address those causes. Local officials at 67 percent of Great Lakes
beaches did not know the sources of bacterial contamination causing
their exceedances of water quality standards during the 2006 beach
season. Furthermore, local officials indicated that actions to address
the sources of contamination had only been taken at an estimated 14
percent of the monitored beaches we surveyed. Local officials generally
stated that they do not have the funds available to do the
investigations necessary to identify specific sources of contamination
or to take actions to mitigate the problem, and they can not use BEACH
grant funds for this purpose. Our review of the BEACH Act and
discussions with EPA officials indicate that it appears EPA cannot
award BEACH Act grants for these purposes. According to state and local
officials, an overall improvement in water quality throughout the Great
Lakes will require a long-term collaborative effort to address the
underlying causes of contamination and also will require increased
funding.
To assist states and localities in identifying and addressing sources
of beach contamination, Congress should consider allowing states some
flexibility to use their BEACH Act grants to undertake limited research
to identify specific sources of contamination at monitored beaches and
take certain actions to mitigate these problems. In addition, we are
recommending that EPA establish a definitive time line for completing
the studies on pathogens and their effects on human health and for
publishing new or revised water quality criteria for pathogens and
pathogen indicators. To better account for states' varied monitoring
needs, if current funding levels remain the same, EPA should reevaluate
the funding formula factors to determine if the weight of the beach
season factor should be reduced, and the weight of the other factors
should be increased. To better ensure consistent levels of public
health protection, EPA should also provide states and localities with
specific guidance on monitoring frequency and methods and public
notification. In commenting on the draft report, EPA generally agreed
with GAO's recommendations and agreed to (1) take actions to establish
an action plan and a definitive time frame to complete studies and
publish revised water quality standards and (2) revise its guidance to
states. With respect to our recommendation to revise the current
funding formula to better reflect states' needs, EPA agreed with this
recommendation, but stated that the states were reluctant to make any
substantial changes to the formula and were supportive of EPA's plan to
make only minor changes to the formula.
Background:
More than 30 million people in the United States rely on the five Great
Lakes--Superior, Michigan, Huron, Erie, and Ontario--as a principal
source of their drinking water, recreation, and economic livelihood.
There are hundreds of beaches along the Great Lakes' approximately
5,000 miles of U.S. shoreline that spans eight states: Illinois,
Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania, and
Wisconsin. Figure 1 shows the five lakes and the eight states with
Great Lakes shorelines, along with their population concentrations.
Figure 1: Map of the Five Great Lakes and Eight Great Lakes States with
Population Density by County:
[See PDF for image]
Sources: United States Census Bureau Population Estimates, 2005. Map:
Ginny Mason, Congressional Cartography, Library of Congress, 2006.
[End of figure]
Development on lands adjacent to the lakes has seriously degraded the
lakes' water quality and, in some areas, contaminated recreational
waters with pathogens--including bacteria, viruses, and parasites--
that can threaten human health and force restrictions on recreational
activities such as swimming at the beaches. Contact with or accidental
ingestion of water contaminated with these pathogens can cause
vomiting, diarrhea, and other illnesses, and may be life-threatening
for susceptible populations such as children, the elderly, and those
with impaired immune systems. When pathogen levels are high enough to
threaten human health, officials from local health departments or
municipalities restrict public access to beaches by issuing health
advisories or through the use of beach closures to lower the risk of
public exposure to these pathogens.
One of the key contributors to this waterborne contamination is fecal
matter from humans and other warm-blooded animals. While sources can
vary from beach to beach, those close to urban areas are more likely to
be affected by sources such as wastewater treatment plants, combined
sewer overflows, and municipal storm sewer systems that can directly
contribute to high levels of bacterial contamination. Beaches in states
with large confined animal feeding operations may be affected by runoff
from these operations. Many beaches are affected by nonpoint source
pollution when storm water runs off impervious surfaces such as streets
and parking lots and picks up pollutants along the way. In addition,
wildlife--in particular seagulls and geese--can congregate on beaches
and lead to significant levels of fecal contamination. Figure 2 shows
some of the potential sources of fecal contamination at beaches in the
Great Lakes.
Figure 2: Potential Sources of Fecal Contamination at Beaches in the
Great Lakes:
[See PDF for image]
Sources: GAO (data); EPA (photo insert).
[End of figure]
Under the Clean Water Act, EPA is responsible for publishing water
quality criteria that identify thresholds at which pathogens may
constitute a risk to human health. States can then use EPA's criteria,
or propose other criteria that EPA deems are as protective of human
health, to develop water quality standards for their recreational
beaches.[Footnote 3] Because pathogens are found sporadically in
recreational waters and can be difficult and costly to detect, EPA has
recommended other more easily identified organisms--called pathogen
indicators--that can indicate the potential for the presence of
pathogens. During the 1960s and 1970s, EPA evaluated several types of
bacteria for use as pathogen indicators and recommended using fecal
coliforms as a pathogen indicator for state recreational water quality
standards. By 1986, new research questioned the reliability of using
fecal coliforms as a pathogen indicator and prompted EPA to recommend
new criteria using E. coli for freshwater and enterococci for fresh and
marine recreational waters.
In 1997, EPA announced a new national program to work with state,
tribal, and local governments to compile information on beach
contamination defining the national extent of the problem. EPA began
gathering information on state and local beach programs through its
National Health Protection Survey of Beaches in 1998. The survey
collected information on monitoring methods used to issue advisories
and closures and the sources of contamination at swimming beaches. In
1999, EPA published a multiyear strategy aimed at improving
recreational water quality programs. This action plan noted that water
quality monitoring programs varied widely at the state and local
levels, and its objective was to enable the consistent management of
recreational water quality programs.
Congress passed the BEACH Act in 2000, amending the Clean Water Act to
improve beach water quality monitoring notification programs. The act
defines coastal recreation waters as Great Lakes and marine coastal
waters designated for swimming, bathing, or similar water contact
activities; inland waters are not included in this definition. The
BEACH Act required states to adopt new or revised water quality
standards by April 10, 2004, for pathogens and pathogen indicators for
their coastal recreation waters that were as protective as EPA's
published criteria. The act required EPA to propose regulations setting
forth new or revised water quality standards for states that had failed
to meet this deadline. In addition, the BEACH Act required EPA to
conduct studies of the relationship between pathogens and human health
and to publish new or revised criteria based on those studies. The
BEACH Act also authorized EPA to award grants to states, local
governments, and tribes to develop and implement beach monitoring and
notification programs. The BEACH Act required EPA to develop and
publish performance criteria that recipients must meet in order to
receive these grants.
EPA Has Taken Steps to Implement the BEACH Act, but Its Grant
Distribution Formula Does Not Adequately Reflect States' Monitoring
Needs:
EPA has implemented seven of the nine BEACH Act requirements and
provisions and has distributed approximately $51 million in BEACH Act
grants since 2001 and created a national water pollution database,
among other requirements. However, EPA has missed statutory deadlines
for two actions: (1) completing required studies on pathogens and human
health for both marine and freshwater by 2003 and (2) using these
studies to publish new or revised water quality criteria for pathogen
indicators by 2005. In addition, the grant distribution formula that
EPA developed to distribute BEACH Act grants does not adequately
reflect the states' varied beach monitoring needs because it does not
appropriately reflect the length of beach miles needing monitoring or
the population using the beaches.
EPA Has Implemented Some but Not All BEACH Act Requirements and
Provisions:
Of the nine actions required by the BEACH Act, EPA has taken the
following seven:
Propose water quality standards and criteria--The BEACH Act required
each state with coastal recreation waters[Footnote 4] to incorporate
EPA's published criteria for pathogens or pathogen indicators, or
criteria EPA considers equally protective of human health, into their
state water quality standards by April 10, 2004. The BEACH Act also
required EPA to propose regulations setting forth federal water quality
standards for those states that did not meet the deadline. On November
16, 2004, EPA published in the Federal Register a final rule
promulgating its 1986 water quality standards for E. coli and
enterococci for the 21 states and territories that had not adopted
water quality criteria that were as protective of human health as EPA's
approved water quality criteria.[Footnote 5] According to EPA, all 35
states with coastal recreational waters are now using EPA's 1986
criteria, compared with the 11 states that were using these criteria in
2000.
Provide BEACH Act grants--The BEACH Act authorized EPA to distribute
annual grants to states, territories, tribes and, in certain
situations, local governments to develop and implement beach monitoring
and notification programs. While the BEACH Act authorized $30 million
per year for BEACH Act grants, actual allocations have been about $10
million a year in accordance with directions from Congressional
conference reports. Since 2001, EPA has awarded approximately $51
million in development and implementation grants for beach monitoring
and notification programs to all 35 states. Alaska is the only eligible
state that has not yet received a BEACH Act implementation grant
because it is still in the process of developing a monitoring and
public notification program consistent with EPA's grant performance
criteria. EPA expects to distribute approximately $10 million for the
2007 beach season subject to the availability of funds.
Publish beach monitoring guidance and performance criteria for grants-
-The BEACH Act required EPA to develop guidance and performance
criteria for beach monitoring and assessment for states receiving BEACH
Act grants by April 2002. After a year of consultations with coastal
states and organizations, EPA responded to this requirement in 2002 by
issuing its National Beach Guidance and Required Performance Criteria
for Grants. To be eligible for BEACH Act grants, EPA requires
recipients to develop (1) a list of beaches evaluated and ranked
according to risk, (2) methods for monitoring water quality at their
beaches, such as when and where to conduct sampling, and (3) plans for
notifying the public of the risk from pathogen contamination at
beaches, among other requirements.
Develop a list of coastal recreational waters--The BEACH Act required
EPA to identify and maintain a publicly available list of coastal
recreational waters adjacent to beaches or other publicly accessible
areas, with information on whether or not each is subject to monitoring
and public notification. In March 2004, EPA published its first
comprehensive National List of Beaches based on information that the
states had provided as a condition for receiving BEACH Act grants. The
list identified 6,099 coastal recreational beaches, of which 3,472, or
57 percent, are being monitored. The BEACH Act also requires EPA to
periodically update its initial list and publish revisions in the
Federal Register. However, EPA has not yet published a revised list, in
part because some states have not provided updated information.
Develop a water pollution database--The BEACH Act required EPA to
establish, maintain, and make available to the public an electronic
national water pollution database. In May 2005, EPA unveiled
"eBeaches," a collection of data pulled from multiple databases on the
location of beaches, water quality monitoring, and public notifications
of beach closures and advisories.[Footnote 6] This information has been
made available to the public through an online tool called BEACON
(Beach Advisory and Closing Online Notification). EPA officials
acknowledge that eBeaches has had some implementation problems,
including periods of downtime when states were unable to submit their
data, and states have had difficulty compiling the data and getting it
into EPA's desired format. EPA is working to centralize its databases
so that states can more easily submit information and expects the data
reporting will become easier for states as they further develop their
system.
Provide technical assistance on floatable materials--The BEACH Act
required EPA to provide technical assistance to help states, tribes,
and localities develop their own assessment and monitoring procedures
for floatable debris in coastal recreational waters. EPA responded by
publishing guidance titled Assessing and Monitoring Floatable Debris in
August 2002. The guidance provided examples of monitoring and
assessment programs that have addressed the impact of floatable debris
and examples of mitigation activities to address floatable debris.
Provide a report to Congress on status of BEACH Act implementation--The
BEACH Act required EPA to report to Congress 4 years after enactment of
the act and every 4 years thereafter on the status of implementation.
EPA completed its first report for Congress, Implementing the BEACH Act
of 2000: Report to Congress in October 2006, which was 2 years after
the October 2004 deadline. EPA officials noted that they missed the
deadline because they needed additional time to include updates on
current research and states' BEACH Act implementation activities and to
complete both internal and external reviews.
EPA has not yet completed the following two BEACH Act requirements:
Conduct epidemiological studies--The BEACH Act required EPA to publish
new epidemiological studies concerning pathogens and the protection of
human health for marine and freshwater by April 10, 2002, and to
complete the studies by October 10, 2003. The studies were to: (1)
assess potential human health risks resulting from exposure to
pathogens in coastal waters; (2) identify appropriate and effective
pathogen indicator(s) to improve the timely detection of pathogens in
coastal waters; (3) identify appropriate, accurate, expeditious, and
cost-effective methods for detecting the presence of pathogens; and (4)
provide guidance for state application of the criteria. EPA initiated
its multiyear National Epidemiological and Environmental Assessment of
Recreational Water Study in 2001 in collaboration with the Centers for
Disease Control and Prevention. The first component of this study was
to develop faster pathogen indicator testing procedures. The second
component was to further clarify the health risk of swimming in
contaminated water, as measured by these faster pathogen indicator
testing procedures.[Footnote 7] While EPA completed these studies for
freshwater--showing a promising relationship between a faster pathogen
indicator and possible adverse health effects from bacterial
contamination--they have not completed the studies for marine water.
