    Great Lakes: Organizational Leadership and Restoration Goals Need
    to Be Better Defined for Monitoring Restoration Progress
    (28-SEP-04, GAO-04-1024).

    The Great Lakes remain environmentally vulnerable, prompting the
    United States and Canada to agree on actions to preserve and
    protect them. As requested, this report (1) determines the extent
    to which current EPA monitoring efforts provide information for
    assessing overall conditions in the Great Lakes Basin, (2)
    identifies existing restoration goals and whether monitoring is
    done to track goal progress, and (3) identifies the major
    challenges to setting restoration goals and developing a
    monitoring system.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-04-1024
        ACCNO:   A12800
      TITLE:     Great Lakes: Organizational Leadership and Restoration
    Goals Need to Be Better Defined for Monitoring Restoration
    Progress
         DATE:   09/28/2004
      SUBJECT:   Environment evaluation
    	     Environmental monitoring
    	     Environmental policies
    	     Inland waterways
    	     International agreements
    	     International cooperation
    	     Water quality
    	     Water resources conservation
    	     Environmental restoration
    	     EPA Great Lakes Strategy 2002
    	     EPA Lakewide Management Plan
    	     Great Lakes
    	     State of the Lakes Ecosystem Conference
    	     Great Lakes Water Quality Agreement

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    GAO-04-1024

    United States Government Accountability Office

    GAO

                           Report to Congressional Requesters

    September 2004

    GREAT LAKES

     Organizational Leadership and Restoration Goals Need to Be Better Defined for
                            Monitoring Restoration Progress

    GAO-04-1024

    September 2004

    GREAT LAKES

    Organizational Leadership and Restoration Goals Need to Be Better Defined for
    Monitoring Restoration Progress

    Current Environmental Protection Agency (EPA) monitoring does not provide
    the comprehensive information needed to assess overall conditions in the
    Great Lakes Basin because the required coordinated joint U.S./Canadian
    monitoring program has not been fully developed. Information collected
    from monitoring by other federal and state agencies does not, by design,
    provide an overall assessment of the Great Lakes because it is collected
    to meet specific program objectives or limited to specific geographic
    areas.

    Multiple restoration goals have been proposed through efforts by EPA and
    other organizations. EPA developed basin-wide goals through its Great
    Lakes Strategy 2002 and goals for plans addressing individual lakes. Other
    organizations have also identified basin-wide restoration goals and
    priorities. Monitoring of progress toward goals is generally limited to
    tracking specific action items proposed in the Great Lakes Strategy 2002;
    other proposed goals are generally not monitored to determine progress.

    Efforts to coordinate basin-wide goals and a monitoring system face
    several challenges. The lack of clearly defined organizational leadership
    poses a major obstacle. Both EPA's Great Lakes National Program Office
    (GLNPO) and a newly created interagency task force have coordination roles
    raising uncertainty as to how leadership and coordination efforts will be
    exercised in the future. Second, coordinating existing restoration goals
    and monitoring activities among the many participating organizations
    within the United States, and between the United States and Canada is a
    significant challenge. Third, centralized information from monitoring
    activities is not yet available, making it difficult to assess restoration
    progress. In addition, an inventory system developed by EPA and Canada may
    not have adequate controls on voluntarily provided information.

    Highlights of GAO-04-1024, a report to congressional requesters

    The Great Lakes remain environmentally vulnerable, prompting the United
    States and Canada to agree on actions to preserve and protect them.

    As requested, this report (1) determines the extent to which current EPA
    monitoring efforts provide information for assessing overall conditions in
    the Great Lakes Basin, (2) identifies existing restoration goals and
    whether monitoring is done to track goal progress, and (3) identifies the
    major challenges to setting restoration goals and developing a monitoring
    system.

    GAO recommends EPA develop controls to ensure the Great Lakes monitoring
    system inventory is complete, accurate, and consistent. Also, the Congress
    may wish to consider clarifying if GLNPO or the task force should lead
    restoration efforts and require development of measurable basin-wide goals
    with a monitoring system for measuring progress.

    EPA agreed with GAO's recommendation regarding adequate inventory
    monitoring controls. EPA believes responsibilities and relationships for
    the task force and GLNPO are clearly stated in the executive order and
    statute but did not address GAO's concerns about how GLNPO will exercise
    its leadership and coordination responsibilities.

    www.gao.gov/cgi-bin/getrpt?GAO-04-1024.

    To view the full product, including the scope and methodology, click on
    the link above. For more information, contact John Stephenson (202)
    512-3841 or stephensonj@gao.gov.

    r

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    .S

    Contents

    Letter

    Results in Brief
    Background
    Current EPA Monitoring Efforts Do Not Provide Comprehensive

    Information on the Condition of the Great Lakes and Monitoring

    by Other Organizations Is Limited by Purpose and Scope Multiple Goals
    Exist for Monitoring Restoration Progress Significant Challenges Exist for
    Setting Basin-Wide Goals and

    Developing a Monitoring System for the Great Lakes Conclusions Matter for
    Congressional Consideration Recommendation for Executive Action Agency
    Comments and Our Evaluation

                                           1

                                          3 5

                                         10 18

    21 34 35 36 36

    Appendix I Scope and Methodology

    Appendix II	Federal, State, Canadian, and Other Organizations That
    Provided Great Lakes Monitoring and Research Information

    Appendix III	Comments by Officials on Need for Indicators and Monitoring
    in the Great Lakes Basin

    Appendix IV	State of Ohio Lake Erie Programs and Initiatives with
    Monitoring Activities

    Appendix V	Observations on Goals and Monitoring Information Contained in
    LaMPs for Four Great Lakes 49

    Appendix VI	Goals and Priorities Established by Three Great Lakes
    Organizations 52

    Appendix VII	Comments from the Environmental Protection Agency 54

    Appendix VIII GAO Contact and Staff Acknowledgments 58

    GAO Contact 58 Staff Acknowledgments 58

    Table

    Table 1: Summary Comments by Officials on the Need for Indicators and
    Comprehensive Monitoring in the Great Lakes Basin

    Figures

    Figure 1: Area Comprising the Great Lakes Basin 6 Figure 2: GLNPO's Water
    Quality Survey Sampling Stations 15 Figure 3: Differences in
    Characteristics of Lake Superior and Lake

    Erie 31

    Abbreviations

    BEC Binational Executive Committee
    EC Environment Canada
    EPA Environmental Protection Agency
    FWS U.S. Department of Interior's Fish and Wildlife Service
    GLERL Great Lakes Environmental Research Laboratory
    GLFC Great Lakes Fishery Commission
    GLISP Great Lakes International Surveillance Plan
    GLNPO Great Lakes National Program Office
    GLWQA Great Lakes Water Quality Agreement
    IADN International Atmospheric Deposition Network
    IJC International Joint Commission
    LaMP Lakewide Management Plan
    NAWQA National Water Quality Assessment
    NHEERL National Health Environmental Effects Research

    Laboratory NRRI Natural Resources Research Institute NOAA National Oceanic
    and Atmospheric Administration ORD Office of Research and Development PCB
    polychlorinated biphenyl SOLEC State of the Lakes Ecosystem Conference
    TMDL Total Maximum Daily Load USGS U.S. Geological Survey USPC U.S. Policy
    Committee

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    United States Government Accountability Office Washington, DC 20548

    September 28, 2004

    Congressional Requesters

    The Great Lakes, the largest system of freshwater in the world, is
    recognized by the United States and Canada as a natural resource that is
    threatened on many environmental fronts. Recently discovered conditions
    such as the reemergence in Lake Erie of a "dead zone"-an area that has
    little or no dissolved oxygen and, therefore, cannot support aquatic life-
    have renewed concerns about the overall ecological health of the Great
    Lakes Basin, which includes the five Great Lakes-Superior, Michigan,
    Huron, Erie, and Ontario-and a large land area that extends beyond the
    lakes, including their watersheds, tributaries, connecting channels, and a
    portion of the St. Lawrence River. While the two countries have made some
    progress in protecting and restoring the Great Lakes ecosystem-the air,
    water, land, and living organisms within the basin-polluted beaches are
    frequently closed to swimmers, fish are unsafe to eat for high-risk
    individuals, and raw sewage is still being dumped into the lakes. While
    some information on environmental conditions of the Great Lakes is
    available, questions remain as to overall conditions and the progress of
    restoration.

    As concern increased over the contamination of the Great Lakes, the United
    States and Canada signed the first international Great Lakes Water Quality
    Agreement (GLWQA) in 1972. In the agreement, the United States and Canada
    agreed to restore and maintain the chemical, physical, and biological
    integrity of the Great Lakes Basin. The overall goals of the GLWQA are to
    restore and enhance water quality in the lakes. In 1978, the parties
    signed another Great Lakes Water Quality Agreement that reaffirmed their
    determination to restore and enhance water quality and called for
    increasing control of toxic substances throughout the Great Lakes Basin.
    Subsequently, amendments were made to the 1978 agreement in 1983 and 1987.
    The 1987 Protocol amendments added several annexes that focused on
    specific environmental concerns and amended one, Annex 11, on surveillance
    and monitoring. Annex 11 requires the two countries to undertake a joint
    program to, among other things, monitor restoration progress and assess
    the degree to which the parties are complying with the requirements and
    objectives of the agreement. Monitoring is accomplished through various
    sampling methods, such as using air monitoring equipment to measure the
    deposition of toxic chemicals. Monitoring may help identify the source and
    extent of problems and aid decision makers in

    setting restoration goals, taking action, and determining the extent to
    which goals are being met. Goals should be stated in measurable terms in
    order to monitor progress. In an effort to establish restoration
    strategies to meet the overall goals of the GLWQA, the U.S. Policy
    Committee (USPC)a forum of senior level representatives from the
    federal, state, and tribal government agencies that share responsibility
    for environmental protection and resource management in the Great
    Lakesdeveloped the Great Lakes Strategy 2002. EPA efforts in
    establishing goals also include helping to develop Lakewide Management
    Plans (LaMP) for each of the individual Great Lakes.

    In addition, a joint effort by the two countries to assess and report on
    environmental conditions in the Great Lakes began in 1994, with the first
    State of the Lakes Ecosystem Conference (SOLEC). The conference has
    convened every 2 years thereafter and its proceedings are used as a basis
    for reporting on the state of the lakes. In the late 1990s, SOLEC began
    developing a comprehensive set of indicators on the condition of the Great
    Lakes ecosystem. SOLEC's reports have described indicators such as
    chemical contaminants in edible fish tissue and toxic chemical
    concentrations in offshore waters.

    The Clean Water Act charges the U.S. Environmental Protection Agency (EPA)
    with leading the effort to meet the requirements of the GLWQA. The act
    also statutorily established the Great Lakes National Program Office
    (GLNPO) within EPA, charging it with, among other things, cooperating with
    federal, state, tribal, and international agencies to develop and
    implement specific action plans to carry out the U.S. responsibilities
    under the agreement. In addition to the various governmental agencies
    involved in Great Lakes restoration, several nongovernmental organizations
    have established restoration goals. In 2003, we reported that an overall
    strategy was needed to guide numerous ongoing restoration activities and
    that indicators and a monitoring system were needed to measure overall
    restoration progress.1

    You asked us to (1) determine the extent to which current EPA monitoring
    efforts provide information for assessing overall conditions in the Great
    Lakes Basin and what information is provided by other organizations
    conducting monitoring in the Great Lakes, (2) identify existing
    restoration

    1GAO, Great Lakes: An Overall Strategy and Indicators for Measuring
    Progress Are Needed to Better Achieve Restoration Goals, GAO-03-515
    (Washington, D.C.: Apr. 30, 2003).

    goals and whether monitoring is done to track goal progress, and (3)
    identify the major challenges to setting basin-wide restoration goals and
    developing a monitoring system for the Great Lakes.

    To address the extent to which information derived from monitoring is
    useful for assessing overall conditions in the Great Lakes Basin, we
    reviewed information on monitoring activities conducted by U.S. and
    Canadian federal agencies and the eight states and two Canadian provinces
    that share the basin. We also examined the monitoring requirements
    included in the GLWQA and compared these requirements with ongoing
    monitoring and SOLEC activities. To identify existing restoration goals,
    we reviewed the goals and monitoring efforts contained in the Great Lakes
    Strategy 2002 and EPA's LaMPs for four of the five Great Lakes. We also
    examined the restoration goals of several organizations participating in
    the restoration of the Great Lakes. To identify major challenges to
    setting restoration goals and developing a monitoring system for the Great
    Lakes, we obtained and analyzed information on several barriers to
    progress and focused on four major challenges involving organizational
    leadership, coordinating goals and monitoring, centralized information on
    monitoring activities, and environmental differences between the lakes. We
    conducted our work from August 2003 to May 2004 in accordance with
    generally accepted government auditing standards. A more detailed
    discussion of our scope and methodology is outlined in appendix I.

    Current EPA monitoring does not provide the comprehensive information
    needed to monitor restoration progress and assess the degree to which the
    parties are complying with the requirements and objectives of the
    agreement because the coordinated joint U.S./Canadian monitoring program
    mandated under the GLWQA has not been fully developed. Other federal and
    state organizations are conducting monitoring efforts but, while useful,
    they are limited to specific purposes and geographical scope. Rather than
    developing a basin-wide monitoring system to assess overall conditions in
    the Great Lakes, EPA focused its efforts on supporting SOLEC in developing
    a comprehensive set of environmental indicators and using some of the
    indicators for reporting on overall conditions in the Great Lakes Basin.
    While SOLEC has identified and evaluated a large number of indicators,
    both Canadian and U.S. officials have questioned the value of the
    information reported by SOLEC from these indicators because, among other
    things, it is not based on their decision-making needs. Specifically,
    SOLEC attempts to describe overall conditions based on information
    voluntarily provided and maintained by others, and it does

      Results in Brief

    not assess whether conditions are improving or deteriorating based on
    measurable restoration goals. Additionally, most of the information
    collected from monitoring activities by other federal and state
    organizations does not, by design, provide an overall assessment of
    restoration progress in the Great Lakes Basin because it is collected to
    meet specific program objectives or limited to specific geographic
    areas such as monitoring water quality to determine whether some
    beaches are safe for swimming or monitoring to support research in a
    particular area of the Great Lakes. State organizations generally conduct
    monitoring in the inland and nearshore areas while federal monitoring
    extends to the open lake water areas.

    EPA and other organizations have proposed multiple restoration goals;
    however, few have monitoring activities to track restoration progress
    called for in the goals. EPA developed basin-wide goals through its Great
    Lakes Strategy 2002 and devised goals for individual lakes in LaMPs.
    Monitoring progress toward achieving goals is generally limited to
    tracking action items proposed in the Great Lakes Strategy 2002; the LaMPs
    discuss indicators and monitoring, but they are not often linked to goals
    or do not show how progress toward goals will be measured. Other
    organizations concerned with Great Lakes restoration, such as the Council
    of Great Lakes Governors, have also identified basin-wide restoration
    goals and priorities. Several of the organizations' goals are similar,
    representing a relative consensus among the groups. While these goals are
    useful in communicating what specific issues the groups believe are
    important to the Great Lakes, these organizations may not have the
    resources or capacity to engage in basin-wide monitoring, and additional
    specifics may be needed to determine whether the goals are being achieved.

    Those involved in protecting and restoring the Great Lakes face four
    significant challenges in setting measurable goals and developing a
    basinwide monitoring system: the lack of clearly defined organizational
    leadership, the inherent difficulty associated with coordinating existing
    goal setting and monitoring activities among the many participating
    organizations in the United States and between the United States and
    Canada, the lack of centralized information from monitoring activities to
    assess restoration progress, and the unique environmental dynamics of each
    of the lakes. First, responsibility for leading and coordinating U.S.
    efforts to meet GLWQA requirements rests with EPA and GLNPO, according to
    the Clean Water Act. However, this role has never been completely filled
    by GLNPO because it has not fully exercised its coordination authority.
    Other organizations have attempted to fill the void.

    Most recently, this executive order created a new interagency task force
    within EPA to coordinate Great Lakes activities, but its long-term
    effectiveness is unclear because executive orders may be changed or
    rescinded by future administrations, and this executive order cannot be
    enforced in court as is often the case with statutes. In addition, the
    future role of GLNPO and other organizations in relation to the task force
    is unclear. Second, existing restoration goals and monitoring activities
    in the United States and within Canada need to be coordinated if
    basin-wide goals are to be established and a joint monitoring system
    developed as called for in the GLWQA. Given the extensiveness of Canada's
    efforts, and agreements between Canada and the provinces of Ontario and
    Quebec, it will be a challenge to coordinate with Canada in developing
    basin-wide goals for measuring restoration progress. Third, the lack of an
    accurate, complete, and centralized source of existing monitoring
    information for coordinating activities and assessing basin-wide
    conditions is a significant challenge. GLNPO and Environment Canada have
    developed an Internetbased inventory for existing monitoring systems, but
    this inventory will rely on voluntarily provided information, which will
    not ensure enough control over the information so that it will result in
    an inventory with complete, accurate, and consistent information. Fourth,
    because each of the five Great Lakes has unique environmental conditions,
    setting measurable goals that reflect these differences and yet provide
    consistent basin-wide information will be difficult.

    To help ensure the coordination of the U.S. efforts in developing
    basinwide measurable restoration goals with a monitoring system, we
    recommend that the Congress may wish to consider clarifying whether GLNPO
    or the interagency task force should lead restoration efforts for the
    United States and require the entity it selects to develop and prioritize
    measurable goals for the Great Lakes Basin and develop and implement a
    monitoring system to measure progress toward attaining goals along with
    identifying actions that could assist in achieving goals.

    In addition, we are recommending that the EPA Administrator direct GLNPO
    to develop controls for the automated inventory to ensure that the
    information it contains is complete, accurate, and consistent.

    Background 	The Great Lakes contain over 95 percent of the nation's
    surface freshwater supply for the contiguous 48 states and more than 20
    percent of the world's freshwater supply. The lakes provide water for
    drinking, transportation, power, recreation-such as swimming and
    fishingand a host of other uses for more than 30 million people
    who live in the Great

    Lakes Basin, roughly 10 percent of the U.S. population and more than 30
    percent of the Canadian population. Spanning more than 750 miles from west
    to east, the basin encompasses nearly all of the state of Michigan and
    parts of Illinois, Indiana, Minnesota, New York, Ohio, Pennsylvania,
    Wisconsin, and the Canadian province of Ontario. Parts of the St. Lawrence
    River, the connecting channel between Lake Ontario and the Atlantic Ocean,
    flow through the provinces of both Ontario and Quebec.

    Figure 1: Area Comprising the Great Lakes Basin

    Source: GAO.

    Recognizing their mutual interests in the Great Lakes and other boundary
    waters, the United States and Great Britain signed the Boundary Waters
    Treaty in 1909, which provided the United States and Canada with a
    framework for dealing with future issues along the border. The treaty
    established the International Joint Commission (IJC), comprising three
    commissioners each from the United States and from Canada, to help the two
    governments resolve and prevent disputes concerning their shared boundary
    waters. Among other things, the IJC also assists the governments in the
    implementation of the GLWQA, reports every 2 years on implementation
    progress, and offers nonbinding recommendations to the two governments.
    Signed in 1972, the GLWQA focused on restoring and enhancing water quality
    in the lakes and controlling phosphorous as a

    principal means of dealing with eutrophication in the lakes. Under the
    terms of the GLWQA, the two governments are required to conduct a
    comprehensive review of the operation and effectiveness of the agreement
    every 6 years. The next review is scheduled to begin in 2004, and based
    upon the results, the two countries may decide to amend the agreement. The
    last review in 1999 found that certain sections of the agreement were
    outdated and revisions were needed.

    As amended, the GLWQA has 17 annexes that define in detail the specific
    programs and activities that the two parties have agreed upon and
    committed to implement. Most of the annexes specify pollution prevention
    strategies. Annex 11 of the GLWQA calls for the parties to implement a
    joint surveillance and monitoring program that, among other things,
    evaluates water quality trends, identifies emerging problems, and supports
    the development of remedial action plans for contaminated areas-referred
    to as areas of concern--and LaMPs for the open waters of each of the five
    lakes to reduce critical pollutants and to restore and protect beneficial
    uses.2 Specifically, Annex 11 calls for the monitoring program to include
    baseline data collection, sample analysis, and evaluation and quality
    assurance programs to assess such things as whole lake data including that
    for open waters and nearshore areas of the lakes as well as fish and
    wildlife contaminants; inputs from tributaries, point source discharges,
    atmosphere, and connecting channels; and total pollutant loadings to and
    from the Great Lakes system.

    The monitoring program under Annex 11 is to be based on the Great Lakes
    International Surveillance Plan (GLISP) developed before the current
    requirements for a surveillance and monitoring system. Developing the
    surveillance plan, which involved developing a separate plan for each
    lake, required extensive efforts by U.S. and Canadian officials over
    several years. However, according to one Canadian official involved in the
    process, the plans were not completed to the point where they could be
    implemented. The IJC's Water Quality Board was involved in the management
    and development of the GLISP, but according to a binational review of the
    GLWQA in 1999, the IJC's role was reduced after the GLQWA amendments of
    1987 placed more of the responsibility for data analysis and reporting on
    the state of the Great Lakes environment with the two

    2We reported no the progress made on remedial action plans in GAO, Great
    Lakes: EPA Needs to Define Organizational Responsibilities Better for
    Effective Oversight and Cleanup of Contaminated Areas, GAO-02-563
    (Washington, D.C.: May 17, 2002).

    governments. IJC's role today is one of assisting in the implementation of
    the agreement and evaluating the actions of the two governments in meeting
    the objectives of the GLWQA. After the GLISP effort, the governments
    reduced support for the surveillance and monitoring called for in the
    agreement, and abandoned the organizational structure created to implement
    the monitoring plan, leaving in place only one of the plan's initiatives,
    the International Atmospheric Deposition Network (IADN), a network of 15
    air-monitoring stations located throughout the basin developed in response
    to the GLWQA requirement of a monitoring program to allow assessment of
    inputs from the atmosphere affecting the Great Lakes. In addition, under a
    separate annex in the GLWQA (Annex 2), LaMPs are required to include,
    among other things, a description of the surveillance and monitoring to be
    used to track the effectiveness of remedial measures and the elimination
    of critical pollutants. The agreement requires that updates to the LaMPs
    be submitted to the IJC for review and comment. IJC is considering whether
    to conduct a review of the LaMPs in 2004.

    The Water Quality Act of 1987 amended the Clean Water Act to state that
    EPA should take the lead and work with other federal agencies and state
    and local authorities to meet the goals in the agreement. It also
    established within EPA, GLNPO, to among other things, coordinate EPA's
    actions aimed at improving Great Lakes water quality both at headquarters
    and at the affected EPA regional offices, and to coordinate EPA's actions
    with the actions of other federal agencies. As of 2003, GLNPO's budget was
    $16 million, including $5 million allocated for program costs, which
    includes 47 full-time EPA staff and 13 non-EPA staff. The remaining costs
    included about $4.3 million per year for monitoring and monitoring-related
    reporting, which included about $1.4 million to operate GLNPO's research
    vessel, the Lake Guardian. For Canada, Environment Canada (EC) is the lead
    agency, which works in cooperation with the provinces of Ontarioin
    which parts of four of the lakes are locatedand Quebec, which
    administers the St. Lawrence River. Coordination between EPA and EC is
    achieved through the Binational Executive Committee (BEC). Subsequent to
    the GLQWA amendments of 1987, the BEC was formed to coordinate programs
    and policies of the two parties to facilitate GLWQA implementation. BEC,
    co-chaired by EPA and EC, meets twice a year and membership includes
    federal, state, and provincial officials from organizations involved in
    Great Lakes activities. The BEC does not have authority to direct that
    projects or programs be implemented but rather makes recommendations
    regarding certain activities, such as the development of SOLEC. Funding
    provided for BEC operations is limited,

    and it relies on funding from other organizations to implement its
    recommendations.