EPA initiated marine studies in Biloxi, Mississippi, in the summer of
2005, 3 years past the statutory deadline for beginning this work, but
the work was interrupted by Hurricane Katrina. EPA officials reported
that additional studies are planned for the summer of 2007, pending
funding.
Publish new pathogen criteria--The BEACH Act required EPA to use the
results of its epidemiological studies to identify new pathogen
indicators with associated criteria, as well as new pathogen testing
measures by October 2005. However, since EPA has not completed the
studies on which these criteria were to be based, this task has been
delayed.
An EPA official reports that EPA has not established a time line for
completing these two remaining provisions of the BEACH Act but
estimates it may take an additional 4-5 years. One EPA official told us
that the initial time frames in the act may not have been realistic.
EPA's failure to complete studies on the health effects of pathogens
for marine waters and failure to publish revised water quality criteria
for pathogens and pathogen indicators prompted the Natural Resources
Defense Council to file suit against EPA on August 2, 2006, for failing
to comply with the statutory obligations of the BEACH Act.
In the absence of new criteria for pathogens and pathogen indicators,
states continue to use EPA's 1986 criteria. EPA reaffirmed the use of
these indicators when it published the draft Implementation Guidance
for Ambient Water Quality for Bacteria in May 2002 and when it set
forth state water quality standards in November 2004. However, there
are two significant limitations to using these indicators:
* The current approved methods of analyzing E.coli and enterococci
require a long incubation period, during which time the bacteria grow
to detectable levels. Local officials at 96 percent of Great Lakes
beaches reported that it took 18-36 hours to get results on water
quality samples once the samples reached the laboratory. Consequently,
water quality sample results indicate the previous day's bacterial
levels, and health advisories or beach closures are based on those
levels. By the time the results are compiled and health advisories or
notices are posted, the contamination may or may not have cleared up.
In any case, beach monitoring personnel would need to retest the water
to determine whether there was still contamination and go through this
18-36 hour cycle again to establish the current conditions. Real-time
or near-time analytical methods would enable officials to better
protect human health because their actions would be based on more
timely and current information. EPA scientists acknowledge that the
public would like nearly immediate testing methods, but note that the
technology does not yet exist.
* The current pathogen indicators--E.coli and enterococci --may not be
good indicators of the presence of pathogens or health risks. EPA
scientists also noted that E.coli may not be an effective indicator
because it is ubiquitous and occurs naturally in many environments. In
addition, current testing methods cannot distinguish whether fecal
contamination is from a human or animal source. Human fecal
contamination may indicate the presence of pathogens that pose a
greater risk to humans than does the presence of fecal contamination
from pets or wildlife. While there are methods to determine the source
of fecal contamination, such as microbial source tracking, scientists
we spoke with noted that this method is time-intensive, expensive, and
not readily available.
The lack of a reliable indicator and the lag time for test results
using current methods could lead to unnecessary beach closures, or
conversely, keeping beaches open when they should have been closed.
Because local officials generally use the same laboratory tests to
determine the results of water quality sampling, this is a potential
problem for all 35 states and territories with coastal recreational
waters and not just the Great Lakes states. A time lag of the entire
process is shown in figure 3.
Figure 3: Time Lag Associated with Current Water Quality Monitoring and
Public Notification Methods:
[See PDF for image]
Sources: GAO and (left to right) PhotoDisc, Creatas, and Fish and
Wildlife Service (photographs).
Note: Figure 3 represents a best case scenario where test results are
available within 24 hours. In some cases, it may take officials upward
of 36-48 hours to get water quality results and make notification
decisions.
[End of figure]
EPA's BEACH Act Grant Formula Does Not Adequately Reflect States'
Monitoring Needs:
While EPA distributed approximately $51 million in BEACH Act grants
between 2001 and 2006 to the 35 eligible states and territories, its
grant distribution formula does not adequately account for states'
widely varied beach monitoring needs. When Congress passed the BEACH
Act in 2000, it authorized $30 million in grants annually, but the act
did not specify how EPA should distribute grants to eligible states.
Beginning in 2001, EPA consulted with representatives from the Coastal
States Organization and the Association of State and Interstate Water
Pollution Control Administrators to consider the states' needs. EPA
determined that initially $2 million would be distributed equally to
all states to cover the base cost of developing water quality
monitoring and notification programs. EPA then developed a distribution
formula for future annual grants that reflected the BEACH Act's
emphasis on beach use and risk to human health. EPA's funding formula
includes the following three factors:
* Length of beach season--EPA selected beach season length[Footnote 8]
as a factor because states with longer beach seasons would require more
monitoring.
* Beach use--EPA selected beach use as a factor because more heavily
used beaches would expose a larger number of people to pathogens,
increasing the public health risk and thus requiring more monitoring.
EPA used coastal population[Footnote 9] as a proxy for beach use
because information on the number of beach visitors was not
consistently available across all the states.
* Beach miles--EPA selected beach miles because states with longer
shorelines would require more monitoring. EPA used shoreline
miles,[Footnote 10] which may include industrial and other nonpublicly
accessible areas, as a proxy for beach miles because verifiable data
for beach miles was not available.
Once EPA determined which funding formula factors to use, EPA officials
weighted the factors. EPA intended that the beach season factor would
provide the base funding and would be augmented by the beach use and
beach mile factors. EPA established a series of fixed amounts that
correspond to states' varying lengths of beach seasons to cover the
general expenses associated with a beach monitoring program. For
example, EPA estimated that a 3-month, or less, beach season would
require approximately two full-time employees costing $150,000, while
states with beach seasons greater than 6 months would require $300,000.
Once the allotments for beach season length are distributed, EPA
determined that 50 percent of the remaining funds would be distributed
according to states' beach use, and the other 50 percent would be
distributed according to states' beach miles, as shown in table 1.
Table 1: BEACH Act Grant Distribution Formula:
Formula factor: Beach season length;
Amount of grant: Less than 3 months: $150,000; 3-4 months: $200,000; 5-
6 months: $250,000; Greater than 6 months: $300,000.
Formula factor: Beach use;
Amount of grant: 50% of funds remaining after allotment of beach season
length funding
Formula factor: Beach miles;
Amount of grant: 50% of funds remaining after allotment of beach season
length funding
Source: EPA.
[A] States with less than a 3-month beach season only receive the
$150,000 in beach season length funding.
[End of table]
EPA officials told us that, originally, the factors would have received
relatively equal weight. Using the distribution formula above and
assuming a $30 million authorization, this would have resulted in the
following allocation across the 35 eligible states: beach season--27
percent (about $8 million); beach use--37 percent (about $11 million);
and beach miles--37 percent (about $11 million). However, since 2002,
funding levels for BEACH Act grants have been about $10 million each
year. Once the approximately $8 million, of the total $10 million
available for grants, was allotted for beach season length, this left
only $2 million, instead of nearly $22 million, to be distributed
equally between the beach use and beach miles factors. This resulted in
the following allocation across the 35 eligible states: beach season--
82 percent (about $8 million); beach use--9 percent (about $1 million);
and beach miles--9 percent (about $1 million). As a result, beach use
and beach miles, which vary widely among the states, account for a much
smaller portion of the distribution formula and, consequently, there is
little variation in grant amounts across the states compared with their
monitoring needs.
Across the Great Lakes, there is significant variation in coastal
populations and in miles of shoreline, but the current BEACH Act grant
allocations are relatively flat. For example, Indiana, which has 45
miles of shoreline and a coastal population of 741,468, received about
$205,800 in 2006, while Michigan, which has 3,224 miles of shoreline
and a coastal population of 4,842,023, received about $278,450 in 2006.
If EPA were to reweight the factors so that they were still roughly
equal given the $10 million appropriation, states' grants would better
reflect these variations.[Footnote 11] Table 2 shows the Great Lakes
states' beach season lengths; beach use, as indicated by coastal
populations; and beach miles, as indicated by shoreline miles; and
compares their current BEACH Act grants with estimates of how much
their grants would be if EPA reweighted the formula given the current
appropriation levels of approximately $10 million.[Footnote 12]
Table 2: BEACH Act Funding Formula Inputs for Great Lakes States:
State: Illinois;
Beach season length: 4;
Beach use (coastal population in 2000): 6,021,097;
Beach miles (shoreline miles): 63;
Grant allocation (based on $10 million appropriation): $246,646;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): $250,310;
Estimated difference: $3,664.
State: Indiana;
Beach season length: 4;
Beach use (coastal population in 2000): 741,468;
Beach miles (shoreline miles): 45;
Grant allocation (based on $10 million appropriation): 206,304;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): 91,485;
Estimated difference: -114,819.
State: Michigan;
Beach season length: 4;
Beach use (coastal population in 2000): 4,842,023;
Beach miles (shoreline miles): 3,224;
Grant allocation (based on $10 million appropriation): 285,214;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): 402,148;
Estimated difference: 116,934.
State: Minnesota;
Beach season length: 4;
Beach use (coastal population in 2000): 236,946;
Beach miles (shoreline miles): 189;
Grant allocation (based on $10 million appropriation): 204,639;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): 84,932;
Estimated difference: -119,707.
State: New York[A];
Beach season length: 4;
Beach use (coastal population in 2000): 16,088,089;
Beach miles (shoreline miles): 2,625;
Grant allocation (based on $10 million appropriation): 361,565;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): 702,739;
Estimated difference: 341,174.
State: Ohio;
Beach season length: 4;
Beach use (coastal population in 2000): 2,767,328;
Beach miles (shoreline miles): 312;
Grant allocation (based on $10 million appropriation): 225,694;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): 167,821;
Estimated difference: -57,873.
State: Pennsylvania;
Beach season length: 4;
Beach use (coastal population in 2000): 2,946,892;
Beach miles (shoreline miles): 140;
Grant allocation (based on $10 million appropriation): 224,471;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): 163,007;
Estimated difference: -61,464.
State: Wisconsin;
Beach season length: 4;
Beach use (coastal population in 2000): 1,992,393;
Beach miles (shoreline miles): 820;
Grant allocation (based on $10 million appropriation): $227,448;
Estimated grant allocation using reweighted factors (based on $10
million appropriation): $174,729;
Estimated difference: -$52,719.
Sources: EPA and GAO.
[A] Includes Atlantic and Great Lake coasts.
[End of table]
Because of the current formula allocations, some states and localities
have expressed concerns that their BEACH Act grants are insufficient to
adequately monitor their beaches. For example, state officials in
Michigan and Wisconsin reported that, due to limited financial
resources and the large number of beaches in their states, they are
unable to test all of their beaches, or to test them more than once per
week. Similarly, local officials at 44 percent of the beaches we
surveyed reported that their BEACH Act grants were either inadequate or
very inadequate for the purpose of monitoring their beaches; while 31
percent reported that their BEACH Act grants were adequate or very
adequate.[Footnote 13] One state official indicated that if their
state's funding level decreases, several of their localities would
prefer to end their beach monitoring programs.
EPA recognizes that there are limitations to the factors in its grant
distribution formula and that, as a result of current funding
allocations, the factors are no longer relatively equally weighted.
Beginning in February 2006, EPA convened six workshop meetings to
evaluate potential changes to the formula, with 25 of the 35 eligible
states participating. The work group considered several modifications
to the formula including: (1) reducing the fixed factor based on beach
season length from a base of $150,000 to $100,000, so that other
factors have more weight; (2) replacing shoreline miles data with
actual beach length data now available from the BEACON database; and
(3) replacing coastal county population with data from a NOAA marine
survey of the number of participants in beach recreation activities.
EPA notes that the work group has also discussed including a factor
related to the number of water samples collected. At the time of this
report's release, EPA had not changed the funding formula.
Great Lakes States' Beach Monitoring and Public Notification Programs
Vary Across Localities and May Not Provide Consistent Levels of Public
Health Protection:
All eight Great Lakes states have used BEACH Act grants to develop
beach monitoring and public notification programs. However, the
frequency with which they monitor their beaches, the methods to monitor
beaches, and the processes for notifying the public of health
advisories and beach closures vary within and across states. These
variations may lead to inconsistent levels of public health protection
across beaches in the Great Lakes.
Great Lakes States Used BEACH Act Grants to Develop Beach Monitoring
and Public Notification Programs:
All eight Great Lakes states have used BEACH Act grants to develop
beach monitoring and public notification programs. Three of the eight
Great Lakes states--Indiana, Minnesota, and Wisconsin--did not have
water quality monitoring programs prior to the BEACH Act and used their
BEACH Act grants to implement such programs. The remaining five states
expanded their existing beach monitoring programs. In most cases, EPA
gives the BEACH Act grants directly to state environmental protection
agencies, which administer the grants, compile and submit water quality
monitoring and public notification data to EPA, and prepare grant
applications and annual reports.[Footnote 14] The states usually
distribute the funds they receive to localities who implement or
develop monitoring and notification programs. The localities, through
local health departments or other public health agencies, usually
collect water samples at local beaches and post results. EPA notes that
localities have traditionally played the lead role in implementing
these programs because they are often more familiar with local problems
and may be better suited to address them.