    In addition to the BEC, several organizations serve coordinating roles,
    offer policy perspectives, or financially support restoration activities
    for the Great Lakes, including the following:

    o  	Council of Great Lakes Governors, a partnership of governors from the
    eight Great Lakes states and the Canadian provinces of Ontario and Quebec,
    encourages and facilitates environmentally responsible economic growth
    throughout the Great Lakes region.

    o  	Great Lakes Commission, an organization promoting the orderly,
    integrated, and comprehensive development, use, and conservation of water
    and related natural resources of the Great Lakes Basin and the St.
    Lawrence River, includes representatives from the eight Great Lakes states
    and the Canadian provinces of Ontario and Quebec.

    o  	Great Lakes United, an international coalition group dedicated to
    preserving and restoring the Great Lakes-St. Lawrence River ecosystem,
    promotes effective policy initiatives, carries out education programs, and
    promotes citizen action and grassroots leadership for Great Lakes
    environmental activities. The coalition's member organizations represent
    environmentalists, conservationists, hunters and anglers, labor unions,
    communities, and citizens of the United States, Canada, and First Nations
    and Tribes.

    o  	United States Policy Committee, a group of senior level
    representatives from federal, state, and tribal government agencies with
    environmental protection or natural resource responsibilities in the Great
    Lakes Basin. The group meets semiannually to coordinate agency actions and
    commitments associated with the Great Lakes Strategy 2002.

    o  	Great Lakes Fishery Commission, a binational commission created by the
    Convention on Great Lakes Fisheries between the United States and Canada
    in 1955, whose primary objectives are to coordinate fisheries management
    and research, and to control sea lamprey. The U.S. Department of State and
    Canada's Department of Fisheries and Oceans provide funding for the
    commission.

    o  	Great Lakes Interagency Task Force, an organization created within EPA
    by executive order to provide coordination of federal activities and
    promote regional collaboration within the Great Lakes Basin and among
    other things, to develop outcome based goals for the Great Lakes system.

      Current EPA Monitoring Efforts Do Not Provide Comprehensive Information on the
      Condition of the Great Lakes and Monitoring by Other Organizations Is Limited
      by Purpose and Scope

    Assisting the task force is a working group composed of regional federal
    officials with GLNPO providing resources for both groups.

    Current EPA monitoring efforts do not provide comprehensive information on
    the condition of the Great Lakes, and the coordinated joint surveillance
    and monitoring program called for in the GLWQA has yet to be fully
    developed. Other ongoing monitoring efforts by federal and state agencies
    yield information that is limited to specific purposes and geographical
    scope. The joint efforts by the United States and Canada to develop
    information on Great Lakes indicators through the SOLEC process does not
    fulfill the monitoring requirements of the GLWQA or adequately assess
    basin-wide conditions of the lakes. Further, the information reported from
    SOLEC is of questionable value to officials making restoration decisions
    because it is not based on their decisionmaking needs. Additionally,
    current monitoring efforts of federal and state organizations do not, by
    design, provide comprehensive information on the overall conditions of the
    Great Lakes. Most of the information collected under these monitoring
    activities is designed to meet specific program objectives or is limited
    to specific geographic areas as opposed to providing an overall assessment
    of the Great Lakes Basin.

    Current Efforts Do Not Fulfill Monitoring Requirements of the GLWQA

    Annex 11 of the GLWQA calls for the United States and Canada to develop a
    joint Great Lakes system-wide surveillance and monitoring program to,
    among other things, provide information on restoration progress and
    whether the objectives of the agreement are being achieved. This program,
    however, has not been fully developed. Instead, officials from GLNPO look
    upon SOLEC as the process by which indicators will be developed to monitor
    environmental conditions and measure restoration progress in the Great
    Lakes. However, as we reported in 2003, the SOLEC process of holding
    conferences every 2 years to develop Great Lakes indicators and monitor
    environmental conditions for subsequent reporting on the state of the
    lakes falls short in several areas.3 First, indicators assessed through
    the process do not provide an adequate basis for making an overall
    assessment of Great Lakes restoration because they rely on limited
    quantitative data and subjective judgments. Second, the SOLEC process is
    dependent on the voluntary participation of officials from federal and
    state agencies, academic institutions, and other organizations. As a
    result, their future commitment to providing information on indicators and
    monitoring

    3GAO-03-515.

    results, along with their future participation, is not assured. Finally,
    most of the stated objectives for SOLEC do not align with the surveillance
    and monitoring program envisioned in the GLWQA. The stated objectives of
    SOLEC are to

    o  	assess the state of the Great Lakes ecosystem based on accepted
    indicators,

    o  strengthen decision making and management,

    o  inform local decision makers of Great Lakes environmental issues, and

    o  provide a forum for communication and networking among stakeholders.

    Other than the objective for assessing the state of the ecosystem based on
    accepted indicators, the SOLEC objectives do not address issues related to
    monitoring. GLNPO officials stated that the objective of SOLEC is not to
    be a monitoring program but rather a reporting venue for conditions in the
    Great Lakes. However, it is the only ongoing effort to provide an overall
    assessment of the Great Lakes and, according to 23 federal, state, and
    other environmental program officials, a surveillance and monitoring
    system is still needed. For example, a Michigan state official explained
    that a monitoring system developed with the involvement of all
    stakeholders and focused on the differences in individual lakes is needed.
    Appendix III contains the specific comments from the officials we
    contacted regarding the need for a monitoring system.

    SOLEC's Monitoring Information Is of Questionable Value in Decision Making

    The monitoring information developed and reported by SOLEC is of
    questionable value to officials responsible for making restoration
    decisions for several reasons. First, the information is not based on
    their decision-making needs. State and federal agency officials stated
    that the SOLEC process is not connected with the policy-making process.
    For example, a Minnesota Pollution Control Agency official stated that the
    SOLEC process is oriented toward the needs of researchers and has not
    connected with the policy-making process for which indicators are needed.
    A Michigan Department of Environmental Quality official stated that SOLEC
    provides information based on data from only one or two sampling locations
    and is not relevant from a state program perspective. Canadian program
    officials shared these opinions, and one official added that SOLEC data
    does not address local community questions or program objectives.

    The comments by program officials are supported by results from a peer
    review of SOLEC in 2003 by an international panel of experts in large
    indicator systems. While the panel had many favorable observations of
    SOLEC, they noted a disconnect between the development of the indicators
    and their usefulness to policy makers. The peer review stated that, to be
    effective, the actual users must define indicators, with policy makers and
    environmental managers involved in the early stages of indicator
    development. In addition to these observations, in the latest report on
    the state of the Great Lakes, one of the management challenges discussed
    is how to better assist managers given the large number of indicators.4
    Specifically, the challenge is to find a method of indexing indicators
    that better assists managers and leads to more useful, informed decision
    making. The disconnect between SOLEC and decision makers is further
    illustrated by the fact that only two of the eight Great Lakes states we
    contacted were reporting information from local monitoring efforts to
    support the SOLEC process and that none of the states reported using the
    monitoring information published by SOLEC to describe conditions of its
    local water bodies or to measure restoration progress. One Minnesota
    official stated that the former head of the state environmental agency
    viewed SOLEC information as irrelevant to describe conditions within the
    state.

    A GLNPO official working on SOLEC stated that developing effective
    indicators requires that you first ask what is to be measured, what the
    best indicator is for this measurement, how much data are needed, who will
    collect and handle the data for consistency, and how often the measurement
    will take place. He stated that the need to ask these questions dates back
    to the early 1980s, but actions to implement this indicator-monitoring
    program never materialized. Instead, different indicators and monitoring
    programs are being conducted by various agencies using different sampling
    methodologies and protocols, and this inconsistent local program
    information cannot, after the fact, be used to make decisions about
    system-wide needs or environmental conditions.

    Second, SOLEC information is based on limited data that further detracts
    from its usefulness to decision makers. For example, of the 80 SOLEC
    indicators reported to describe the Great Lakes Basin in 2003, evaluative
    data were only available for 43 of them. Often this data was
    geographically

    4Environment Canada and U.S. Environmental Protection Agency, State of The
    Great Lakes 2003, EPA 905-R-03-004.

    limited and did not address conditions within the entire basin.
    Additionally, the IJC reported in its 2002 biennial report that sufficient
    data were not being collected from around the Great Lakes and that the
    methods of collection, the data collection time frames, the lack of
    uniform protocols, and the incompatible nature of some data jeopardized
    their use as indicators.5

    Third, there is no guarantee that SOLEC information will be consistently
    collected or will be available in the future. As we reported earlier, the
    SOLEC process involves individuals providing information on a voluntary
    basis with the indicator data residing in a diverse number of sources with
    limited control by SOLEC organizers.6 Therefore, there is no assurance
    that the information will continue to be collected or consistently
    reported over time. Environmental program officials from federal, state,
    and provincial agencies stated that the process lacks sufficient and
    consistent monitoring information to measure environmental restoration
    progress. The SOLEC peer review group found that the SOLEC process has
    serious flaws regarding lack of repeatability and transparency. According
    to GLNPO officials, SOLEC organizers attempted to address the issue of
    repeatability and transparency in 2003 by issuing a technical report,
    which provides additional information on data sources. Further, the
    process is lacking in standard methodology, and SOLEC has yet to establish
    standard protocols to improve data comparability and reliability.

    One attempt to measure restoration progress in the basin using SOLEC
    indicators is presented in EPA's fiscal year 2005 budget justification. To
    measure progress, a single quantitative score is derived based on a
    formula using eight SOLEC indicators. Each indicator is given a score from
    1 to 5 based on the professional judgments of individuals providing the
    indicator information. A score of 1 is considered poor, and 5 is
    considered good. Totaling the individual indicator scores resulted in a
    score of 20 based on a total 40-point scale for the Great Lakes. While
    this is an attempt to measure overall progress, the scoring process is
    based on a limited number of indicators, and the point scores are based on
    subjective judgment. Further, the indicators described in the budget
    justification do not align with the ones used in developing the scores.
    According to GLNPO officials, this may have resulted from information
    being submitted at different times during the development of the budget
    justification.

    5IJC, 11th Biennial Report on Great Lakes Water Quality, (Sept. 12, 2002).
    6GAO-03-515.

    Information from Other Federal and State Monitoring Efforts Is Limited by
    Purpose and Geographic Scope

    Monitoring by Federal Agencies

    In addition to EPA's efforts, several federal and state agencies conduct
    monitoring for specific purposes within the open waters, nearshore, and
    inland areas of the Great Lakes Basin.7 Monitoring is done in these areas
    for assessing environmental conditions, as part of ongoing federal or
    state programs, or for research purposes. The geographic areas monitored
    are generally limited and only specific conditions are monitored. In a few
    cases, such as monitoring the air deposition of toxic substances,
    monitoring of specific conditions covers an extensive area. Monitoring by
    state organizations is generally limited to federal or state program
    purposes and conducted in the nearshore or inland areas of the basin, such
    as identifying impaired waterways that may be tributaries to the lakes
    under the Clean Water Act. Open lake monitoring is generally done by
    federal agencies, like GLNPO, for specific research or program purposes
    and not as part of an overall assessment of the Great Lakes.

    Four federal agencies, EPA, National Oceanic and Atmospheric
    Administration (NOAA), U.S. Geological Survey (USGS), U.S. Department of
    Interior's Fish and Wildlife Service (FWS), and one international
    commission, the Great Lakes Fishery Commission (GLFC), have ongoing
    monitoring activities for specific purposes within limited areas of the
    Great Lakes Basin. EPA's GLNPO conducts four monitoring activities. First,
    GLNPO conducts annual monitoring of open lake water areas for the specific
    purpose of gathering information on water quality and biological
    conditions. The information gathered includes toxic pollutant levels of
    persistent substances, such as phosphorous. These sampling efforts are
    generally conducted twice each year, once in spring and once in summer,
    when the Lake Guardian travels to various fixed sampling sites on each of
    the lakes (see fig. 2). Sampling information collected during these
    assessments is stored in an automated database and is limited to assessing
    long-term trends in open lake waters. GLNPO officials stated that it takes
    about 6 to 7 years of data before enough information is available to
    identify a long-term trend.