To be eligible for BEACH Act grants, EPA requires states, tribes, or
local governments to develop, among other things: (1) a list of beaches
evaluated and ranked according to risk; (2) methods for monitoring
water quality at their beaches, such as when and where to conduct
sampling, and (3) plans for notifying the public of the risk from
pathogen contamination.
Develop a list of beaches. EPA required states and territories that
received BEACH Act grants to develop and submit to EPA lists of their
beaches that identified whether there was a monitoring program in place
for each beach. EPA's BEACH Act grant performance criteria also
required states and local government to rank their beaches based on
beach use and risk to human health from pathogens. In developing their
beach classification and prioritization schemes, the Great Lakes states
considered beach use and accessibility, historical contamination
problems, and proximity to known sources of contamination. Table 3
shows the number of Great Lakes beaches and the percentage being
monitored, as reported by officials from the Great Lakes states for the
2006 beach season.
Table 3: Number of Great Lakes Beaches Identified, Number and
Percentage of Beaches Being Monitored for the 2006 Beach Season:
State: Illinois;
Number of Great Lakes beaches identified: 69;
Number of beaches monitored: 54;
Percentage of beaches monitored: 78%.
State: Indiana;
Number of Great Lakes beaches identified: 30;
Number of beaches monitored: 25;
Percentage of beaches monitored: 83.
State: Michigan;
Number of Great Lakes beaches identified: 905;
Number of beaches monitored: 212;
Percentage of beaches monitored: 23.
State: Minnesota;
Number of Great Lakes beaches identified: 79;
Number of beaches monitored: 39;
Percentage of beaches monitored: 49.
State: New York[A];
Number of Great Lakes beaches identified: 38;
Number of beaches monitored: 38;
Percentage of beaches monitored: 100.
State: Ohio;
Number of Great Lakes beaches identified: 54;
Number of beaches monitored: 54;
Percentage of beaches monitored: 100.
State: Pennsylvania;
Number of Great Lakes beaches identified: 12;
Number of beaches monitored: 12;
Percentage of beaches monitored: 100.
State: Wisconsin;
Number of Great Lakes beaches identified: 192;
Number of beaches monitored: 123;
Percentage of beaches monitored: 64.
State: Total;
Number of Great Lakes beaches identified: 1,379;
Number of beaches monitored: 557;
Percentage of beaches monitored: 40%.
Source: GAO analysis of information provided by state BEACH Act
officials.
[A] New York has shoreline miles both along the Atlantic Ocean and
along Lake Erie and Lake Ontario. There are 348 beaches in the state of
New York, and all are monitored.
[End of table]
Develop methods for monitoring water quality. EPA also recommended that
states and localities develop a three-tiered plan that prioritizes
beaches for monitoring. EPA intended the beach prioritization scheme to
allow beach managers to devote more resources and intensive monitoring
and notification efforts to those high-use and/or high-risk beaches. A
tier 1 classification indicates that the beach is a high-use and/or
high-risk beach and, therefore, is a high priority for monitoring. A
tier 2 beach is a medium-use and/or medium-risk beach and is a lower
priority for monitoring. A tier 3 beach is a low-use and/or low-risk
beach and is a low priority for monitoring. All eight Great Lakes
states prioritized their beaches for monitoring according to EPA's
suggested factors of beach use and risk to human health. Great Lakes
beaches have varying numbers of high, medium, and low-priority beaches,
as shown in table 4.
Table 4: Great Lakes Prioritized Beaches Reported by States for
Monitoring Using BEACH Act Grant Funds as of October 2006:
State: Illinois[A];
Number of beaches by priority: High: 49;
Number of beaches by priority: Medium: 5;
Number of beaches by priority: Low: 15[B];
Number of beaches by priority: Beaches prioritized for monitoring: 54.
State: Indiana;
Number of beaches by priority: High: 7;
Number of beaches by priority: Medium: 10;
Number of beaches by priority: Low: 6;
Number of beaches by priority: Beaches prioritized for monitoring: 23.
State: Michigan;
Number of beaches by priority: High: 207;
Number of beaches by priority: Medium: Varies[C];
Number of beaches by priority: Low: 334;
Number of beaches by priority: Beaches prioritized for monitoring: 207.
State: Minnesota;
Number of beaches by priority: High: 9;
Number of beaches by priority: Medium: 30;
Number of beaches by priority: Low: 0;
Number of beaches by priority: Beaches prioritized for monitoring: 39.
State: New York;
Number of beaches by priority: High: 20;
Number of beaches by priority: Medium: 13;
Number of beaches by priority: Low: 5;
Number of beaches by priority: Beaches prioritized for monitoring: 38.
State: Ohio;
Number of beaches by priority: High: 41;
Number of beaches by priority: Medium: 0;
Number of beaches by priority: Low: 11;
Number of beaches by priority: Beaches prioritized for monitoring: 52.
State: Pennsylvania;
Number of beaches by priority: High: 11;
Number of beaches by priority: Medium: 1;
Number of beaches by priority: Low: 0;
Number of beaches by priority: Beaches prioritized for monitoring: 12.
State: Wisconsin;
Number of beaches by priority: High: 34;
Number of beaches by priority: Medium: 39;
Number of beaches by priority: Low: 50;
Number of beaches by priority: Beaches prioritized for monitoring: 123.
Source: GAO analysis of information provided by state BEACH Act
officials.
[A] Does not include Chicago beaches because Chicago did not originally
apply for BEACH Act grants.
[B] Illinois does not monitor its 15 tier 3 beaches.
[C] Michigan reported that the number of tier 2 (medium) priority
beaches varies. Michigan does not monitor its 334 tier 3 beaches.
[End of table]
Develop public notification plans. EPA's grant performance criteria
require states and localities that find their beach water contamination
exceeds EPA's criteria to notify the public or resample the water.
EPA's guidelines allow states to monitor for two pathogen indicators in
freshwater--E. coli and enterococci--using two water quality testing
options--a single sample or a geometric mean ("geomean") based on no
fewer than five samples equally spaced over a 30-day period. Health
departments may also use observations of the presence of visible
debris/contaminants, as well as predicted high levels of rainfall or
sewage releases.[Footnote 15] If there is a water quality exceedance,
states or localities may resample if there is reason to doubt the
accuracy or certainty of the sample results. If the second sample
indicates that a water quality standard has been exceeded, states and
localities must provide prompt public notification. State or local
health officials decide whether or not to issue a health advisory or
close a beach. EPA's performance criteria allow states and localities
to develop signs or "functionally equivalent" communication measures,
which may include press releases, signs posted at the beach, or
Internet sites, among other things. All of the Great Lakes states have
developed public notification plans and may post beach advisory and/or
closure decisions on signs on the beach, or on the Internet, among
other methods.
Variation in Beach Monitoring and Public Notification Methods May Lead
to Inconsistent Protection of Public Health:
While the Great Lakes states and localities have generally adhered to
EPA's criteria for receiving BEACH Act grants, their beach monitoring
and public notification programs vary considerably. EPA grant criteria
and the BEACH Act give states and localities some flexibility as to:
(1) the frequency of monitoring; (2) which beaches are selected for
monitoring, methods of monitoring; and (3) processes for notifying the
public when pathogen indicator levels exceed state standards, including
the decision to close beaches or issue a public health advisory.
Nevertheless, we identified significant variability in the Great Lakes
states beach monitoring and public notification programs, including the
frequency at which they monitor high-priority beaches, the depths at
which they take water samples, and the processes they use for notifying
the public of health risks from pathogen criteria.
Frequency of monitoring. Some Great Lakes states are monitoring their
high-priority beaches almost daily, while other states monitor their
high-priority beaches as little as one to two times per week. The
frequency with which the Great Lakes states monitor their beaches
varies, due in part to the availability of funding. For example, state
officials in Michigan and Wisconsin reported a lack of funding for
monitoring. While EPA officials reported that daily beach monitoring is
recommended for high-priority beaches, EPA acknowledges that frequency
and location of monitoring may be limited by funding and staffing
levels. Table 5 shows the variation in monitoring at Great Lakes
beaches.
Table 5: Monitoring Frequency of Great Lake Beaches by Priority:
State: Illinois;
High-priority: 5-7 days per week;
Medium-priority: 1 day per week;
Low-priority: Not monitored.
State: Indiana;
High-priority: 5 days per week;
Medium-priority: 5 days per week;
Low-priority: 5 days per week.
State: Michigan;
High-priority: 1-2 days per week;
Medium-priority: 1 day per year;
Low-priority: Not monitored.
State: Minnesota;
High-priority: 2 days per week;
Medium-priority: 1 day per week;
Low-priority: Not monitored.
State: New York;
High-priority: 1-2 days per week;
Medium-priority: Once every 2 weeks;
Low-priority: 1 day per month.
State: Ohio;
High-priority: 4 days per week;
Medium-priority: Not applicable[A];
Low-priority: 1 day per week.
State: Pennsylvania;
High-priority: 2 days per week;
Medium-priority: 1 day per week;
Low-priority: Not applicable[B].
State: Wisconsin;
High-priority: 4-7 days per week;
Medium-priority: 2 days per week;
Low-priority: 1 day per week.
Source: GAO analysis of information provided by state BEACH Act
officials.
[A] Ohio reported that the state does not currently classify any
beaches as tier 2.
[B] Pennsylvania reported that the state does not currently classify
any beaches as tier 3.
[End of table]
Because of the variation in the number of days beaches are tested, more
information is known about some beaches than others, and it is
difficult to compare data across beaches. For example, local officials
at one high-priority beach in our sample reported that their beach was
monitored on 10 days out of the 90-day beach season. On 1 of these 10
testing days--or 10 percent, the samples exceeded the applicable water
quality standards, causing the beach to be closed. In contrast, local
officials at another high-priority beach in our sample reported that
their beach was monitored on 92 days of its 95 day beach season. On 22
of these 92 testing days--or 24 percent, the samples exceeded the
applicable water quality standards, causing the beach to be closed. At
first glance, the first beach would appear to have better water quality
than the second beach. However, because the first beach was tested on
only 10 days, conclusions cannot be reliably drawn about the water
quality for the remaining 80 days of the beach season. One state
official commented that human health could be better protected if the
managers were taking more samples.
Without daily testing at all beaches, conclusions also cannot be drawn
about the number of safe days at beaches. However, EPA appears to do
just that in its annual performance report, which concluded that
beaches were "open and safe for swimming" on 97 percent of the days of
the 2005 season nationwide, exceeding EPA's 94 percent benchmark goal
for fiscal year 2006. This percentage assumes that any day that a beach
was open it was safe for swimming, even if it was not tested.[Footnote
16] Additionally, according to EPA data, in 2005, 3,245 of the possible
58,710 beach days in the Great Lakes, or 5.5 percent, were under an
advisory or closure and unsafe for recreational use.[Footnote 17] Based
on EPA's methodology, the beaches were open and safe for swimming on
the other 94.5 percent of the days during the season. However, this
conclusion cannot be drawn because nothing is known about the quality
of the water on days that water is not tested. According to EPA
officials, the balance of the other 94.5 percent of the days for which
no advisory or closure action was in effect--days on which the beaches
are open--is subject to the limitations and uncertainties of current
monitoring practices, including relatively infrequent monitoring for
the most part, and testing methods that require 18-36 hours to obtain
results. EPA officials indicated that the benefits of water quality
monitoring generally outweigh these limitations and uncertainties.
Methods of sampling. Most of the Great Lakes states and localities use
similar sampling methods to monitor water quality at local beaches. For
example, officials at 79 percent of the beaches we surveyed reported
that they collected water samples during the morning, and 78 percent
reported that they always collected water samples from the same
location. Collecting data at the same time of day and from the same
site ensures more consistent water quality data. However, we found
significant variations in the depth at which local officials in the
Great Lakes states were taking water samples. According to EPA, depth
is a key determinant of microbial indicator levels.[Footnote 18] EPA's
guidance recommends that beach officials sample at the same depth--knee
depth, or approximately 3-feet deep--for all beaches to ensure
consistency and comparability among samples. Great Lakes states,
however, varied considerably in the depths at which they sampled water,
with some sampling occurring at 1-6 inches and other sampling at 37-48
inches. Figure 4 shows the variation in the depths at which Great Lakes
state officials took water quality samples.
Figure 4: Reported Depth of Water Quality Sampling at Great Lakes
Beaches:
[See PDF for image]
Source: Responses to GAO's survey of monitored beaches in the great
lakes.
Note: Percentages may not sum to 100 percent due to rounding.