    7Inland areas include rivers, tributaries, and streams flowing into the
    lakes; nearshore includes the shoreline out to where the open lake begins,
    which is where water is 30 feet deep or a distance of 2 miles from the
    shoreline, according to GLNPO officials.

    polychlorinated biphenyls (PCB) and trace metals, such as lead and
    cadmium, that have entered the watershed. While GLNPO is responsible for
    monitoring in the United States, EC is responsible for Canadian locations.
    IADN consists of 5 master sampling stations and 10 satellite stations
    located throughout the basin and is limited to identifying substances
    deposited through the air. Fourth, GLNPO conducts an annual fish program
    to monitor concentrations of contaminants in Great Lakes fish. GLNPO has
    agreements with the Universities of Minnesota, Indiana, and Wisconsin,
    along with USGS, to collect specific fish species from each lake and grind
    them into paste to analyze for contaminants that might pose a risk to
    humans if consumed.

    In addition to GLNPO's monitoring efforts, EPA's Office of Research and
    Development (ORD) funds research activities involving developing
    indicators and Great Lakes monitoring. There are four divisions within
    ORD's National Health Environmental Effects Research Laboratory (NHEERL),
    and one of thesethe Mid-Continent Ecology Division located in
    Duluth, Minnesotaconducts research related to fresh water issues
    involving human health, which includes the Great Lakes. In addition to the
    research conducted by this office, ORD, through its National Center for
    Environmental Research, has an ongoing cooperative agreement with the
    Natural Resources Research Institute (NRRI) of the University of
    Minnesota, Duluth, to develop environmental indicators specifically for
    the nearshore areas of the Great Lakes. Once NRRI develops indicators for
    all of the nearshore areas, the results will be published and submitted to
    ORD for developing an implementation plan measuring environmental
    conditions in the Great Lakes, according to NRRI researchers.

    Two other federal agencies, NOAA and USGS, conduct monitoring for specific
    purposes within the basin. NOAA's Great Lakes Environmental Research
    Laboratory (GLERL) located in Ann Arbor, Michigan, has 15 specific
    legislative mandates for research or monitoring, according to a GLERL
    official. Specific research efforts by NOAA are in areas such as water
    quality, quantity, and levels. NOAA is also developing an experimental
    Great Lakes Observing network. This network will consist of observation
    buoys that are linked to satellites, strategically located throughout the
    five Great Lakes, for collecting specific chemical, physical, and
    biological information needed for ecosystem forecasting. A NOAA prototype
    system is deployed in Lake Erie, using three buoy sites, and focused on
    gathering information on the reemergence of the lake's dead zone.

                            Page 17 GAO-04-1024 Great Lakes
                                                The                             conducts                                                                           sea                                              about              to measure                                                                                                                                                                                           However,
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                                              Great     such as                    Water                                                       monitoring to    trout.                                           to carry              monitoring                              changes                                               Monitoring mix of                                                         the                               for
                                                                                                                                               determine the      This                                                out                                                                                                             by State  activities Organizations
      identifying
         impaired
            water
      bodies, the
    process is
         not done
     consistently
    throughout        of a
    the United     federal
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                   Monitoring

    9GAO, Water Quality: Inconsistent State Approaches Complicate Nation's
    Efforts to Identify Its Most Polluted Waters, GAO-02-186 (Washington,
    D.C.: Jan. 11, 2002).

    Program under the Beach Act. This program involves sampling of only the
    nearshore waters of state beaches for the presence of bacteria to
    determine if the water is safe for swimming.

    In addition, states conduct monitoring in the Great Lakes Basin for state
    requirements. For example, in Ohio, two state agencies-the Ohio
    Environmental Protection Agency and the Ohio Department of Natural
    Resourcesconduct routine monitoring in Lake Erie's nearshore and
    inland areas for several state and federal programs. These agencies
    conduct monitoring to assess water quality in the state's streams and
    rivers, ambient groundwater quality, tributary quality, and changes in
    fish and wildlife populations. Appendix IV contains information on nine
    programs involving monitoring activities in Ohio. In addition to federal
    program monitoring, some states fund and conduct their own monitoring
    activities in the Great Lakes Basin. The extent to which states conduct
    their own monitoring activities beyond federal requirements is closely
    tied to available state funding for monitoring.

    State organizations generally conduct monitoring activities in the
    nearshore or inland areas. For example, Michigan has a state program to
    address water quality issues with funding specifically devoted to
    monitoring. Voters approved a special state bond issue
    authoritythe Clean Michigan Initiativein 1998, which
    provided funding to the Michigan Department of Environmental Quality for
    surface water quality monitoring. Supported by initial Clean Michigan
    Initiative funding in 2000, the Michigan program funds monitoring
    activities in the state's rivers, streams, tributaries, and Great Lakes
    water bodies. Among other things, monitoring is conducted to assess
    contaminant levels in fish and other wildlife, as well as water and
    sediment.

    Multiple restoration goals have been proposed by EPA and other
    organizations that could be a basis for monitoring restoration progress.
    EPA developed basin-wide goals in its Great Lakes Strategy 2002 and goals
    for individual lakes in LaMPs. Other organizations concerned with Great
    Lakes restoration, such as the Council of Great Lakes Governors, have also
    identified basin-wide restoration goals and priorities. Monitoring
    progress toward achieving goals is generally limited to tracking specific
    action items contained in the Great Lakes Strategy 2002; other proposed
    goals do not have associated monitoring activities or monitoring plans to
    determine progress. Additional specifics for many of the proposed goals
    and monitoring plans may be needed if the goals are to be used in
    determining whether progress is being achieved.

      Multiple Goals Exist for Monitoring Restoration Progress

    EPA's Efforts Have Produced Basin-Wide and Lake-Wide Goals

    EPA's efforts in developing the Great Lakes Strategy 2002 and LaMPs have
    resulted in proposed goals for the overall basin and for individual lakes.
    USPCa group of mainly federal and state officials from the Great
    Lakes states coordinated by GLNPOdeveloped and published the Great
    Lakes Strategy 2002, which sets forth 4 overarching goals, 33 subgoals, 23
    objectives, and 103 key actions for the Great Lakes. For example, one goal
    is "to protect human health and restore and maintain stable, diverse, and
    self-sustaining populations of plants, fish and other aquatic life, and
    wildlife in the Great Lakes ecosystem." A key action under this goal is to
    continue human health studies under the Great Lakes Human Health Effects
    Research Program and make the results available to environmental managers
    and the public. For monitoring the progress in achieving the strategy's
    goals, GLNPO is tracking the implementation status of the actions in the
    strategy and, as of May 2003, seven actions were reported by GLNPO as
    completed.

    In addition, EPA has participated in developing LaMPs that are the primary
    means for coordinating and planning ecosystem projects for each lake,
    according to the Great Lakes Strategy 2002. The GLWQA requires that LaMPs
    be developed for each lake, with the United States and Canada responsible
    for preparing the plans in consultation with relevant states and
    provincial governments.10 A GLNPO manager for each LaMP coordinates EPA's
    efforts to develop the plans. In developing LaMPs, the parties have agreed
    that they will report progress every 2 years and that updates to each LaMP
    will be submitted to the IJC for review and comment.

    LaMPs have been prepared for four of the five Great LakesErie,
    Michigan, Ontario and Superiorand they present overviews of lake
    conditions and general restoration needs.11 For example, the Lake Michigan
    LaMP sets forth one overall goalto restore and protect the
    integrity of the Lake Michigan ecosystem through collaborative
    partnerships-and 11 subgoals. These subgoals are stated as general
    questions, such as "can we drink the water," or "can we swim in the
    water." The LaMPs also generally discuss indicators and monitoring, but
    they are not often linked to goals or how progress toward goals will be

    10Lake Michigan lies entirely within the United States and, therefore, EPA
    is solely responsible for the Lake Michigan LaMP under the GLWQA and the
    Clean Water Act.

    11Lake Huron currently has an initiative action plan, which is similar but
    is not considered a LaMP.

    Other Organizations Have Three organizationsthe Council of Great
    Lakes Governors, Great Lakes Developed Basin-Wide Commission, and Great
    Lakes Unitedhave independently of EPA Goals developed goals for
    the Great Lakes Basin. The goals are presented in measured. For example,
    the Lake Erie LaMP states that a working group discussed indicators, but
    none were selected. While each LaMP describes monitoring efforts to some
    extent, they usually do not define how progress to achieve goals will be
    tracked. An exception to this is a section of the Lake Superior LaMP
    addressing critical pollutants. See appendix V for goals and monitoring
    information contained in LaMPs for four of the Great Lakes.

    general terms, such as stopping the spread of invasive species or cleaning
    up contaminated areas. Several of the organizations' goals are similar,
    representing a relative consensus among the organizations. While the goals
    are useful in communicating what specific issues the groups believe are
    important to the Great Lakes, additional specifics, such as which invasive
    species are to be controlled or by what time frame, may be needed to
    determine whether the goals are being achieved. It should be noted that
    these organizations do not have the resources of federal or state agencies
    to address proposed goals and priorities and must rely on others to take
    action. For some of the priorities, specific federal agencies are
    identified to take actions. The goals or priorities developed by the three
    organizations are summarized in appendix VI.

    One recent set of priorities was prepared by the Great Lakes Governors'
    Priorities Task Force, which consisted of governors' representatives for
    the eight Great Lakes states. After deliberating for approximately 2
    years, this group reached consensus in 2003, on nine priorities to guide
    Great Lakes restoration and protection efforts. These priorities addressed
    a range of issues including protecting human health and enhancing
    information collection and standardization. The priorities are defined in
    general terms, such as "control pollution from diffuse sources into water,
    land, and air." Details on the type and causes of pollution to be assessed
    and the desired outcomes are not further defined. After the priorities
    were reported, public sessions were held in Great Lakes states to obtain
    reaction and input on the Governors' goals. These sessions, however, are
    not expected to result in further refinement of the priorities.

    Similarly, the Great Lakes Commission, which includes representatives from
    the eight Great Lakes states and the Canadian provinces of Ontario and
    Quebec, established seven priorities for the Great Lakes such as cleaning
    up toxic hot spots, controlling nonpoint source pollution, and

    preventing the introduction or limiting the spread of invasive species.
    Its report outlining the seven major priorities identifies an overall goal
    for each priority.12 Each of the goals contains recommendations for
    actions, and many goals are stated in general terms with funding requests
    for a particular federal agency or organization for implementation. For
    example, one action item under the goal for cleaning up toxic hot spots
    recommends "ensure that polluters responsible for sediment contamination
    pay their fair share$5 million annually to the U.S. Fish and
    Wildlife Servicefor Great Lakes projects." While the Great Lakes
    Commission lists their seven priorities, it is unclear what specific
    actions are necessary to achieve the priorities.

    Great Lakes United, a binational coalition that promotes citizen action
    and grassroots leadership for Great Lakes environmental activities,
    published a citizen's action agenda for the Great Lakes in 2003. This
    document, and its summary version, describes what members consider to be
    the seven major challenges to be addressed in the Great Lakes, such as
    toxic cleanup, protecting and restoring species, and sustaining and
    restoring water flows.13 Under each challenge, the agenda recommends
    several action items for restoring the Great Lakes Basin. Some of these
    action items have established time frames.

    Coordinating the establishment of measurable goals and developing a
    monitoring system for tracking progress in the Great Lakes are difficult
    tasks that face significant challenges. Of great importance, no single
    organizational entity has exercised leadership responsibility for
    coordinating the establishing of specific goals and a monitoring system.
    As we reported previously, under the Clean Water Act, GLNPO has
    coordination authority over many Great Lakes activities but has not fully
    exercised it. Further, it is uncertain whether the Executive Order issued
    in May 2004, creating a Great Lakes Interagency Task Force, will provide
    the needed stability in leadership.14 Second, the restoration goal setting
    and monitoring efforts ongoing by numerous governmental and
    nongovernmental organizations in the United States and Canada will

      Significant Challenges Exist for Setting Basin-Wide Goals and Developing a
      Monitoring System for the Great Lakes

    12Great Lakes Commission, Great Lakes Program to Ensure Environmental and
    Economic Prosperity (March 2004).

    13Great Lakes United, Citizen's Action Agenda for Restoring the Great
    LakesSt. Lawrence River Ecosystem, and Great Lakes Green Book
    (June 2003).

    14Exec. Order No. 13340, 69 Fed. Reg. 29043 (May 18, 2004).

    create a challenge for coordinating within and between the two countries.
    Specific obstacles include coordinating the goal setting efforts of the
    various Great Lakes organizations and accounting for ongoing agreements
    within Canada when developing the joint monitoring system called for in
    the GLWQA. Third, coordinating information derived from the various
    monitoring activities of the numerous groups involved in the Great Lakes
    is a significant challenge. The lack of a centralized repository of
    monitoring information makes it difficult to assess restoration progress.
    Fourth, because each of the five Great Lakes has unique environmental
    conditions, it will be difficult to establish measurable goals that
    reflect these differences and yet provide consistent basin-wide
    information. One restoration effort, the Chesapeake Bay Program, has
    developed measurable goals and a defined organizational structure that may
    offer valuable lessons for restoration efforts in the Great Lakes.

    Great Lakes Restoration Efforts Lack Clearly Defined Organizational
    Leadership

    Organizational leadership for setting goals and developing a monitoring
    system has yet to be realized for the Great Lakes. Several attempts at
    providing organizational leadership have not resulted in a stable
    structure for leading Great Lakes restoration efforts. We previously
    reported that, within the Great Lakes several entities are involved in
    coordinating and planning, which has resulted in confusion by federal and
    state officials as to which entity bears ultimate responsibility.15 We
    further reported that the responsibility for leading the U.S.'s Great
    Lakes efforts rests with GLNPO and that it is not fully exercising its
    authority under the Clean Water Act for coordinating Great Lakes
    restoration programs. We recommended GLNPO fulfill its coordinating
    responsibilities and develop an overarching Great Lakes restoration
    strategy. EPA promised to provide a detailed response to our
    recommendations, but has not yet done so. However, in 2003 an EPA official
    stated in congressional testimony that the Clean Water Act does require
    EPA, and more specifically GLNPO, to serve as the lead entity for
    coordinating the protection and restoration of the Great Lakes system. The
    same official stated in 2004 congressional testimony that our
    recommendations are answered by the Executive Order and again promised a
    detailed response to these recommendations. However, the Executive Order
    does not address our recommendations.

    As a result of the Executive Order issued in May 2004, which created a
    Great Lakes Interagency Task Force within EPA, how GLNPO's leadership

    15GAO-03-515.

    role and coordination responsibilities will be exercised in the future is
    unclear. Task force members include representatives from EPA, eight other
    federal agencies with Great Lakes program responsibilities, and the
    Council on Environmental Quality. Under the Executive Order, one of the
    purposes of the task force is to coordinate government action associated
    with the Great Lakes. The EPA Administrator chairs the task force that is
    also charged with developing outcome-based goals and collaborating with
    Canada and its provinces and with other binational bodies involved in the
    Great Lakes region regarding policies, strategies, projects, and
    priorities for the Great Lakes. The head of GLNPO, the Great Lakes
    National Program Manager, chairs the working group, and GLNPO staff are to
    assist both the task force and the working group in performing their
    duties. While the Executive Order addresses GLNPO's role with respect to
    the task force and working group, it does not address GLNPO's existing
    responsibilities under the Clean Water Act for coordinating EPA's
    activities with other federal agencies and state and local authorities to
    meet GLWQA goals. The coordination role for the task force under the
    Executive Order is very similar to GLNPO's coordination role under the
    Clean Water Act. However, because the Executive Order does not affect the
    statutory obligations of federal agencies, GLNPO is still under a
    statutory obligation to fulfill its coordination role. Moreover, under the
    Clean Water Act, GLNPO is required to not only develop but also implement
    specific action plans to carry out the responsibilities under GLWQA.
    However, according to the Executive Order, GLNPO will participate on a
    Great Lakes Regional Working Group that is responsible for coordinating
    and making recommendations for implementing the task force polices and
    strategies, but it will be the task force that actually implements
    recommendations.

    Existing coordination activities of USPC are also uncertain in light of
    the Executive Order. The USPC is focused on coordinating federal, state,
    and tribal government activities related to fulfilling the GLWQA, and it
    developed the Great Lakes Strategy 2002 to set restoration goals and
    actions. Membership on the USPC is similar to the newly formed working
    group in that it includes regional federal officials, and the GLNPO
    program manager chairs both groups and also serves as the Acting Assistant
    Administrator for EPA's Office of Enforcement and Compliance Assurance.
    According to the Director of GLNPO, as of July 2004, when the last USPC
    semiannual meeting was held, there were no plans to change the role of the
    USPC. Therefore, the USPC, the task force working group, and GLNPO all
    seemingly are engaged in coordinating federal regional activities in the
    Great Lakes Basin.

    Coordinating Great Lakes research is another responsibility provided to
    the task force under the Executive Order, but other organizations have
    research responsibilities by statute. Specifically, NOAA's Great Lakes
    Research Office, acting through the GLERL and other entities, is
    responsible under the Clean Water Act for conducting Great Lakes research
    and monitoring activities and annually reporting issues, on which Great
    Lakes research is needed, to the Congress.16 Each year GLERL and GLNPO are
    to prepare a joint research plan and to provide a health research report
    to the Congress. Thus far, GLERL and GLNPO have not prepared these plans
    or reported to the Congress because funds were not requested or provided
    for the coordination and reporting activities, according to agency
    officials. The GLERL Director stated that they have about 15 specific
    legislative mandates involving Great Lakes research. Coordinating and
    prioritizing research is also an activity of the IJC's binational Council
    of Great Lakes Research Managers. This council, established in 1984,
    proposes priority research areas for the Great Lakes, and some of the
    proposals are priorities for GLERL, in part, because the council is
    currently co-chaired by the GLERL Director. Future councils, however, may
    not be co-chaired by the GLERL Director, and priority research areas may
    not be addressed because research managers are not bound to follow council
    priorities.

    Finally, the creation of the task force and working group by the Executive
    Order also raises questions about the permanency of this organizational
    structure for addressing the long-term restoration needs of the Great
    Lakes. Executive orders, such as the one creating the task force, stay in
    effect despite changes in administrations, but they may be amended or
    rescinded by a subsequent President. Moreover, the Executive Order cannot
    be enforced in court, unlike statutory provisions that can often be
    judicially enforced. Therefore, the task force may prove to be a temporary
    rather than a permanent attempt at coordinating and developing goals for
    the Great Lakes. Legislation was proposed in 2004 to enact the provisions
    of the Executive Order into law, but this legislation remains pending in
    the Congress.

    1633 U.S.C. S: 1268(d).

    Coordinating Restoration Goals and Monitoring Activities within the United
    States and Canada Poses Challenges for a Basin-Wide Approach

    Many organizations participating in the restoration of the Great Lakes
    have independently developed goals for the Great Lakes Basin. However,
    these organizations have tended to develop goals independently of EPA and
    one another, resulting in duplicative efforts and the lack of
    prioritization of goals. We previously reported that the numerous
    restoration strategies containing goals developed by various organizations
    did not provide an overarching approach that can be used as a blueprint to
    guide overall restoration activities.17 The situation remains the same
    today with several organizations developing strategies and goals, without
    clearly defined leadership responsibilities to bring together or
    coordinate the various efforts. In some cases, the goals developed are
    very similar to each other. For example, the Council of Great Lakes
    Governors and the Great Lakes Commission both have similar goals relating
    to cleaning up of areas of concern18 and stopping the spread of invasive
    species. Yet, consensus has not been reached by the various organizations
    as to specifically how such goals should be measured.

    The leadership to coordinate goal setting efforts has not yet
    materialized. There is no one organization or group of organizations that
    is recognized as the leader. For example, at a Senate hearing on Great
    Lakes restoration efforts in 2003, the hearing chairman asked a panel of
    federal agency officials, including the Great Lakes National Program
    Manager, if there was an orchestra leader for the efforts in the Great
    Lakes, and none of the panel members volunteered a response. Similarly,
    during an IJC conference session in 2003, where the leadership for the
    various Great Lakes organizations was addressed, the Great Lakes National
    Program Manager stated that because of the number of groups involved in
    the Great Lakes, there is a need to find a way to work together toward
    goals; however, he was reluctant to lead this effort. The recently created
    Great Lakes Interagency Task Force was charged with establishing a process
    for collaboration among task force members to, among other things, develop
    outcome-based goals for the Great Lakes system. The desired outcomes are
    conditions such as cleaner water or sustainable fisheries.

    Federal and state program officials acknowledge that limited coordination
    of monitoring activities now exists and that there is no single
    organization in place to direct the coordination of monitoring efforts.
    One attempt to coordinate monitoring involving research vessels on the
    Great Lakes

    17GAO-03-515.
    18Areas of concern are specific areas of contamination in the Great Lakes.

    began in 1997, by the IJC's Council of Great Lakes Research Managers. The
    impetus for this effort was that over 60 research vessels were operating
    independently in the basin without coordination or collaboration and with
    limited monitoring funds. Since that time the IJC has been developing an
    inventory of Great Lakes research vessels that was placed on a Web site
    designed to identify the ships, scientific equipment, general research
    schedules, and points of contact to aid in coordinating operations and
    sharing resources. The extent that this inventory has facilitated
    coordination has yet to be determined, however, coordination has begun
    through sharing of information on research vessels, according to an IJC
    official.

    Further, existing agreements on restoration goals and monitoring between
    Canada and its provincial governments of Ontario and Quebec will need to
    be considered in developing basin-wide goals if a joint U.S.-Canada
    monitoring system is to be developed as required under the GLWQA. Four of
    the five Great Lakes are shared by the United States and Canada and share
    many of the same environmental problems. The restoration goals and
    monitoring efforts developed in Canada to address these problems are
    important for a coordinated effort by the two countries. One set of goals
    to consider are in an agreement reached in 2002, between the governments
    of Canada and Ontario on overall goals and actions to be taken to protect,
    restore, and conserve the Great Lakes Basin ecosystem. This
    agreementthe Canada-Ontario agreementcontains four annexes
    that address areas of concern, harmful pollutants, lakewide management,
    monitoring, and information management. Each annex contains overall goals
    to be achieved over a 5-year period and results that the parties have
    agreed to achieve together or individually. For example, one result under
    the lakewide management annex is "reductions in the release of harmful
    pollutants on a lake-by-lake basis."

    Another agreement containing goals that should be considered involves
    restoring the St. Lawrence River. This agreement-the St. Lawrence Action
    Plan-was reached in 1988, between officials of Canada and the province of
    Quebec and was a 5-year plan to address major problems of industrial
    pollution threatening natural habitats. While the St. Lawrence River is
    not geographically part of the Great Lakes Basin, it is the connecting
    channel from Lake Ontario to the Atlantic Ocean, and Quebec
    representatives participate in several of the organizations and activities
    involving the Great Lakes such as the BEC, SOLEC, and the Council of Great
    Lakes Research Managers. Since the first 5-year plan in 1988, subsequent
    5-year agreements, referred to as phases, have focused on specific
    environmental priorities. The most recent agreement, Phase III,

    also referred to as the St. Lawrence Vision 2000, has three major
    objectives: protecting ecosystem and human health, involving riverside
    communities in the process of helping to make the St. Lawrence more
    accessible, and recovering its former uses. An updated agreement, Phase
    IV, was being developed as of July 2004.