[End of figure]
Public notification. Local officials in the Great Lakes differ in the
information they use to decide whether to issue a health advisory or
close beaches when water contamination exceeds EPA criteria and in how
to notify the public of their decision. The EPA criteria for single-
sample tests or a 5-day geometric mean for E. coli indicate that single-
sample test results cannot exceed 235 bacteria colonies per 100/ ml
sample, and geomean results cannot exceed 126 bacteria colonies per
100/ml sample.[Footnote 19] However, even with these designated testing
thresholds, the decisions on whether or not to issue a public health
advisory or close a beach can vary within and across the Great Lakes
states. This happens because states have established different
standards for triggering an advisory or closure, and states vary in
whether they will issue advisories or closures or both. For example,
Minnesota and Ohio only issue health advisories; Indiana, Michigan, and
Wisconsin issue both health advisories and beach closures; and
Illinois, New York, and Pennsylvania only issue beach closures. In
addition, while most states will issue an advisory or close a beach
following the first water quality standard exceedance, in some cases,
officials will resample and not close the beach until the standard is
exceeded on 2 consecutive days. Table 6 shows the variation in states'
pathogen indicator thresholds and responses to water quality
exceedances.
Table 6: Variation in Great Lakes States' Pathogen Indicator (E. coli)
Thresholds and Responses to Water Quality Exceedances:
State: Illinois;
Issue advisory: No[B];
Advisory threshold[A]: Not applicable;
Issue closure: Yes;
Closure threshold: 235 single sample.
State: Indiana;
Issue advisory: Yes;
Advisory threshold[A]: 235 single sample or 126 geomean;
Issue closure: Yes;
Closure threshold: 235 single sample or 126 geomean.
State: Michigan;
Issue advisory: Yes;
Advisory threshold[A]: 300 single sample or 130 geomean;
Issue closure: Yes;
Closure threshold: 300 single sample or 130 geomean.
State: Minnesota;
Issue advisory: Yes;
Advisory threshold[A]: 235 single sample or 126 geomean[C];
Issue closure: No;
Closure threshold: Not applicable.
State: New York;
Issue advisory: No;
Advisory threshold[A]: Not applicable;
Issue closure: Yes[D];
Closure threshold: 235 single sample or 126 geomean.
State: Ohio;
Issue advisory: Yes;
Advisory threshold[A]: 235 single sample;
Issue closure: No;
Closure threshold: Not applicable.
State: Pennsylvania;
Issue advisory: No;
Advisory threshold[A]: Not applicable;
Issue closure: Yes;
Closure threshold: 235 single sample or 126 geomean.
State: Wisconsin;
Issue advisory: Yes;
Advisory threshold[A]: 235 single sample or 126 geomean;
Issue closure: Yes;
Closure threshold: 1,000 single sample.
Source: GAO analysis of information provided by state BEACH Act
officials.
[A] Colonies per 100/mL.
[B] The Chicago Park District issues advisories following a 235 single
sample and issues closures following a 1,000 single sample.
[C] EPA approved Michigan's threshold in 1993 determining that there
was no statistical difference between 235 and 300 based on the
estimated number of gastrointestinal illnesses per 1,000 swimmers.
[D] New York state officials indicated that a 235 single sample or 126
geomean would generally prompt a beach closure, however the state
sanitary code provides local health departments some flexibility to
conduct site specific assessments to determine if a beach closure is
appropriate.
[End of table]
In addition to using information from water quality samples, officials
in at least four Great Lakes states--Indiana, Illinois, Ohio, and
Wisconsin--are using predictive models that use real-time data such as
rainfall and water temperature to predict water quality conditions and
to help make more timely decisions about beach closings and advisories.
Officials in Lake County, Illinois, have used BEACH Act grants in the
development of SwimCast, a predictive model that has proven to be 89-95
percent accurate when comparing measured results versus predicted
conditions. In Indiana, officials have used BEACH Act grants and worked
with officials from USGS to develop Project SAFE (Swimming Advisory
Forecast Estimate), which uses real-time information on weather and
water data collected at several locations to predict E. coli count
probability. EPA guidance states that predictive models can effectively
supplement but not replace beach monitoring programs to provide
conservative estimates during the lag time between sampling and water
quality test results.
Also, states' and localities' means of notifying the public of health
advisories or beaches closures vary across the Great Lakes. Some states
post water quality monitoring results on signs at beaches; some provide
results on the Internet or on telephone hotlines; some distribute the
information to local media. When asked to rank the most effective
method of notifying the public of a water quality exceedance, six state
BEACH Act Administrators indicated that posting signs at the beach is
the single most effective method; however, states also vary in the form
and content of their beach signage. Of the beach signs that we
reviewed, the appearance and wording varied considerably and, although
it was recommended in EPA's performance criteria, not all included the
effective date(s) of the health advisory or beach closure or the date
the water quality sampling was conducted, as shown in figure 5.
Figure 5: Variation in Public Notification Signs at Great Lakes
Beaches:
[See PDF for image]
Sources: (left to right) Minnesota Pollution Control Agency, Wisconsin
Department of Natural Resources, and GAO.
[End of figure]
The BEACH Act Has Helped Identify the Scope of Contamination, but
Underlying Causes Remain Unaddressed:
Since the passage of the BEACH Act, increased monitoring has improved
the overall understanding of the scope of contamination in the Great
Lakes and helped local officials determine which of their beaches are
more likely to be contaminated. However, the underlying causes of
contamination are largely unknown and remain unaddressed. Although a
few localities have been able to use the results of monitoring to
identify and take steps to address sources of bacterial contamination,
most do not know the sources of the contamination and, consequently,
have not taken actions to address them. State and local officials
generally stated that they did not have the funds available to
investigate and address specific sources of contamination.
Increased Monitoring Has Helped States Identify the Scope of
Contamination:
Because the frequency of monitoring has increased at Great Lakes
beaches since the passage of the BEACH Act, states and localities have
a better understanding of the overall scope of contamination. BEACH Act
officials from six of the eight states--Illinois, Michigan, Minnesota,
New York, Ohio, and Wisconsin--reported that the number of beaches
being monitored in their state has increased since the passage of the
BEACH Act in 2000. For example, in Minnesota, state officials reported
that only one beach was being monitored prior to the BEACH Act, and
there are now 39 beaches being monitored in three counties. In
addition, EPA data shows that, in 1999, the number of identified
beaches in the Great Lakes was about 330, with about 250 of those being
monitored. In 2005, the most recent year for which data are available,
the Great Lakes states identified almost 900 beaches and were
monitoring about 550, as shown in figure 6.[Footnote 20]
Figure 6: Number of Identified Beaches and Number of Identified Beaches
Monitored in the Great Lakes from 1999 to 2005:
[See PDF for image]
Source: EPA.
Note: From 1998-2002, EPA collected information on beach monitoring
from states through a series of voluntary surveys; participation rates
in these surveys varied from year to year. States receiving BEACH Act
grants are now required to submit information on the number of beaches
in their state, number of monitored beaches, and other related
information to EPA.
[End of figure]
In addition to an increase in the number of beaches being monitored,
the frequency of monitoring at many of the beaches in the Great Lakes
has increased. For example, state BEACH Act officials in Pennsylvania
and Indiana reported that, although the number of beaches being
monitored in their states had not increased, the frequency with which
the beaches were monitored did. Indiana officials noted that, prior to
the BEACH Act, monitoring was done a few times per week; now monitoring
is done 5-7 days per week. In addition, based on our survey, an
estimated 45 percent of Great Lakes beaches increased the frequency of
their monitoring since the passage of the BEACH Act, as shown in figure
7. For example, local officials in one Ohio county reported testing
some beaches along Lake Erie twice a month prior to the BEACH Act; they
are now tested once a week.
Figure 7: Estimated Changes in Frequency of Monitoring at Great Lakes
Beaches Since Passage of the BEACH Act:
[See PDF for image]
Source: Responses to GAO's survey of monitored beaches in the Great
Lakes.
[End of figure]
The increased scope and frequency of monitoring, in response to the
BEACH Act, is helping to identify the overall scope of contamination in
the Great Lakes. While the number of beaches being monitored in the
Great Lakes has increased, the percentage of beaches reporting at least
one health advisory or closure remained around 40 percent from 1999 to
2005. Figure 8 shows the number of monitored beaches with at least one
advisory or closure from 1999 to 2005.
Figure 8: Number of Great Lakes Identified Beaches Monitored and
Monitored Beaches with at Least One Closure or Advisory from 1999 to
2005:
[See PDF for image]
Source: GAO analysis of EPA data.
Note: From 1998-2002, EPA collected information on beach monitoring
from states through a series of voluntary surveys; participation rates
in these surveys varied from year to year. States receiving BEACH Act
grants are now required to submit information on the number of beaches
in their state, number of monitored beaches, and other related
information to EPA.
[End of figure]
Because of the information available from BEACH Act monitoring
activities, state and local beach officials are now better able to
determine which of their beaches are more likely to be contaminated,
which are relatively clean, and which may require additional monitoring
resources to help them better understand the levels of contamination
that may be present. For example, state BEACH Act officials reported
that they now know which beaches are regularly contaminated or are
being regularly tested for elevated levels of contamination. Officials
at 54 percent of Great Lakes beaches we surveyed believe that their
ability to make advisory and closure decisions has increased or greatly
increased since the BEACH Act initiated water quality monitoring, as
shown in figure 9.
Figure 9: Estimated Change in Ability to Make Decisions Based on Water
Quality Data Since Passage of the BEACH Act:
[See PDF for image]
Source: Responses to GAO's survey of monitored beaches in the Great
Lakes.
Note: Percentages may not add to 100 percent due to rounding.
[End of figure]
Most of the Underlying Causes of Contamination Remain Unknown and
Unaddressed:
While some localities have been able to identify and address local
sources of contamination, the specific sources of contamination at most
Great Lakes beaches are not known. States and localities report that,
because they lack funding to investigate and mitigate sources of
contamination, the underlying causes of contamination at most beaches
have not been identified or addressed. Based on our survey, local
officials at 67 percent of Great Lakes' beaches did not know the
sources of bacterial contamination causing their exceedances of water
quality standards during the 2006 beach season.
Nonetheless, five of the eight Great Lakes state BEACH Act officials
reported that the increased monitoring has helped some local officials
in their state identify the sources of contamination. These officials
identified the following examples of localities where contamination
sources have been identified and, in some cases, local actions have
been taken to address them:
* Illinois--Beach monitoring led officials at one beach in Chicago to
identify a sewer break, prompting the city to fix the leaking sewer and
remove 6 million cubic yards of sand.
* Michigan--In Traverse City, local officials have used monitoring data
to identify problems at their wastewater treatment plants which
resulted in plant improvements.
* Ohio--The Lucas County Health Department has identified private
sewage systems that are contaminating local beaches.
* Minnesota--With the establishment of the state's beach program
following the BEACH Act, state and local officials in Minnesota formed
a beach committee that includes representation from the state pollution
control agency, local and state health departments, local sewage
districts and utilities, University of Minnesota researchers, and other
groups. The beach committee has coordinated efforts to identify the
sources and causes of beach contamination. For example, where beach
monitoring data has indicated problems at normally clean beaches, the
sanitary district has investigated these situations and found and
repaired broken pipes.
* Wisconsin--Officials in Racine began looking into high numbers of
beach closures and advisories at one of their beaches in 1999. Using
the results of water quality monitoring, these officials were able to
identify a storm water outfall adjacent to the beach that was
contributing to the contamination and developed an underground
treatment system and wetland area to filter the discharge. In addition,
city officials determined that beach grooming procedures and the
overall geography of the beach were also contributing to the
contamination, and they improved their beach grooming techniques and
regraded the beach to reduce standing water. With these corrective
actions, the city was able to reduce the number of beach health
advisory and closure days from 62 in 2000 to 3 in 2006. Figure 10
illustrates the changes to the city's beach grooming processes.
Figure 10: Changes to Beach Grooming Process at a Racine, Wisconsin,
Beach:
[See PDF for image]
Source: Dr. Julie Kinzelman, City of Racine Health Department
Laboratory.
[End of figure]
In addition to these efforts to identify and address local sources of
contamination, local officials report an overall increase in awareness
of how personal actions can impact water quality at beaches, as shown
in figure 11. For example, not adhering to proper beach practices--such
as using swim diapers for young children--or not properly disposing of
trash can lead to increased problems with wildlife such as seagulls and
geese. In addition to actions that the public can take to mitigate
contamination, there are also actions beach managers can take, such as
ensuring the availability of sufficient trash cans and functioning
restrooms, that can also help mitigate beach contamination. Local
officials report that they have taken some of these actions on a
limited basis.
Figure 11: Estimated Change in Public Awareness of Personal Actions on
Water Quality at Great Lakes Beaches Since Passage of the BEACH Act:
[See PDF for image]
Source: Responses to GAO's survey of monitored beaches in the Great
Lakes.
[End of figure]
Nevertheless, EPA officials stated that the primary source of
contamination at beaches generally is reported by state officials as
"unknown." Comprehensive sanitary surveys can help local water program
managers identify persistent problems; ascertain the sources and
magnitude of contamination; suggest appropriate actions to control
contamination and identify priority locations for sampling.[Footnote
21] Although local officials at Great Lakes beaches reported conducting
field observations to determine the sources of contamination at 88
percent of the beaches, comprehensive sanitary surveys have been
conducted at only 48 percent of the beaches.