    In addition to agreements, Canada and the two provinces have ongoing
    monitoring activities that provide information on environmental conditions
    in the Great Lakes Basin that will need to be considered in developing a
    joint basin-wide monitoring system. For example, the Ministry of the
    Environment, Ontario, conducts a Great Lakes nearshore monitoring and
    assessment program that contains five monitoring efforts. One of these
    involves sampling water quality at 66 sites within the basin on a rotating
    basis to determine how water quality is changing over time. Another
    component of the Ontario program is monitoring of Great Lakes tributaries
    for toxic contaminants. This monitoring is done to identify those
    tributaries to each lake having significant concentrations of persistent
    bioaccumulative substances, such as pesticides. In addition to monitoring
    conducted by the province of Ontario, monitoring and reporting is done by
    Conservation Authorities within the province. The Authorities consist of
    36 local community-based organizations established by provincial
    legislation that manage watersheds throughout Ontario. The Authorities'
    monitoring efforts are concentrated on tributary, stream, and inland areas
    of the Great Lakes Basin, and reports are issued to the public on the
    state of the watersheds.

    For the St. Lawrence River in Quebec, a monitoring component for the St.
    Lawrence Vision 2000 plan was developed by two Canadian federal agencies,
    the Quebec Ministry of Environment and a nongovernmental organization, to
    provide information on the environmental conditions in the St. Lawrence
    River Basin. The program began in 2003, with the four parties agreeing to
    conduct 21 monitoring activities until 2010, to analyze and report on the
    results. The 21 activities are ongoing activities by governmental
    organizations and were selected based on the descriptive information
    provided on St. Lawrence conditions. Several environmental issues are
    addressed, such as contamination of water, sediments, and biological
    resources by toxic substances. To better integrate the ongoing monitoring
    activities of the different organizations, the parties agreed to improve
    the spatial and temporal coverage of certain indicators, develop new
    indicators, and strive for better collaboration.

    In addition to efforts conducted by the provinces and others, EC conducts
    monitoring in open lake waters, connecting channels, and tributaries of

    the Great Lakes Basin. Open lake monitoring is conducted at various sites
    for ensuring compliance with GLWQA water quality objectives, evaluating
    trends, and identifying emerging issues. The monitoring focuses on two
    lakes each year, with the exception of Lake Michigan where it is the
    responsibility of the United States, to gather information on
    contaminants, nutrients, metals, and physical parameters at specific
    locations in each lake. Other monitoring programs involve pesticides and
    emerging chemicals monitoring in selected watersheds and embayments, and
    water quality monitoring of the Niagara, St. Lawrence, St. Clair, and
    Detroit Rivers. For example, the monitoring of the Niagara River is done
    as part of an agreement reached between EC, EPA, Ontario Ministry of
    Environment, and the New York Department of Environmental Conservation to
    reduce toxic chemical pollutants in the Niagara River. Monitoring is done
    at an upstream location near Lake Erie and downstream near Lake Ontario.

    Lack of Centralized Information from Monitoring Activities Makes
    Coordination to Assess Restoration Progress Difficult

    There is currently no centralized repository of information on monitoring
    activities. As a result, it is difficult to coordinate existing data and
    determine what additional information is needed to establish baseline
    conditions and assess progress toward restoration goals. Two related
    efforts are, however, under way to develop inventories of the existing
    monitoring programs within the Great Lakes. One effort is being led by the
    Great Lakes Commission, funded by grants from the Joyce Foundation and
    GLNPO, to develop a comprehensive inventory of environmental monitoring
    programs in the Great Lakes Basin. Information is being gathered from
    existing sources and through surveys and interviews with program
    officials. The information will be placed in a database, analyzed to
    identify monitoring gaps in existing programs, and used by the BEC to
    develop a monitoring coordination framework, according to Great Lakes
    Commission officials. This project, however, was funded on a one-time
    basis and does not include plans for updating the inventory of monitoring
    data.

    A related effort is being conducted by GLNPO and EC under the direction of
    the BEC and is focused on developing an Internet-based inventory of
    existing monitoring systems. The inventory will not contain monitoring
    data, but rather a database of monitoring sources, referred to as metadata
    by GLNPO officials.19 The inventory of existing monitoring sources will

    19Metadata are data about databases describing various attributes such as
    who is responsible for the database and the data content.

    rely on common data fields and terminology for standardization of
    information, and GLNPO plans to manage the database. To create the
    database, the BEC will request the various federal and state agencies and
    other organizations conducting monitoring activities to input information
    into the database, according to GLNPO officials. Ultimate responsibility
    for data completeness and quality rests with the BEC. However, it is
    unclear how this will be accomplished since the BEC has limited resources
    to carry out this responsibility. Further, since the input and annual
    update of monitoring information is voluntary, it is unclear how a
    complete and accurate inventory can be assured since there is no
    independent verification of the data. GLNPO officials stated that, as of
    July 2004, the Web-based system is developed, and they are awaiting
    organizations to enter information on monitoring systems into the
    database.

    Unique Environmental Conditions for Each Lake Makes Setting Basin-Wide
    Goals Difficult

    While basin-wide goals are useful, existing goal-setting efforts are
    complicated by the unique characteristics of each lake. The physical
    magnitude of the basin is often recognized as a daunting challenge for
    setting measurable restoration goals. Although the Great Lakes are
    connected through rivers and channels, they are not one contiguous water
    body but rather distinct lakes with unique environmental conditions. The
    Great Lakes Basin area spans 750 miles and has multiple environmental
    challenges. This presents challenges to setting goals and developing a
    monitoring system that can be used to describe restoration progress across
    the basin and also capture the uniqueness of each lake. The distinct
    physical characteristics of the lakes are illustrated by the differences
    between Lakes Superior and Erie. (See fig. 3.)

        Figure 3: Differences in Characteristics of Lake Superior and Lake Erie

    Lake Superior is a larger, deeper lake with a relatively sparse human
    population within its watershed. Most of the shoreline of Lake Superior is
    forested and not host to the extensive urban development along its shores
    that Lake Erie has. For Lake Superior, the overarching concern is to
    preserve current conditions and keep pollutants and invasive species from
    entering the lake. Lake Erie has other unique environmental problems, the
    most recent being the reemergence of a dead zone in the central basin of
    the lake that is void of oxygen and cannot support aquatic life. Recently,
    the phosphorus levels of the lake have exceeded acceptable levels as the
    result of unknown causes. Research efforts are now focused on determining
    the cause of the rise in phosphorous levels, which cause harmful algae
    blooms. Because Lake Erie is the shallowest of the Great Lakes and is
    subject to urban pressures, it is sometimes cited as the lake that first
    develops environmental problems within the Great Lakes Basin.

    The differences between the Great Lakes pose a challenge to setting
    basinwide goals. While goals are needed to determine basin-wide progress,
    goals for each lake are also needed to address specific problems or public
    concerns for each lake. For Lake Superior, a major concern is stopping
    pollutants from entering the lake, which is addressed through a program
    that established a goal of zero-discharge for point source pollutants.20
    For Lake Erie, goals developed by the Lake Erie Commission address other
    problems, such as how remediating contaminated sediments in Lake Erie's
    harbors and tributaries. The future challenge will be how to build on the
    existing goal-setting efforts for each lake in developing measurable goals
    for the Great Lakes Basin as a whole.

    Chesapeake Bay Program May Offer Lessons Learned for Developing an
    Organizational Structure and Setting Restoration Goals

    The Chesapeake Bay Program, a restoration effort lead by EPA, has
    demonstrated that quantifiable and prioritized goals with definitive time
    frames can be developed for measuring restoration progress. While the
    Great Lakes have unique challenges, such as coordination with Canada, the
    bay program also provides an example of how an organizational structure
    can be created to successfully coordinate goal setting.

    Unlike the restoration goals prepared for the Great Lakes, the Chesapeake
    Bay Program has specific, measurable goals with definitive time frames

    20Point source pollutants are those that contribute pollutants directly to
    a body of water from a pipe or other discrete conveyance.

    that are linked to indicators and a monitoring and modeling program.21
    Overall goals developed for the program are stated in a general fashion
    similar to many developed for the Great Lakes and are to (1) address water
    quality and clarity problems caused by excess nutrients, sediments, and
    toxics; (2) maintain and restore living resources of the bay, such as
    controlling exotic species and protecting crabs and oysters; (3) protect
    and restore vital habitats, such as wetlands and submerged aquatic
    vegetation; (4) make sound land use decisions, such as land conservation;
    and (5) engage the community through education and outreach. However, the
    general goals are further defined as specific commitments that are used to
    measure program progress.

    As of December 2003, the program was endorsing over 40 measurable
    environmental commitments for the watershed. The program has prioritized
    commitments included in the most recent bay agreement, Chesapeake 2000, by
    identifying the 10 most important "keystone commitments" for the bay for
    focusing their efforts on critical needs and making the best use of
    resources and capabilities. For example, one keystone commitment for the
    overall goal of maintaining and restoring living resources in the bay, is
    that by 2010, at a minimum, a tenfold increase in native oysters should be
    achieved in the Chesapeake Bay, using a 1994 baseline. In addition, this
    commitment involves developing appropriate research and management
    strategies for attaining this increase.

    According to program officials, defining measurable goals and commitments
    up front is the key to the success of the Chesapeake Bay Program. If the
    goals are developed first, then they can be linked to the appropriate
    measurement and tracking activities and indicators to evaluate progress.
    Once program officials analyze the data collected from monitoring,
    modeling, and tracking programs to determine progress, they can decide on
    the appropriate actions to take to maintain or improve conditions.
    Officials from organizations involved in the restoration and protection of
    the bay agree that defining goals up front is important to the restoration
    effort and that the Chesapeake Bay Program has done a good

    21The Chesapeake Bay Agreement in 1983 established the Chesapeake
    Executive Council to assess and oversee the implementation of coordinated
    plans to improve and protect the water quality and living resources of the
    Chesapeake Bay estuarine systems. Subsequent Chesapeake Bay agreements in
    1987, 1992, and 2000 defined the agenda for the Chesapeake Bay Program
    setting forth strategic plans with measurable goals and objectives for the
    bay watershed.

    job in this regard. For example, an official from the Chesapeake Bay
    Foundationthe largest conservation organization dedicated to
    saving the Chesapeake Bay watershedstated that the Chesapeake Bay
    Program does a good job in establishing clearly defined goals and
    commitments and linking them to indicators and monitoring to reflect the
    current overall conditions of the bay. In addition, State of Maryland
    officials from the Department of Environment and Department of Natural
    Resources stated that the goals and commitments of the program mirror
    those established by the state and that they are adequately linked to the
    monitoring and indicators used by the program. Recently, however, concerns
    were raised regarding how accurately the program's computer model
    estimates projected reductions in nutrients. According to one program
    official, the controversy highlights the need for reaching consensus on
    appropriate measurement approaches and the need for peer review of all
    monitoring and modeling protocols.

    Finally, the program is an example of how a permanent organizational
    structure was established to set measurable goals and to coordinate
    restoration efforts. The organizational structure of the Chesapeake Bay
    Program is founded on an agreement between three states, the District of
    Columbia, and EPA with an executive council leading the program. This
    council consists of three governors, the Mayor of the District of
    Columbia, EPA's Administrator, and a representative from the Chesapeake
    Bay Commission. The council establishes measurable program goals and
    commitments in such areas as water clarity after receiving input from
    several program committees and subcommittees. Restoration and monitoring
    efforts are coordinated by a number of written agreements between federal
    agencies and other organizations to focus resources in certain areas, such
    as an agreement between the FWS and EPA to provide technical assistance
    for various activities including habitat classification and mapping,
    resource assessments, and field surveys and inventories.

                                      Conclusions

    A clearly defined organizational leadership structure is needed for
    restoring the Great Lakes and in particular for developing measurable
    basin-wide goals and a monitoring system as called for in the GLWQA and
    the Clean Water Act. Several organizations have offered basin-wide goals
    over the years, but none are guiding restoration efforts and measurable
    progress remains an elusive information component. The required monitoring
    system has not been fully developed and the vision of having information
    to guide restoration efforts remains unfulfilled. While the recent
    Executive Order creates a Great Lakes Interagency Task Force within EPA to
    develop measurable goals and coordinate federal activities,

      Matter for Congressional Consideration

    it is uncertain whether this task force will provide definitive, stable
    leadership needed over time because it may be readily changed by future
    executive orders. Additionally, while GLNPO has existing statutory
    responsibility for coordinating Great Lakes activities, it is unclear how
    its responsibilities and those of other organizations fit with the
    coordination activities of the new task force. EPA is now taking steps to
    implement the Executive Order; however, it is unclear whether this
    fulfills its responsibilities under the Clean Water Act. Absent a clearly
    defined leadership structure, setting measurable goals and monitoring
    progress in the Great Lakes is unlikely to be accomplished, and
    duplicative responsibilities for coordination, goal setting, and
    monitoring may be inevitable. EPA has recently demonstrated leadership on
    monitoring by developing an inventory of all monitoring activities in the
    Great Lakes. While we believe this is a worthwhile effort, controls should
    be in place to ensure the completeness and accuracy of the data in the
    inventory.