One reason why sanitary surveys have not been more widespread is lack
of funding, but EPA has concluded that BEACH Act grant funds can only
be used for this purpose under certain circumstances.[Footnote 22] In
particular, sanitary surveys can be done during the development of a
monitoring program when states are prioritizing their beaches for
monitoring or when there is a need to reprioritize the beaches. EPA has
initiated a pilot sanitary survey effort throughout the Great Lakes,
working with state and county Great Lakes beach managers to design and
implement a beach sanitary survey project for Great Lakes recreational
waters. EPA posted a Request for Proposal in August 2006 indicating
that $500,000 would be available to fund pilot surveys at Great Lakes
beaches. Nine state or county agencies submitted proposals for
conducting sanitary surveys at numerous beaches. EPA expects that this
work will result in the development of a tool for watershed-based
sanitary surveys that could be used by others. EPA made award decisions
in December 2006 and anticipates grant awards in April 2007.
Because state and local officials do not have enough information on the
specific sources of contamination and generally lack funds for
remediation, most of the sources of contamination at Great Lakes'
beaches have not been addressed. Local officials indicated that actions
to address the sources of contamination had only been taken at an
estimated 14 percent of the monitored beaches. While none of the eight
Great Lakes state officials suggested that the BEACH Act was intended
to help remediate the sources of contamination, some said that they
lack the funds needed to mitigate the sources of contamination that
increased monitoring has helped to identify. However, our review of the
BEACH Act and EPA's criteria found that they both specify that BEACH
Act grant funds should be used only for monitoring and notification
purposes. Several state officials believe that it may be more useful to
use BEACH Act grants to identify and remediate sources of contamination
rather than just continue to monitor water quality. Local officials
also reported a need for funding to identify and address sources of
contamination. Furthermore, at EPA's National Beaches Conference in
October 2006, a panel of federal and academic researches recommended
that EPA provide the states with more freedom on how they may spend
their BEACH Act funding.
According to state and local officials, as well as other Great Lakes
stakeholders, an overall improvement in water quality throughout the
Great Lakes will require a substantial effort directed toward both
large-scale initiatives and localized actions to address the underlying
causes of contamination. State officials reported that combined sewer
overflows and sewage disposal problems throughout the Great Lakes must
be addressed. Although some communities have taken steps in this
direction, others continue to discharge partially treated wastewater
into the Great Lakes as part of their wastewater treatment processes.
In addition, more localized action is also needed to address some
sources of contamination at Great Lakes beaches. Examples include
regrading the beaches to reduce standing water and minimizing the use
of impervious surface materials to construct parking lots adjacent to
beaches to reduce storm water runoff.
Conclusions:
EPA has made progress in implementing many of the BEACH Act's
requirements but two critical actions, relating to the completion of
pathogen studies and developing new water quality criteria, have not
been completed as required by the act and may not be completed for
several more years. Without the completion of these studies and the
development of new water quality criteria, states will have to continue
to use existing methods that are already outdated for monitoring water
quality at their beaches. The use of these methods limits states'
ability to obtain water quality test results and make beach closing
decisions in a timely manner to ensure that public health is adequately
protected. However, EPA has not established a firm time line to guide
the completion of the studies and the development of the new criteria,
so it is unclear when states can expect to receive updated methods to
guide their monitoring efforts.
In addition, although EPA developed a formula to distribute BEACH Act
grants to the states, this formula was based on the assumption that the
program would receive its fully authorized allocation of $30 million.
During the last 5 years, the program has not received full funding, and
EPA has not adjusted the formula to reflect the impacts of reduced
levels of funding. As a result, the current distribution formula fails
to adequately take into account the monitoring needs of the states.
Instead, it places the greatest emphasis on the length of the beach
season and not enough emphasis on other factors, such as beach use and
beach miles, that vary greatly across states, and which also impact the
public health risk and significantly influence the level of monitoring
that states need to undertake. While we recognize that any changes to
the distribution formula would inevitably result in some states
receiving more funds and some less, unless the program is fully funded
as authorized, the current distribution formula does not reflect the
states' varied monitoring needs.
Finally, the BEACH Act has had a significant impact in helping the
Great Lakes states increase their level of monitoring, which in turn
has increased their knowledge about the scope of contamination at area
beaches. However, the variability in how the states are conducting
their monitoring and how they are using their monitoring results to
notify the public have raised concerns about the adequacy of protection
provided among and across Great Lakes states. In addition, because it
appears that BEACH Act funds cannot currently be used to investigate
the source of contamination or remediate an identified problem, states
have been unable to address the contamination that they now know
exists. While we recognize that funding for BEACH Act grants has been
limited over the last 5 years, we believe that additional flexibility
for the states to use a portion of their BEACH Act grants to help them
identify the source of contamination if their monitoring has identified
a reoccurring problem would be helpful. In this regard, we also believe
that EPA could provide guidance to ensure that states are still
conducting the monitoring programs expected by the BEACH Act and not
diverting all their monitoring funds to investigation and mitigation.
Matter for Congressional Consideration:
As it considers reauthorization of the BEACH Act, Congress should
consider providing EPA some flexibility in awarding BEACH Act grants to
allow states to undertake limited research to identify specific sources
of contamination at monitored beaches and certain actions to mitigate
these problems, as specified by EPA.
Recommendations for Executive Action:
To ensure that EPA complies with the requirements laid out in the BEACH
Act, we recommend that the Administrator of EPA take the following
three actions:
* Establish a definitive time line for completing the studies on
pathogens and their effects on human health, and for publishing new or
revised water quality criteria for pathogens and pathogen indicators;
* If current funding levels remain the same, revise the formula for
distributing BEACH Act grants to better reflect the states' varied
monitoring needs by reevaluating the formula factors to determine if
the weight of the beach season factor should be reduced and if the
weight of the other factors, such as beach use and beach miles should
be increased; and:
* To better ensure consistent levels of public health protection, EPA
should provide states and localities with specific guidance on
monitoring frequency and methods and public notification.
Agency Comments and Our Evaluation:
In commenting on the draft report, EPA generally agreed with GAO's
recommendations and agreed to (1) take actions to establish an action
plan and a definitive time frame to complete studies and publish
revised water quality standards and (2) revise its guidance to states.
With respect to our recommendation to revise the current funding
formula to better reflect states' needs, EPA agreed with this
recommendation, but stated that the states were reluctant to make any
substantial changes to the formula and were supportive of EPA's plan to
make only minor changes to the formula. EPA's comments are included in
appendix IV.
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 to the EPA
Administrator and other interested parties. We will also 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 about this report, please
contact me at (202) 512-3841 or mittala@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix V.
Signed by:
Anu K. Mittal:
Director, Natural Resources and Environment:
List of Requesters:
The Honorable Evan Bayh:
United States Senate:
The Honorable Richard Durbin:
United States Senate:
The Honorable Russell D. Feingold:
United States Senate:
The Honorable Carl Levin:
United States Senate:
The Honorable Richard Lugar:
United States Senate:
The Honorable Barack Obama:
United States Senate:
The Honorable Debbie Stabenow:
United States Senate:
The Honorable George Voinovich:
United States Senate:
The Honorable John Dingell:
House of Representatives:
The Honorable Rahm Emanuel:
House of Representatives:
The Honorable Luis V. Gutierrez:
House of Representatives:
The Honorable Brian M. Higgins:
House of Representatives:
The Honorable Dale Kildee:
House of Representatives:
The Honorable Carolyn C. Kilpatrick:
House of Representatives:
The Honorable Mark Kirk:
House of Representatives:
The Honorable Dennis Kucinich:
House of Representatives:
The Honorable Sander M. Levin:
House of Representatives:
The Honorable Janice Schakowsky:
House of Representatives:
The Honorable Louise Slaughter:
House of Representatives:
The Honorable Bart Stupak:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
The objectives of this review were to (1) determine the extent to which
the Environmental Protection Agency (EPA) has implemented the Beaches
Environmental Assessment and Coastal Health (BEACH) Act of 2000 and
evaluate EPA's formula for allocating BEACH Act grants, (2) describe
and evaluate the monitoring and notification programs the eight Great
Lakes states have developed using BEACH Act grants, and (3) determine
the effect that the BEACH Act has had on water quality monitoring and
contamination at Great Lakes beaches.
We identified and analyzed applicable laws, regulations, policies, and
procedures to determine what actions EPA has taken to implement the act
and what remains to be addressed. Specifically, we reviewed the act to
identify what actions the agency was required to take. To identify the
actions EPA has taken to implement the act's requirements and
provisions, we reviewed notices and regulations published in the
Federal Register and agency documents, and interviewed agency officials
at EPA headquarters, EPA's Great Lakes National Program Office, EPA
Region 5 (Chicago), EPA Region 2 (New York), and EPA's National
Exposure Research Laboratory. To assess the criteria EPA uses to
allocate BEACH Act funds to eligible states, we interviewed officials
that were involved in developing the funding formula and conducted a
funding formula simulation to demonstrate how slight alterations of the
BEACH Act grant funding formula would shift funding and potentially
affect current allocations.
To determine how the eight Great Lakes states have used BEACH Act funds
to develop monitoring and notification programs, we used a data
collection instrument to gather information from state level BEACH Act
Administrators from each of the Great Lakes states--Illinois, Indiana,
Ohio, Michigan, Minnesota, New York, Wisconsin, and Pennsylvania. We
interviewed an official from Erie County, Pennsylvania, where BEACH Act
funds are distributed directly to the county because this is the only
county in the state with coastal recreational waters. EPA identified
these officials as the person(s) responsible for coordinating beach
monitoring and notification programs for each state and collecting and
submitting information generated by these programs to EPA.
In addition, we conducted a survey of the 563 Great Lakes beaches EPA
identified as having monitoring programs in 2005. To gather data
representative of the Great Lakes beaches, we conducted a random sample
of 140 beaches which were selected systematically for each state. This
ensured that the sample selected was proportional to the number of
Great Lakes beaches in each of the states. Table 7 summarizes sample
size and disposition by state.
Table 7: Great Lakes Beaches Reported Monitored by EPA in 2005, GAO
Sample, and Sample Disposition by State:
State: Illinois;
Total beaches monitored: 73;
Sample beaches: 19;
Responding beaches: 15;
Response rate: 79%.
State: Indiana;
Total beaches monitored: 25;
Sample beaches: 6;
Responding beaches: 5;
Response rate: 83.
State: Michigan;
Total beaches monitored: 214;
Sample beaches: 53;
Responding beaches: 49;
Response rate: 92.
State: Minnesota;
Total beaches monitored: 39;
Sample beaches: 10;
Responding beaches: 10;
Response rate: 100.
State: New York;
Total beaches monitored: 38;
Sample beaches: 9;
Responding beaches: 9;
Response rate: 100.
State: Ohio;
Total beaches monitored: 47;
Sample beaches: 12;
Responding beaches: 11;
Response rate: 92.
State: Pennsylvania;
Total beaches monitored: 12;
Sample beaches: 3;
Responding beaches: 3;
Response rate: 100.
State: Wisconsin;
Total beaches monitored: 115;
Sample beaches: 28;
Responding beaches: 28;
Response rate: 100.
State: Grand total;
Total beaches monitored: 563;
Sample beaches: 140;
Responding beaches: 130;
Response rate: 93%.
Source: GAO.
[End of table]
Information obtained through this survey was used to produce estimates
of beach monitoring and notification in the 2006 beach season at the
Great Lakes beaches that conducted monitoring in 2005. Since our beach
sample is only one of a large number of samples that we might have
drawn, and each sample could have provided different estimates, we
express our confidence in the precision of our particular sample's
results as a 95 percent confidence interval. This is the interval that
would contain the actual population value for 95 percent of the samples
we could have drawn. All proportion estimates from this sample used in
this report have 95 percent confidence intervals within plus or minus
10 percentage points, unless otherwise noted.
Even though we surveyed a random sample of beaches in the Great Lakes,
the practical difficulties of conducting any survey may introduce other
types of errors, commonly referred to as "nonsampling errors." For
example, differences in how a particular question is interpreted or the
sources of information available to respondents can introduce unwanted
variability into the survey results. We included steps in both the data
collection and data analysis stages to minimize these nonsampling
errors. For example, in the research design and data collection stages,
we took the following steps:
* We obtained from EPA a list of contacts for beaches with monitoring
programs in the Great Lakes. We then attempted to contact all listed
local officials via telephone and asked them to tell us if they or
someone else would be the most appropriate contact and to provide their
e-mail address. Some officials identified more appropriate survey
respondents. In order to obtain the appropriate contacts for beaches
where we were not able to contact the officials using EPA's list, we
asked state BEACH Act officials for the most appropriate contact and
obtained telephone and/or e-mail contacts from them.
* We reviewed EPA's National Health Protection Survey of Beaches.
* We pretested the survey with officials from four beaches between
November 13, 2006, and November 27, 2006, and used their feedback to
refine the survey. These beaches were selected randomly from the list
of monitored beaches provided by EPA. For these pretests, we sent
officials a draft of the survey. We then interviewed the officials to
ensure that (1) questions were clear and unambiguous, (2) terms were
precise, and (3) data needed to respond to the questions were available
to the local officials. As a result of our pretests, we refined some of
the survey questions. A GAO survey specialist also independently
reviewed the questionnaire.
* We e-mailed the survey as an attachment on December 5, 2006, to local
officials at 140 beaches. We asked respondents to return the survey by
e-mail within 15 working days of receiving our e-mail. We sent e-mail
reminders and called nonrespondents and accepted responses to the
surveys through February 2, 2007.
To minimize nonsampling errors in the data analysis stage, we contacted
local officials to clarify survey responses, when necessary, and used a
centralized tracking document to record all changes. Changes made in
the tracking document were verified against the keypunched data to
ensure all changes and updates were recorded. When changes took place
after a survey was keypunched, the updates were made in the computer
program used to generate survey results.
As summarized in table 7, we received completed questionnaires for 130
of the 140 sample beaches, for an overall response rate of 93 percent.
We did not receive a completed questionnaire from 10 beaches. We do not
know if the responses for these beaches would have differed materially
from those for the 130 beaches we did receive. From the questionnaires
we received, we gathered information for each including: (1) the
potential sources of contamination; (2) water quality standards in
place; (3) methods of monitoring, including depth and location of
samples; (4) frequency of monitoring and number of sampling days where
water quality standards were exceeded; and (5) public notification and
remediation efforts.
To determine the effect the BEACH Act has had on Great Lakes beach
monitoring and the identification of sources of contamination, we
analyzed the results of our survey and information obtained from state
BEACH Act Administrators. In addition, we reviewed EPA data on the
number of beaches identified in the Great Lakes, the number of
identified beaches being monitored, and the number of monitored beaches
with health advisories and beach closures. We interviewed agency
officials regarding a series of data reliability questions addressing
such areas as data entry, data access, quality control procedures, and
data accuracy and completeness. We asked follow-up questions whenever
necessary. We determined that these data were sufficiently reliable for
the purposes of this report.
Finally, we conducted interviews with organizations working on Great
Lakes issues including the National Oceanic and Atmospheric
Administration (NOAA), the U.S. Geological Survey, the Natural
Resources Defense Council, the International Joint Commission, the
Alliance for the Great Lakes, and the Northeast-Midwest Institute Great
Lakes and St. Lawrence Cities Initiative, among others.
We conducted our work from June 2006 through March 2007 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: Map of 35 States and Territories with Coastal Recreational
Waters:
[See PDF for Image]
Source: Map Resources (map) and EPA Office of water.
[End of figure]
[End of section]
Appendix III: GAO's Calculations for an Alternative BEACH Act Grant
Distribution Formula:
This appendix describes EPA's BEACH Act grant distribution formula and
the results of our calculation using an alternative formula allocation.
Currently, EPA's grant formula allocates about 82 percent of the grant
funds according to beach season and about 9 percent each to beach use
and beach miles. Our simulation reweighs the factors used in EPA's
formula so that beach season receives a weight of about 27 percent,
beach use receives a weight of about 36 percent, and beach miles
receive a weight of about 36 percent as EPA originally intended. The
resulting funding amounts are shown for each of the 35 states and
territories. Finally, we present information on how EPA can alter its
formula to minimize fluctuations in funding amounts if funding levels
increase.
EPA's BEACH Act Grant Distribution Formula:
EPA distributes BEACH Act grants to eligible states and territories
according to a formula that considers the length of the beach season,
beach use, and beach miles. EPA intended that the beach season length
factor would provide the base funding and would be augmented by the
beach use and beach miles factors. EPA established a series of fixed
amounts that correspond to states' varying lengths of beach season to
cover the general expenses associated with a beach monitoring program.
For example, EPA estimated that a 3-month beach season would require
states to fund salaries for two employees, which would cost
approximately $150,000, while states with beach seasons greater than 6-
months would require $300,000. The eight Great Lakes states are all
classified as having 3 to 4 months of beach season, as shown in table
8.
Table 8: EPA Beach Season Length Factor and States Associated Funding
Levels:
State: Alaska;
Beach season: <3 months[A];
Base amount: $150,000.
State: Connecticut, Delaware, Illinois, Indiana, Maine, Maryland,
Massachusetts, Michigan, Minnesota, New Hampshire, New Jersey, New
York, Ohio, Oregon, Pennsylvania, Rhode Island, Virginia, Washington,
Wisconsin;
Beach season: 3-4 months;
Base amount: $200,000.
State: Alabama, Georgia, Louisiana, Mississippi, North Carolina, South
Carolina;
Beach season: 5-6 months;
Base amount: $250,000.
State: American Samoa, California, Florida, Guam, Hawaii, Northern
Mariana, Puerto Rico, Texas, U.S. Virgin Islands;
Beach season: >6 months;
Base amount: $300,000.
Source: EPA.
[A] States and territories with seasons of less than 3 months receive
season-based funding only.
[End of table]
Once the allotments for beach season length are distributed, EPA
determined that 50 percent of the remaining funds would be distributed
to states according to beach use, and the other 50 percent would be
distributed according to states' beach miles. Because consistent data
across states on beach usage are not available, EPA uses coastal
population of counties as a surrogate for beach use. Similarly, EPA
currently does not have beach mileage data in a format that can be used
for the allocation formula and, therefore, uses shoreline miles as a
surrogate for beach miles.[Footnote 23]
EPA developed this formula with the expectation that BEACH Act grants
would be allocated funding at their authorized level of $30 million
annually. Using this authorized amount and EPA's distribution formula
$30 million and using this distribution formula, each factor would have
received approximately equal weight, with beach season accounting for
about 27 percent of each state or territory's grant, and the remainder
equally divided between the two other factors--beach use (36 percent)
and beach miles (36 percent) as shown in table 9.
Table 9: EPA's Formula for Distributing $30 Million in BEACH Act
Grants:
Factor: Beach season length;
Allocation: 27% of total annual BEACH Act funds, or $8 million,
distributed as follows:
< 3 months: $150,000[A];
3-4 months: $200,000;
5-6 months: $250,000;
>6 months: $300,000.
Factor: Shoreline miles;
Allocation: 36% of total annual BEACH Act funds, or $11 million.
Factor: Coastal population;
Allocation: 36% of total annual BEACH Act funds, or $11 million.
Sources: EPA and GAO.
[A] States and territories with seasons of less than 3 months receive
season-based funding only.
[End of table]
However, since 2002, funding levels for BEACH Act grants have been
about $10 million each year. Given the lower than anticipated funding
levels, once the approximately $8 million (which now accounts for 82
percent of the total grant funding) was allocated in accordance with
each state's beach season, this left only about $1.85 million or about
18 percent of the total funding to be divided equally (about $1 million
or 9 percent each) between the beach use and beach miles factors, as
shown in table 10.
Table 10: EPA's Formula for Distributing $10 Million in BEACH Act
Grants:
Factor: Beach season length;
Allocation:
< 3 months: $150,000[A];
3-4 months: $200,000;
5-6 months: $250,000;
>6 months: $300,000.
Factor: Shoreline miles;
Allocation: 50% of remaining $1.85 million funds, or $.92 million.
Factor: Coastal population;
Allocation: 50% of remaining $1.85 million funds, or $.92 million.
Sources: EPA and GAO.
[A] States and territories with seasons of less than 3 months receive
season-based funding only.
[End of table]
Because the beach season factor accounts for a much larger proportion
of each state's BEACH Act grant as compared with beach miles or beach
use, BEACH Act grant amounts may vary little between states that have
widely varied shorelines or coastal populations, as shown in table 11.
Table 11: Factors Used in BEACH Act Formula Allocations and Resulting
2006 Grants by State and Territory:
State: Alabama;
Beach season length: 6;
Minimum allocation: $250,000;
Shoreline miles: 607;
Shoreline ratio: 0.0099;
Coastal population (2000): 540,258;
Population ratio: 0.0044;
Grant allocation in 2006: $262,170.
State: Alaska;
Beach season length: 2;
Minimum allocation: 150,000;
Shoreline miles: 33,904;
Shoreline ratio: 0.0000;
Coastal population (2000): 538,258;
Population ratio: 0.0000;
Grant allocation in 2006: 150,000.
State: American Samoa;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 126;
Shoreline ratio: 0.0020;
Coastal population (2000): 57,291;
Population ratio: 0.0005;
Grant allocation in 2006: 302,140.
State: California;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 3,427;
Shoreline ratio: 0.0557;
Coastal population (2000): 24,260,099;
Population ratio: 0.1991;
Grant allocation in 2006: 516,960.
State: Connecticut;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 618;
Shoreline ratio: 0.0100;
Coastal population (2000): 2,120,734;
Population ratio: 0.0174;
Grant allocation in 2006: 223,370.
State: Delaware;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 381;
Shoreline ratio: 0.0062;
Coastal population (2000): 783,600;
Population ratio: 0.0064;
Grant allocation in 2006: 210,750.
State: Florida;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 8,436;
Shoreline ratio: 0.1371;
Coastal population (2000): 15,982,378;
Population ratio: 0.1311;
Grant allocation in 2006: 528,410.
State: Georgia;
Beach season length: 6;
Minimum allocation: 250,000;
Shoreline miles: 2,344;
Shoreline ratio: 0.0381;
Coastal population (2000): 538,469;
Population ratio: 0.0044;
Grant allocation in 2006: 286,200.
State: Guam;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 110;
Shoreline ratio: 0.0018;
Coastal population (2000): 154,805;
Population ratio: 0.0013;
Grant allocation in 2006: 302,600.
State: Hawaii;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 1,052;
Shoreline ratio: 0.0171;
Coastal population (2000): 1,211,537;
Population ratio: 0.0099;
Grant allocation in 2006: 323,020.
State: Illinois;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 63;
Shoreline ratio: 0.0010;
Coastal population (2000): 6,021,097;
Population ratio: 0.0494;
Grant allocation in 2006: 242,940.
State: Indiana;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 45;
Shoreline ratio: 0.0007;
Coastal population (2000): 741,468;
Population ratio: 0.0061;
Grant allocation in 2006: 205,800.
State: Louisiana;
Beach season length: 6;
Minimum allocation: 250,000;
Shoreline miles: 7,721;
Shoreline ratio: 0.1255;
Coastal population (2000): 2,170,717;
Population ratio: 0.0178;
Grant allocation in 2006: 322,010.
State: Maine;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 3,478;
Shoreline ratio: 0.0565;
Coastal population (2000): 944,847;
Population ratio: 0.0078;
Grant allocation in 2006: 254,730.
State: Maryland;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 3,190;
Shoreline ratio: 0.0518;
Coastal population (2000): 3,592,430;
Population ratio: 0.0295;
Grant allocation in 2006: 269,250.
State: Massachusetts;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 1,519;
Shoreline ratio: 0.0247;
Coastal population (2000): 4,783,167;
Population ratio: 0.0392;
Grant allocation in 2006: 254,440.
State: Michigan;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 3,224;
Shoreline ratio: 0.0524;
Coastal population (2000): 4,842,023;
Population ratio: 0.0397;
Grant allocation in 2006: 278,450.
State: Minnesota;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 189;
Shoreline ratio: 0.0031;
Coastal population (2000): 236,946;
Population ratio: 0.0019;
Grant allocation in 2006: 204,270.
State: Mississippi;
Beach season length: 6;
Minimum allocation: 250,000;
Shoreline miles: 359;
Shoreline ratio: 0.0058;
Coastal population (2000): 363,988;
Population ratio: 0.0030;
Grant allocation in 2006: 257,510.
State: New Hampshire;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 131;
Shoreline ratio: 0.0021;
Coastal population (2000): 389,592;
Population ratio: 0.0032;
Grant allocation in 2006: 204,530.
State: New Jersey;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 1,792;
Shoreline ratio: 0.0291;
Coastal population (2000): 7,575,546;
Population ratio: 0.0622;
Grant allocation in 2006: 277,730.
State: New York;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 2,625;
Shoreline ratio: 0.0427;
Coastal population (2000): 16,088,089;
Population ratio: 0.1320;
Grant allocation in 2006: 348,740.
State: North Carolina;
Beach season length: 6;
Minimum allocation: 250,000;
Shoreline miles: 3,375;
Shoreline ratio: 0.0548;
Coastal population (2000): 826,019;
Population ratio: 0.0068;
Grant allocation in 2006: 302,480.
State: Northern Mariana Islands;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 206;
Shoreline ratio: 0.0033;
Coastal population (2000): 69,221;
Population ratio: 0.0006;
Grant allocation in 2006: 303,330.