    In light of the uncertainty regarding how GLNPO's responsibilities fit
    with the newly created Great Lakes Interagency Task Force and to help
    ensure the coordination of U.S. efforts in developing basin-wide
    measurable restoration goals for the Great Lakes, as well as the
    development of a joint monitoring system based on those goals, the
    Congress may want to consider

    o  	clarifying whether GLNPO or the task force should lead the U.S.
    efforts in restoring the Great Lakes and requiring this entity, in
    consultation with Canada, the governors of the Great Lakes states, federal
    agencies, and other organizations, to develop and prioritize specific
    measurable restoration goals for the Great Lakes Basin within a certain
    time frame; and

    o  	requiring the entity to develop and implement monitoring activities to
    measure progress toward attaining goals and identify actions that could
    assist in achieving these goals.

    If the Congress decides that the task force should have the leadership
    role, it may also want to consider whether additional Great Lakes Basin
    stakeholders should be task force members, such as representatives of
    states and other organizations.

    Recommendation for Executive Action

      Agency Comments and Our Evaluation

    To facilitate the coordination of monitoring activities by the various
    federal, state, and other organizations within the Great Lakes Basin, we
    recommend that the EPA Administrator direct GLNPO to develop adequate
    controls for the inventory of monitoring systems to ensure that inventory
    data is accurate, current, and complete so as to facilitate users' efforts
    to coordinate monitoring activities.

    GAO provided EPA with a draft of this report for its review and comment.
    The agency generally agreed with the findings and recommendations in the
    report. EPA stated that the inventory of monitoring activities is a
    critical component for monitoring and reporting efforts, and adequate
    controls are needed to ensure that data are accurate, current, and
    complete in order to facilitate users' efforts to coordinate monitoring
    activities. Accordingly, EPA stated it has begun taking steps to develop
    these controls. Specifically, GLNPO will lead the U.S. efforts to track
    entries into the inventory database to ensure that data from all agencies
    are included. GLNPO will also request annual verification and updating by
    organizations of their information to ensure that the database is accurate
    and current. If effectively implemented, these steps should help ensure
    the accuracy and usefulness of the inventory for coordination purposes.
    Regarding our matter for the Congress to consider clarifying leadership
    responsibilities, EPA stated that it believes the responsibilities for
    organizational leadership in the Great Lakes for both GLNPO and Great
    Lakes Interagency Task Force are clearly stated in the Clean Water Act and
    the Executive Order, respectively. While EPA describes the overall
    structure and responsibilities of the task force and GLNPO to support its
    position, it does not address our concern that similar coordination
    responsibilities are assigned to different organizations under the
    Executive Order and the Clean Water Act. EPA states that the Executive
    Order appoints the Great Lakes National Program Manager as chair of the
    Great Lakes Regional Working Group and that this will enhance GLNPO's
    ability to meet its statutory obligation to coordinate federal restoration
    activities. However, this does not address our point that the Clean Water
    Act assigns GLNPO the responsibility of implementing specific action plans
    to carry out U.S. responsibilities under the act, while under the
    Executive Order, it is the task force, not GLNPO that will implement
    recommendations of the working group. Further, EPA did not address our
    concern that the task force does not provide the definitive, stable
    leadership that is needed over time given that its responsibilities may be
    changed by future executive orders. The full text of EPA's comments is
    included in appendix VII.

    As agreed with your offices, unless you publicly announce the contents of
    this report earlier, we plan no further distribution until 30 days from
    the report date. At that time, we will send copies of this report to
    appropriate Congressional Committees; the EPA Administrator; various other
    federal departments and agencies; and the International Joint Commission.
    We also will make copies available to others upon request. In addition,
    the report will be available at no charge on the GAO Web site at
    http://www.gao.gov.

    If you or your staff have any questions, please call me at (202) 512-3841.
    Key contributors to this report are listed in appendix VIII.

    John B. Stephenson Director, Natural Resources and Environment

    List of Congressional Requesters

    The Honorable Mike DeWine United States Senate

    The Honorable Russell Feingold United States Senate

    The Honorable Carl Levin United States Senate

    The Honorable Debbie Stabenow United States Senate

    The Honorable George Voinovich United States Senate

    The Honorable John Conyers, Jr. House of Representatives

    The Honorable John Dingell House of Representatives

    The Honorable Rahm Emanuel House of Representatives

    The Honorable Vernon Ehlers House of Representatives

    The Honorable Marcy Kaptur House of Representatives

    The Honorable Dale Kildee House of Representatives

    The Honorable Ron Kind House of Representatives

    The Honorable Mark Kirk House of Representatives

    The Honorable Dennis Kucinich House of Representatives

    The Honorable Steven LaTourette House of Representatives

    The Honorable Sander Levin House of Representatives

    The Honorable Candice Miller House of Representatives

    The Honorable James Oberstar House of Representatives

    The Honorable Jack Quinn House of Representatives

    The Honorable Bart Stupak House of Representatives

                           Appendix I: Scope and Methodology

    To determine the extent to which information derived from monitoring is
    useful for assessing overall conditions in the Great Lakes Basin, we
    gathered and analyzed information on efforts to develop indicators through
    the State of the Lakes Ecosystem Conferences (SOLEC), which is a jointly
    sponsored effort by EPA's Great Lakes National Program Office (GLNPO) and
    Environment Canada (EC). We also gathered and analyzed information on
    monitoring activities obtained from state agency officials in each of the
    eight Great Lakes statesIllinois, Indiana, Ohio, Michigan,
    Minnesota, New York, Pennsylvania, and Wisconsin; eight federal agencies;
    two Canadian federal agencies; and provincial agencies in Ontario and
    Quebec, Canada. For each agency, we obtained information about ongoing
    monitoring efforts including the purpose of the monitoring efforts, type
    of information collected during monitoring, how the information was
    analyzed and used, and how monitoring was coordinated with other federal
    or state agencies. A detailed listing of the federal, state, and Canadian
    agencies that provided monitoring information is included as appendix II.
    We reviewed the monitoring requirements contained in the Great Lakes Water
    Quality Agreement (GLWQA) and compared these requirements with the ongoing
    monitoring activities.

    To identify existing restoration goals and whether monitoring is done to
    track goal progress, we obtained and analyzed Great Lakes restoration
    goals prepared by several organizations including the Council of Great
    Lakes Governors, Great Lakes Commission, Great Lakes United, and U.S.
    Policy Committee. We analyzed the goals contained in the Great Lakes
    Strategy 2002 and reviewed information on monitoring the progress in
    achieving the goals. We further reviewed the restoration goals and
    monitoring efforts contained in Lakewide Management Plans (LaMP) prepared
    for four of the five Great Lakes. We interviewed LaMP managers to
    determine the process followed for setting goals and related monitoring
    activities. We also interviewed officials conducting the monitoring for
    the Great Lakes Strategy 2002 and reviewed monitoring progress reports.

    To identify major challenges to setting restoration goals and developing a
    monitoring system for the Great Lakes, we identified barriers to
    accomplishing these tasks and gathered information on four major
    challenges involving organizational responsibilities, coordination of
    monitoring activities with Canada, centralized information on monitoring
    activities, and unique lake environmental conditions. We gathered and
    analyzed information on existing organization responsibilities, including
    those established by the GLWQA, statutes, and administrative decisions,
    along with the organizational responsibilities set forth in a May 2004
    executive order. We interviewed officials and gathered information from

    Appendix I: Scope and Methodology

    EC, the Ontario Ministry of Natural Resources and Ministry of the
    Environment, and the Quebec Ministry of Environment to identify their
    ongoing monitoring activities and challenges to Canada's participation in
    developing and implementing a comprehensive monitoring system for the
    Great Lakes. We identified and analyzed efforts for inventorying and
    coordinating monitoring activities in the Great Lakes Basin and obtained
    and analyzed information on a proposed Web based inventory of monitoring
    efforts from GLNPO officials. We obtained and analyzed documentation about
    the environmental conditions for each of the Great Lakes and discussed
    with federal and state officials the difficulties in developing a
    basin-wide monitoring system. Finally, we gathered information on goals,
    monitoring, and the organizational structure for the Chesapeake Bay
    Program. We interviewed program, state, and nonprofit officials about how
    goals were developed, monitored, and results communicated.

    We performed our work from August 2003 to May 2004 in accordance with
    generally accepted government auditing standards.

    Appendix II: Federal, State, Canadian, and Other Organizations That Provided
    Great Lakes Monitoring and Research Information

    Federal Agencies

    o   o   o   o

    o   o

    o

    o

    Environmental Protection Agency

    Great Lakes National Program Office
    Office of Research and Development
    Chesapeake Bay Program
    Region V

    Department of Interior

    U. S. Fish and Wildlife Service
    U. S. Geological Survey

    Department of Commerce

    National Oceanic and Atmospheric Administration

    Department of Agriculture

    Forest Service

    State Agencies

    o

    o

    o   o

    o

    o

    Illinois

    Illinois Environmental Protection Agency

    Indiana

    Indiana Department of Environmental Management

    Ohio

    Ohio Environmental Protection Agency Ohio Department of Natural Resources

    Michigan

    Michigan Department of Environmental Quality

    Minnesota

    Minnesota Pollution Control Agency

    New York

    Appendix II: Federal, State, Canadian, and Other Organizations That
    Provided Great Lakes Monitoring and Research Information

    o  	New York State Department of Environmental Conservation Pennsylvania

    o  	Pennsylvania Department of Environmental Protection Wisconsin

    o  Wisconsin Department of Natural Resources Canadian Agencies  o
    Environment CanadaOntario Region

    o  Environment CanadaQuebec Region

    o  Ontario Ministry of Natural Resources

    o  Ontario Ministry of the Environment

    o  Ontario Great Lakes Fisheries Management

    o  Conservation Ontario

    o  Quebec Ministry of the Environment

    Other Organizations  o  Great Lakes Commission

    o  The Nature Conservancy

    o  Great Lakes Cities Initiative

    o  International Joint Commission

    o  University of Minnesota's Natural Resources Research Institute

    Appendix III: Comments by Officials on Need for Indicators and Monitoring in the
    Great Lakes Basin

    Nearly all of the officials we contacted endorsed the need for a
    comprehensive surveillance and monitoring system and their comments
    include why a system is needed or factors to consider in developing a
    system. See table 1 for a summary of these comments.

         Table 1: Summary Comments by Officials on the Need for Indicators and
     Comprehensive Monitoring in the Great Lakes Basin Agency/organization Comments

    Department of Interior: U. S. Geological Survey (USGS)

    o  	A comprehensive surveillance and monitoring system with indicators is
    needed and should be developed cooperatively between federal and state
    agencies.

    o  	No one agency has the capability to adequately monitor and assess the
    Great Lakes ecosystem.

    o  	The Environmental Protection Agency's (EPA) Great Lakes National
    Program Offices' (GLNPO) strength is in open lake surveillance monitoring,
    but the other agencies like USGS that have expertise in tributary,
    wetland, and groundwater issues should come together to develop a
    monitoring system.

    USGSGreat Lakes Science Center  o  	A comprehensive surveillance
    and monitoring system and indicators are necessary for the Great Lakes.

    o  	The Great Lakes Science Center integrates monitoring systems and
    indicators with scientifically based proactive research; a similar
    approach should be used to develop a comprehensive system.