State: Ohio;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 312;
Shoreline ratio: 0.0051;
Coastal population (2000): 2,767,328;
Population ratio: 0.0227;
Grant allocation in 2006: 223,650.
State: Oregon;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 1,410;
Shoreline ratio: 0.0229;
Coastal population (2000): 1,326,072;
Population ratio: 0.0109;
Grant allocation in 2006: 228,780.
State: Pennsylvania;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 140;
Shoreline ratio: 0.0023;
Coastal population (2000): 2,946,892;
Population ratio: 0.0242;
Grant allocation in 2006: 222,530.
State: Puerto Rico;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 700;
Shoreline ratio: 0.0114;
Coastal population (2000): 2,685,883;
Population ratio: 0.0220;
Grant allocation in 2006: 328,450.
State: Rhode Island;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 384;
Shoreline ratio: 0.0062;
Coastal population (2000): 1,048,319;
Population ratio: 0.0086;
Grant allocation in 2006: 212,640.
State: South Carolina;
Beach season length: 6;
Minimum allocation: 250,000;
Shoreline miles: 2,876;
Shoreline ratio: 0.0467;
Coastal population (2000): 981,338;
Population ratio: 0.0081;
Grant allocation in 2006: 296,660.
State: Texas;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 3,359;
Shoreline ratio: 0.0546;
Coastal population (2000): 5,211,014;
Population ratio: 0.0428;
Grant allocation in 2006: 382,890.
State: Virgin Islands;
Beach season length: 12;
Minimum allocation: 300,000;
Shoreline miles: 175;
Shoreline ratio: 0.0028;
Coastal population (2000): 108,612;
Population ratio: 0.0009;
Grant allocation in 2006: 303,180.
State: Virginia;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 3,315;
Shoreline ratio: 0.0539;
Coastal population (2000): 4,440,709;
Population ratio: 0.0364;
Grant allocation in 2006: 276,900.
State: Washington;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 3,026;
Shoreline ratio: 0.0492;
Coastal population (2000): 4,070,515;
Population ratio: 0.0334;
Grant allocation in 2006: 270,320.
State: Wisconsin;
Beach season length: 4;
Minimum allocation: 200,000;
Shoreline miles: 820;
Shoreline ratio: 0.0133;
Coastal population (2000): 1,992,393;
Population ratio: 0.0163;
Grant allocation in 2006: 225,270.
State: Total;
Beach season length: 220;
Minimum allocation: $8,150,000;
Shoreline miles: 61,535;
Shoreline ratio: 1.0000;
Coastal population (2000): 121,873,396;
Population ratio: 1.0000;
Grant allocation in 2006: $9,803,100.
Sources: EPA and GAO.
Note: The totals exclude shoreline miles and coastal population for
Alaska because Alaska beach season is less than 3 months.
[End of table]
As a result, states and territories with 12-month beach seasons may
receive larger BEACH Act grants than states with much longer
shorelines. For example, shoreline miles in the Great Lakes states
range from 63 miles in Illinois to 3,224 in Michigan; therefore,
Michigan may need to monitor 50 times as many shoreline miles as
Illinois. However, because the beach miles factor accounts for a much
smaller portion of each state's BEACH Act grant than beach season, the
BEACH Act grant amount distributed to Michigan is only 35 percent more
than that for Indiana ($278,450 and $205,800, respectively).
Because of the way in which the current formula allocates funding,
states and territories with 12-month beach seasons may also receive
larger BEACH Act grants than more populous states. For example, in
general, EPA's grant distribution formula gives territories an
advantage over the states, because they tend to be in warmer climates
with longer beach seasons. Territories receive an average of $309,000
each year, while states receive an annual average of $294,000. The
Great Lakes states, with their comparatively short beach seasons,
receive an annual average of $248,000. Similarly, states with larger
populations are currently at a disadvantage to the territories that
have a longer beach season but significantly smaller coastal
populations. For example Guam and American Samoa, with coastal
populations of less than 200,000 each, receive larger grants than
Maryland and Virginia, with coastal populations of 3.6 and 4.4 million,
respectively. However, if greater weights were assigned to coastal
populations, Maryland and Virginia would see an increase in their grant
allocation.
Simulations of Alternative BEACH Act Distribution Formulas:
We calculated the distribution of $10 million in annual BEACH Act
grants according to an alternative formula that weights each of the
factors equally (27 percent for beach season, 36 percent for beach use,
and 36 percent for beach miles) in accordance with the weights that EPA
had built into its formula when it anticipated that $30 million would
be available in annual funding levels. For the purposes of our
calculation, we reduced the total amount available to be allocated to
beach season length from 82 to 27.2 percent of the current $10 million
funding levels. Given this simulation, the total amount allocated on
the basis of beach season length falls from $8.15 million to roughly
$2.72 million, and the proportion allocated to beach use and beach
miles increases to $3.65 million (or 36.4 percent) each.
Under this alternative formula, Alabama's total allocation, for
example, would decrease by 48.6 percent, from $263,225 to $135,399, and
its share of funding that is based on the length of the beach season
would fall from $250,000 to $83,333. Table 12 shows how each state and
territory's allocations would differ if EPA applied the percentages it
built into its formula when it anticipated $30 million in funding
compared with the current $10 million.
Table 12: Difference in Allocations Using Current and Alternative
Formulas:
States and territories: Alabama;
BEACH Act grant allocation of $10 million: $263,225;
Amount based on beach season: $250,000;
27.2% of amount based on beach season: $83,333;
Estimated BEACH Act grant under simulated formula: $135,399;
Difference between actual and estimated allocations (in dollars): -
$127,826;
Difference between actual and estimated allocations: -48.6%.
States and territories: Alaska;
BEACH Act grant allocation of $10 million: 150,000;
Amount based on beach season: 150,000;
27.2% of amount based on beach season: 50,000;
Estimated BEACH Act grant under simulated formula: 50,000;
Difference between actual and estimated allocations (in dollars): -
100,000;
Difference between actual and estimated allocations: -66.7.
States and territories: American Samoa;
BEACH Act grant allocation of $10 million: 302,329;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 109,169;
Difference between actual and estimated allocations (in dollars): -
193,160;
Difference between actual and estimated allocations: -63.9.
States and territories: California;
BEACH Act grant allocation of $10 million: 535,645;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 1,027,721;
Difference between actual and estimated allocations (in dollars):
492,076;
Difference between actual and estimated allocations: 91.9.
States and territories: Connecticut;
BEACH Act grant allocation of $10 million: 225,386;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 166,609;
Difference between actual and estimated allocations (in dollars): -
58,777;
Difference between actual and estimated allocations: -26.1.
States and territories: Delaware;
BEACH Act grant allocation of $10 million: 211,675;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 112,629;
Difference between actual and estimated allocations (in dollars): -
99,046;
Difference between actual and estimated allocations: -46.8.
States and territories: Florida;
BEACH Act grant allocation of $10 million: 548,115;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 1,076,811;
Difference between actual and estimated allocations (in dollars):
528,696;
Difference between actual and estimated allocations: 96.5.
States and territories: Georgia;
BEACH Act grant allocation of $10 million: 289,322;
Amount based on beach season: 250,000;
27.2% of amount based on beach season: 83,333;
Estimated BEACH Act grant under simulated formula: 238,142;
Difference between actual and estimated allocations (in dollars): -
51,180;
Difference between actual and estimated allocations: -17.7.
States and territories: Guam;
BEACH Act grant allocation of $10 million: 302,828;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 111,136;
Difference between actual and estimated allocations (in dollars): -
191,692;
Difference between actual and estimated allocations: -63.3.
States and territories: Hawaii;
BEACH Act grant allocation of $10 million: 325,009;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 198,459;
Difference between actual and estimated allocations (in dollars): -
126,550;
Difference between actual and estimated allocations: -38.9.
States and territories: Illinois;
BEACH Act grant allocation of $10 million: 246,646;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 250,310;
Difference between actual and estimated allocations (in dollars):
3,664;
Difference between actual and estimated allocations: 1.5.
States and territories: Indiana;
BEACH Act grant allocation of $10 million: 206,304;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 91,485;
Difference between actual and estimated allocations (in dollars): -
114,819;
Difference between actual and estimated allocations: -55.7.
States and territories: Louisiana;
BEACH Act grant allocation of $10 million: 382,538;
Amount based on beach season: 250,000;
27.2% of amount based on beach season: 83,333;
Estimated BEACH Act grant under simulated formula: 605,128;
Difference between actual and estimated allocations (in dollars):
222,590;
Difference between actual and estimated allocations: 58.2.
States and territories: Maine;
BEACH Act grant allocation of $10 million: 259,453;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 300,729;
Difference between actual and estimated allocations (in dollars):
41,276;
Difference between actual and estimated allocations: 15.9.
States and territories: Maryland;
BEACH Act grant allocation of $10 million: 275,218;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 362,797;
Difference between actual and estimated allocations (in dollars):
87,579;
Difference between actual and estimated allocations: 31.8.
States and territories: Massachusetts;
BEACH Act grant allocation of $10 million: 259,137;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 299,486;
Difference between actual and estimated allocations (in dollars):
40,349;
Difference between actual and estimated allocations: 15.6.
States and territories: Michigan;
BEACH Act grant allocation of $10 million: 285,214;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 402,148;
Difference between actual and estimated allocations (in dollars):
116,934;
Difference between actual and estimated allocations: 41.0.
States and territories: Minnesota;
BEACH Act grant allocation of $10 million: 204,639;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 84,932;
Difference between actual and estimated allocations (in dollars): -
119,707;
Difference between actual and estimated allocations: -58.5.
States and territories: Mississippi;
BEACH Act grant allocation of $10 million: 258,159;
Amount based on beach season: 250,000;
27.2% of amount based on beach season: 83,333;
Estimated BEACH Act grant under simulated formula: 115,455;
Difference between actual and estimated allocations (in dollars): -
142,704;
Difference between actual and estimated allocations: -55.3.
States and territories: New Hampshire;
BEACH Act grant allocation of $10 million: 204,926;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 86,061;
Difference between actual and estimated allocations (in dollars): -
118,865;
Difference between actual and estimated allocations: -58.0.
States and territories: New Jersey;
BEACH Act grant allocation of $10 million: 284,435;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 399,081;
Difference between actual and estimated allocations (in dollars):
114,646;
Difference between actual and estimated allocations: 40.3.
States and territories: New York;
BEACH Act grant allocation of $10 million: 361,565;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 702,739;
Difference between actual and estimated allocations (in dollars):
341,174;
Difference between actual and estimated allocations: 94.4.
States and territories: North Carolina;
BEACH Act grant allocation of $10 million: 307,003;
Amount based on beach season: 250,000;
27.2% of amount based on beach season: 83,333;
Estimated BEACH Act grant under simulated formula: 307,749;
Difference between actual and estimated allocations (in dollars): 746;
Difference between actual and estimated allocations: 0.2.
States and territories: Northern Mariana Islands;
BEACH Act grant allocation of $10 million: 303,622;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 114,260;
Difference between actual and estimated allocations (in dollars): -
189,362;
Difference between actual and estimated allocations: -62.4.
States and territories: Ohio;
BEACH Act grant allocation of $10 million: 225,694;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 167,821;
Difference between actual and estimated allocations (in dollars): -
57,873;
Difference between actual and estimated allocations: -25.6.
States and territories: Oregon;
BEACH Act grant allocation of $10 million: 231,260;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 189,735;
Difference between actual and estimated allocations (in dollars): -
41,525;
Difference between actual and estimated allocations: -18.0.
States and territories: Pennsylvania;
BEACH Act grant allocation of $10 million: 224,471;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 163,007;
Difference between actual and estimated allocations (in dollars): -
61,464;
Difference between actual and estimated allocations: -27.4.
States and territories: Puerto Rico;
BEACH Act grant allocation of $10 million: 330,908;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 221,682;
Difference between actual and estimated allocations (in dollars): -
109,226;
Difference between actual and estimated allocations: -33.0.
States and territories: Rhode Island;
BEACH Act grant allocation of $10 million: 213,729;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: 120,716;
Difference between actual and estimated allocations (in dollars): -
93,013;
Difference between actual and estimated allocations: -43.5.
States and territories: South Carolina;
BEACH Act grant allocation of $10 million: 300,681;
Amount based on beach season: 250,000;
27.2% of amount based on beach season: 83,333;
Estimated BEACH Act grant under simulated formula: 282,859;
Difference between actual and estimated allocations (in dollars): -
17,822;
Difference between actual and estimated allocations: -5.9.
States and territories: Texas;
BEACH Act grant allocation of $10 million: 390,044;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 454,496;
Difference between actual and estimated allocations (in dollars):
64,452;
Difference between actual and estimated allocations: 16.5.
States and territories: Virgin Islands;
BEACH Act grant allocation of $10 million: 303,455;
Amount based on beach season: 300,000;
27.2% of amount based on beach season: 100,000;
Estimated BEACH Act grant under simulated formula: 113,602;
Difference between actual and estimated allocations (in dollars): -
189,853;
Difference between actual and estimated allocations: -62.6.
States and territories: Virginia;
BEACH Act grant allocation of $10 million: 283,536;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: $395,541;
Difference between actual and estimated allocations (in dollars):
112,005;
Difference between actual and estimated allocations: 39.5.
States and territories: Washington;
BEACH Act grant allocation of $10 million: 276,382;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: $367,377;
Difference between actual and estimated allocations (in dollars):
90,995;
Difference between actual and estimated allocations: 32.9.
States and territories: Wisconsin;
BEACH Act grant allocation of $10 million: 227,448;
Amount based on beach season: 200,000;
27.2% of amount based on beach season: 66,667;
Estimated BEACH Act grant under simulated formula: $174,729;
Difference between actual and estimated allocations (in dollars): -
52,719;
Difference between actual and estimated allocations: -23.2.
States and territories: Total;
BEACH Act grant allocation of $10 million: $10,000,001;
Amount based on beach season: $8,150,000;
27.2% of amount based on beach season: $2,716,667;
Estimated BEACH Act grant under simulated formula: $10,000,000;
Difference between actual and estimated allocations (in dollars): -$1;
Difference between actual and estimated allocations: 0.0%.
Source: GAO.
Note: Differences noted are due to rounding.
[End of table]
By simulating the distribution of BEACH Act grants given the more
equally weighted percentages EPA built into its original formula,
states with large populations, such as Florida, California, and New
York would receive almost twice as much grant funding as their current
allocations. However, this increase would come at the expense of states
such as Alabama and Indiana, and territories such as Puerto Rico, which
would receive as little as half of their current allocations.
California's allocation, for example, would increase by 92 percent,
while Indiana's allocation would decrease by 56 percent. It is
important to recognize that such large swings in allocations could make
it difficult for states that have come to depend on BEACH Act funding
over the last 6 years to continue to monitor their beaches. EPA could
consider using a hold-harmless provision to minimize states' potential
loss of large portions of their BEACH Act grants. The hold-harmless
provision would ensure that the current grantees would maintain, at a
minimum, their previous year's allocation, while any additional funding
would be allocated to those states with longer shorelines and larger
populations.
[End of section]
Appendix IV: Comments from the Environmental Protection Agency:
United States Environmental Protection Agency:
Office Of Water:
Washington, D.C. 20460:
Apr 13:
Ms. Anu Mittal:
Director, Natural Resources and Environment:
U.S. Government Accountability Office (GAO):
Washington, DC 20548:
Dear Ms Mittal:
Thank you for the opportunity to comment on the draft report entitled:
Great Lakes: EPA and States Have Made Progress in Implementing the
BEACH Act, but Additional Actions Could Improve Public Health
Protection (GAO-07-591). The Office of Water has reviewed the draft
report and offers the following comments in response to the three
"Recommendations for Executive Action."
Recommendation: Establish a definitive timeline for completing the
studies on pathogens and their effects on human health, and or
publishing new or revised water quality criteria for pathogens and
pathogen indicators.
The report accurately represents EPA's efforts in developing new or
revised recreational water criteria. On March 26-30, EPA sponsored a
week-long national and international experts' workshop on the
scientific and research needs associated with producing new
recreational water quality criteria. The workshop underscored the
challenge EPA faces in developing new criteria that are scientifically
sound, advance public health protection, and are able to be easily
adopted and implemented by States. Although there have been numerous
advances in science (including significant work completed by EPA) since
the development of the 1986 Ambient Water Quality Criteria for
Bacteria, there remain substantial gaps in the state of scientific
knowledge in this area. For example, although there appears to be
general agreement in the scientific community that recreational waters
contaminated with animal waste pose less risk to humans than waters
contaminated with human waste, this has yet to be quantified. New
criteria that do not account for this difference would likely lead to
over-regulation in cases where the sole source or predominant source of
fecal contamination is animal waste. EPA will develop a science action
plan and definitive timeline for the completion of additional studies
and research and will use these data to develop and publish new or
revised water quality criteria.
Recommendation: If current funding levels remain the same, revise the
formula for distributing BEACHAct grants to better reflect the states'
varied monitoring needs by reevaluating the formula factors to
determine if the weight of the beach season factor should be reduced
and if the weight of other factors, such as beach use and beach miles
should be increased.
In 2006-2007, EPA engaged the states in a year-long stakeholder
dialogue to discuss whether and how to modify the current BEACH Act
grant allocation formula. There was high state participation in a
series of conference calls (25 of the 35 BEACH Act states and
territories participated), the purpose of which was to explore the same
types of questions that GAO has raised. EPA developed and presented to
the states approximately 5 allocation funding options, some of which
generated outcomes very close to those produced by GAO. EPA was
successful in producing allocation formulas that provided larger grants
to states with more beaches and more people. However, the potential
impact to established beach monitoring programs in the states that
would have lost funding was viewed by the workgroup participants,
winners and losers alike, as unacceptably detrimental to programs in
those states and to the national BEACH Act program. This is because
there is a minimum level of funding that is needed to operate a beach
monitoring and advisory program---regardless of the number of beach
miles or the length of the beach season.
This level of funding includes funding a state beach coordinator and
sufficient resources to effect the other requirements of the BEACH Act,
including collection and submission to EPA of data on water quality and
advisories. Other factors relating to the extent of beaches and
population are accounted for to some extent in the current allocation
formula, but GAO is correct in pointing out the same disparities that
led EPA to convene a dialogue with state partners to consider options
for revisiting the formula. For many states, budgets are very tight,
and recreational water monitoring is limited to the amount received in
BEACH Act grant funding. These states are extremely sensitive to the
prospect of any reductions in their grant amounts, to the point where
they could choose to opt out of EPA's BEACH Act grant program if
reductions occurred.
For states such as Florida and California, which use BEACH Act funds to
supplement existing state funding for beaches, tourism and associated
beach use are major drivers of the states' economies. Although these
two states are among those that receive proportionally less than might
otherwise be the case under alternative allocation scenarios, both
provide very substantial additional monies for beach monitoring, and
both were supportive of EPA's plan to make only minor changes to the
current allocation formula.
Recommendation: To better ensure consistent levels of public health
protection, EPA should provide states and localities with specific
guidance on monitoring frequency and methods and public notification.
By design, EPA allows states a substantial degree of latitude within
its published performance criteria in the implementation of their beach
monitoring and advisory programs. This is in deference to the range of
conditions that exist in the various states, the range of agencies that
implement the beach programs in the states, and the capabilities and
creativity of local beach managers in carrying out their programs. This
being said, the science of sampling and monitoring of beach waters has
progressed substantially since the enactment of the BEACH Act and the
initial publication of EPA's 2002 National Beach Guidance. EPA
envisions beginning the process of revising this guidance document in
the near future. In the meantime, EPA will provide additional
information to the states on developing best practices and successful
strategies for monitoring and notification through vehicles such as its
National Beach Conference.
Again, thank you for the opportunity to review and comment on the draft
report. I look forward to our comments being reflected in the final
report. If you have questions or concerns about the comments or the
BEACH Act program, you may contact me, or have your staff contact
Ephraim King, Director, Office of Science and Technology, at 202-566-
0430.
Sincerely,
Signed by:
Benjamin H. Grumbles:
Assistant Administrator:
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Anu K. Mittal, (202) 512-3841, mittala@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Edward Zadjura, Assistant
Director; Eric Bachhuber; Joanna Chan; Robert Dinkelmeyer; Greg
Dybalski; Heather Holsinger; DuEwa Kamara; Matt Michaels; Omari Norman;
Alison O'Neill; Mark Ramage; and Walter Vance made key contributions to
this report. Also contributing to the report were Kim Raheb, Jena
Sinkfield, and John Wanska.
FOOTNOTES
[1] Although the BEACH Act was originally authorized through 2005,
Congress continued to fund EPA's efforts under the act in 2006 and
2007.
[2] In this report, all percentages based on our survey are estimates
and subject to sampling error. Unless otherwise noted, all percentage
estimates from this survey have 95 percent confidence intervals of
within plus or minus 10 percentage points of the estimate.
[3] Water quality standards include narrative and numeric criteria that
support specific designated uses and also specify goals to prevent
degradation of good quality waters.
[4] The BEACH Act defines coastal recreation waters as the Great Lakes
and coastal waters (including coastal estuaries) that states,
territories, and authorized tribes officially recognize (or
"designate") for swimming, bathing, surfing, or similar activities in
the water. The BEACH Act applies to 30 coastal and Great Lakes states
and 5 U.S. territories. See appendix II for a map of the 35 states and
territories with coastal recreational waters.
[5] EPA worked with the states and territories to identify their
existing water quality standards and to review them for consistency
with the BEACH Act requirements. On April 16, 2004, EPA sent a letter
to environmental agencies at all 35 states with coastal recreational
waters and proposed federal standards for those states that had not yet
adopted EPA's 1986 criteria.
[6] In order to house the water quality data, EPA decided to use EPA's
previously existing STORET (STORage and RETrieval) database. For beach
advisory and closing data, EPA created the PRAWN (Program Tracking
database for Advisories, Water Quality Standards, and Nutrients)
database. STORET is the repository for water quality, biological, and
physical data and is used by EPA offices, state environmental agencies,
universities, and other organizations. PRAWN is a repository for beach
advisory and closing data.
[7] EPA used quantitative polymerase chain reaction (PCR) method to
quantify two types of bacteria, enterococci and bacteroides, at four
freshwater beaches on Lake Michigan and Lake Erie. The results of the
water quality tests were then correlated to health surveys of
beachgoers who swam at the beaches, by interviewing beachgoers as they
left the beach, and again by telephone 10 to 12 days after their beach
visit to assess the levels of diarrhea and gastrointestinal illness, as
well as other adverse health effects.
[8] EPA used information on the length of beach seasons reported in the
National Health Protection Survey of Beaches for the states or
territories that submitted a completed survey. EPA estimated the beach
season length for Alaska based on several factors.
[9] EPA used the Census Bureau's 2000 Census data as a surrogate for
coastal population.
[10] EPA used NOAA's The Coastline of the United States to quantify
shoreline miles.
[11] We conducted a simulation to allocate funding based on the ratios
obtained when the $30 million authorizations was anticipated. We
constructed the formula to maintain the 27 percent weight for beach
season while allocating a $10 million appropriation amount. This
simulation demonstrates how altering the formula would shift funding,
affecting current allocations for the Great Lakes states.
[12] GAO conducted a simulation for all 35 coastal states and
territories to determine how their grants funding levels would change
if EPA reweighted the formula given the current appropriation levels of
approximately $10 million. See appendix III for a description of this
simulation and results for all states.
[13] Based on our survey, an estimated 41 percent believe that their
grants were inadequate, and an estimated 3 percent believe that these
grants are very inadequate. Further, about 30 percent believe that
their grants were adequate, and 1 percent believe that these grants are
very adequate.
[14] The only exception is Pennsylvania, where all of the state's
beaches are in Erie County. As such, in 2006, Pennsylvania became the
only state in the country with a county-run program, and Erie County is
the only locality that receives grants directly from EPA.
[15] In the case of predicted high levels of rainfall or sewage
releases, local officials responding to our survey reported that about
13 percent of Great Lakes beaches issue preemptive closures.
[16] If a sample exceeds a standard, a locality will typically resample
until the test is normal.
[17] EPA calculates the total number of beach days by estimating a
beach season (number of days the beach is open) for each beach and
summing this across all beaches in the Great Lakes.
[18] EPA's Environmental Monitoring for Public Access and Community
Tracking (EMPACT) project examined five beach environments to determine
if beach-specific characteristics impact beach monitoring results and
found that the depth of water sample collection influences bacterial
densities.
[19] EPA's 1986 Ambient Water Quality Criteria for Bacteria. Michigan,
New York, and Wisconsin also continue to test for fecal coliforms in
addition to E. coli.
[20] EPA officials have had difficulty tracking the total number of
monitored and unmonitored beaches because states have changed their
beach inventories over the years. In addition, double counting of
beaches has occurred in the past as historical data were not always
vetted by the state officials, and because local counties with dual
jurisdictions may have double counted beach data.
[21] Sanitary surveys are used to identify sources of pollution and
provide information on source controls and identification, persistent
problems, and management actions. EPA's National Beach Guidance and
Required Performance Criteria for Grants states that a sanitary survey
can be an effective tool for protecting human health at bathing beaches
and providing information that helps in designing monitoring programs.
[22] The BEACH Act provides that EPA may award grants to states and
localities for "monitoring and notification" programs. 33 U.S.C. §
1346(b)(2)(A). According to EPA officials, the term "monitoring"
encompasses limited investigations to determine sources of
contamination but does not include remediation to address the source of
the contamination.
[23] The estimate of shoreline miles are taken from NOAA's The
Coastline of the United States. Population estimates are taken from the
2000 Census.
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