    Department of Commerce: National Oceanic and Atmospheric Administration
    (NOAA)

    o  	It is strongly believed that a comprehensive surveillance and
    monitoring system, with indicators, is needed for the Great Lakes.

    o  	The International Joint Commission's (IJC) Science Advisory Board
    recommended that the U.S. and Canadian governments, while considering
    revisions to the Great Lakes Water Quality Agreement (GLWQA), consider
    requiring implementation of a systematic, science-based program that has
    data quality objectives and data collection plans driven by ecosystem
    behavior and contaminant fate and develop binational surveillance programs
    for water quality management similar to the Integrated Atmospheric
    Deposition Network.

                       Department of Interior: Fish and Wildlife

    Service

    o  	A well-coordinated, comprehensive basin-wide surveillance and
    monitoring system with indicators for the Great Lakes is needed to measure
    outcomes of programs, public investment, and status of ecosystem health,
    while targeting actions strategically and allowing for informed
    environmental decisions.

    o  	A real-time comprehensive system of mapping, modeling, and statistical
    assessment is needed to evaluate conservation and restoration efforts.

    Department of Agriculture:  o  It would be valuable to have comprehensive
    monitoring of social, economic, and Forest Service environmental
    conditions in the Great Lakes Basin.

    o  Data of this kind, consistently collected at regular intervals, is
    rare.

    o  	Comprehensive monitoring could cover the range of economic sectors; be
    grounded in suitable scientific disciplines; and address information needs
    of city, county, state, and federal governments, as well as other
    agencies, organizations, and individuals that invest resources for public
    benefit.

    Appendix III: Comments by Officials on Need for Indicators and Monitoring
    in the Great Lakes Basin

    Agency/organization Comments

    Environmental Protection Agency: GLNPO  o  	A comprehensive surveillance
    and monitoring system, with associated environmental indicators, is
    necessary for the Great Lakes if we are to be able to track environmental
    trends, understand emerging threats to the ecosystem, implement
    appropriate control strategies, and assess the effectiveness of our
    programs.

    o  	With programs such as the State of the Lakes Ecosystem Conference
    (SOLEC), the Binational Executive Committee's inventory of monitoring
    programs, and the Presidents' recently signed an executive order calling
    for a Great Lakes Interagency Task Force to plan and coordinate Great
    Lakes activities, improvements are expected.

    Illinois Environmental Protection Agency  o  	A comprehensive surveillance
    and monitoring system with indicators is needed and should be developed as
    a joint effort of the Great Lake states, GLNPO, the Great Lakes
    Commission, and others, including university researchers, to identify
    current and future potential problems, develop and implement monitoring
    strategies, and seek options for both short-term and long-term problem
    resolution.

    Indiana Department of Environmental Management

    Michigan Department of Environment Quality

    Minnesota Pollution Control Agency

    New York State Department of Environment Conservation

    o  	A comprehensive surveillance and monitoring system with indicators is
    needed. It should be developed in a cooperative effort by EPA Region 5 and
    GLNPO, the International Joint Commission, the Great Lakes Commission,
    Environment Canada, and the EPA Region 5 states.

    o  	A comprehensive monitoring system for the Great Lakes is needed;
    however, such a system must be developed with involvement from all parties
    that have a stake in what happens in the Great Lakes.

    o  	Each lake must be looked upon individually when it comes to indicators
    because of their differences. One set of indicators will not fit all the
    lakes.

    o  	To address environmental conditions and know if things are getting
    better or worse requires quantitative answers to specific problems related
    to each individual lake.

    o  	A comprehensive system is needed, but it must address both ambient
    indicators such as fish, water, and beaches and the source indicators
    needed to assess regional progress. The system should also be flexible
    since there is no single set of indicators that apply to all the lakes.

    o  	A lake trout indicator for Lake Superior might not be appropriate for
    Lake Erie, and a yellow perch indictor well suited for Lake Erie would not
    make sense for Lake Superior. The system should also use existing
    monitoring and indicator systems as much as possible.

    o  	A comprehensive system is needed, but it must be mandated by law and
    adequately funded to support staff and equipment resourcing, analytical
    analysis, and reporting over a long-term period.

    Ohio Environmental Protection Agency  o  It is important for the Great
    Lakes to have a long-term surveillance and monitoring and Ohio Department
    of Natural system with indicators. Appropriate indicators are probably the
    most important things

    Resources needed.

    o  	A carefully chosen set of indicators that provide the best information
    on the state of the lakes should be established before the monitoring
    program is designed. We need to know the reasons why we should monitor.

    o  	Comprehensive monitoring for surface and groundwater in the Great
    Lakes basin is needed to understand the availability, limits and impacts
    of water withdrawals, as well as to support science-based decision making
    under the agreement.

    Appendix III: Comments by Officials on Need for Indicators and Monitoring
    in the Great Lakes Basin

    Agency/organization Comments

    Pennsylvania Office of Environmental  o  There are a number of systems
    already in place to survey and monitor environmental Protection parameters
    within the Great Lakes, such as SOLEC and Lakewide Management Plans
    (LaMP).

    o  	The bigger problem is in coordinating the surveillance and monitoring
    and having enough resources to do a comprehensive job. A lot of resources
    go into monitoring and surveillance, but the results are not always shared
    with those who need the information.

                            Wisconsin Department of Natural

    Resources

    o  	One environmental official believes existing systems are adequate to
    accomplish the stated tasks. Instead, better acceptance is needed by
    concerned agencies and a willingness to provide funds for efficient and
    technically credible monitoring efforts.

    o  	Another environmental official believes some surveillance and
    monitoring is needed; however, it should involve a limited number of
    indicators and biological measures established by system ecologists as a
    starting point. More in-depth comprehensive surveillance and monitoring
    should be targeted to problem areas and resource

    a

                      management concerns across the Great Lakes.

    Great Lakes Commission  o  	There is a great need for a comprehensive
    monitoring plan for the Great Lakes, but to be effective it must have
    buy-in from all federal state and local organizations with responsibility
    for activities in the Great Lakes.

    o  	The GLWQA is believed to be the tool needed to harmonize the U.S. and
    Canadian governments' objectives for the Great Lakes; however, a
    comprehensive indicator and monitoring system is required to accomplish
    this.

    Nature Conservancy  o  	The lack of monitoring activity is a problem
    throughout the ecosystem, and the development of a comprehensive
    monitoring system is becoming more and more important each day. However,
    monitoring must be based on documented and tested scientific information
    because of the turnover of staff personnel in environmental and
    conservation areas.

    Great Lakes Cities Initiatives  o  	Because of philosophical differences
    and complexities among Great Lakes Governors, monitoring at the state
    level is even more difficult and requires the input of city mayors. There
    is a grave need for someone to set priorities for restoration activities.

    o  	With tight state budgets, there must be a collective body to set
    priorities and oversee projects to prohibit duplicative spending. There is
    a need for indicators and monitoring to say whether things are getting
    better or worse in the Great Lakes.

    o  	Currently, people are deciding independently what is most important,
    and sufficient and accurate information is not available to assess
    conditions.

    Environment Canada Ontario Region

    o  	Developing indicators for the Great Lakes is a work in progress, and
    it is essential that these efforts continue. Appropriate indicators must
    be developed and they must have linkage.

    o  	A comprehensive monitoring system with indicators is needed, but
    everyone with a vested interest in the Great Lakes must take part in
    developing the indicators and the surveillance process to monitor them.

    Ontario Ministry of Natural Resources  o  	A comprehensive monitoring
    strategy and indicators are needed for the Great Lakes; however, the
    development of such a strategy will be a significant challenge. There has
    been significant progress made in restoration of the Great Lakes by
    various federal, state, and provincial organizations.

    o  	The problem is that there are too many different people with different
    interests who do not always talk to each other. The sum of the parts from
    various Great Lakes projects has been good, but the results are by fluke,
    not by plan. There must be a process where everyone participates and talks
    to each other.

    Appendix III: Comments by Officials on Need for Indicators and Monitoring
    in the Great Lakes Basin

                              Agency/organization Comments

    Ontario Great Lakes Fisheries  o  A comprehensive monitoring system is
    needed. Threats to the biological, physical, and

    Management 	chemical integrity of the Great Lakes require an ecosystem and
    collaborative approach to objective setting, indicator development,
    monitoring, and reporting.

    Environment Canada Quebec Region  o  	Such a program is definitely
    needed to report on the state and evolution of the ecosystem. Considering
    the size of the drainage basin, such a program should answer questions at
    the lake, river, and basin levels. It should be based on a wide array of
    environmental indicators and not just on a few highlighted ones.

    o  	These indicators need to be useful and significant for government and
    nongovernment managers and interested communities in order to have a
    lasting impact. The indicators and monitoring must support the
    decision-making process.

    Quebec Ministry of the Environment  o  	There is a need to monitor all the
    Great Lakes and the St. Lawrence to determine progress toward restoring
    these watersheds. We must know where we are and where we want to go before
    we can know if things are getting better.

    o  	There must be a relationship between the state of the environment and
    the pressures placed on it from various contaminants and users. We can't
    just monitor the lakes for the sake of monitoring.

    o  	Monitoring in and of itself is not a good goal. Monitoring must be
    done to answer specific management questions and make decisions about what
    needs to be done.

    IJC  o  	A system of monitoring to measure indicators of ecosystem health
    is essential for the Great Lakes. Without it we have no way of knowing
    either the state of the lakes or whether our policies and programs are
    effective in protecting the Great Lakes and those who rely on them for
    drinking water, commerce, and quality of life.

    o  	We need a coordinated approach across a multiplicity of institutions
    to include EPA; Environment Canada; fisheries and natural resource
    agencies; and federal, state, and provincial governments.

    o  	Presently there is growing enthusiasm for a Great Lakes observing
    system, possibly lead by NOAA and coordinated with help from the IJC's
    Council of Great Lakes Research Managers.

    Sources: USGS, NOAA, FWS, FS, EPA, IL, IN, MI, MN, NY, OH, PA, WI, Great
    Lakes Commission, Nature Conservancy, Great Lakes Cities Initiatives,
    Environment Canada, Ontario Ministry of Natural Resources, Quebec Ministry
    of the Environment, Ontario Great Lakes Fisheries Management,
    International Joint Commission, and GAO.

    aThere was no definitive yes or no response from Wisconsin officials, see
    the comment box.

    Appendix IV: State of Ohio Lake Erie Programs and Initiatives with Monitoring
    Activities

    Programs and initiatives with
    monitoring activities Program objectives or focus Program responsibility

    Fish Consumption Advisory Analysis of sport fish caught in Ohio waters for
    State funded program, state administered.

    Program toxins; results are basis for fish consumption advisories.

    Clean Water Act, Section 305 (b) 	Biennially assess Ohio's water bodies
    and report Federally requirement, jointly funded by the status of impaired
    waters. federal and state; administered by stste.

    Clean Water Act, Section 303 (d) 	Protect impaired or threatened waters by
    developing total maximum daily load limits by 2013.

      Federally requirement, jointly funded by federal and state; administered by
     state. Ohio Department of Natural Conduct nonpoint pollution abatement program

    State initiated, jointly funded by federal and state.

    Resources Coastal Urban Streams Program

    with focus on urban, residential, and commercial sources.

    Phosphorus Reduction Strategy	Long-term program to reduce phosphorus
    loading Joint federal and state funded program; into Lake Erie.
    administered by state.

    Ohio Department of Natural Resources Bald Eagle Management Program Program
    to reestablish the bald eagles throughout Ohio

      State initiated and funded. Biological Indices Program Indices measuring the
        health of streams based on health and diversity of aquatic communities.

    State initiated jointly funded by federal and state.

    Bacterial Beach Monitoring Monitor swimming beaches for fecal bacteria
    Joint federal and state funded program; Program contamination using E.
    coli as test organism. administered by state.

    Ohio Tributary Monitoring Program	An analysis of water samples collected
    within the State initiated and funded. Lake Erie basin to assess sediment,
    nutrient, and metal compositions.

            Sources: Ohio Lake Erie Protection and Restoration Plan and GAO.

    Appendix V: Observations on Goals and Monitoring Information Contained in LaMPs
    for Four Great Lakes

    Lake Erie 	The Lake Erie Lakewide Management Plan (LaMP) contains goals
    stated as four ecosystem management objectives focused on land use,
    nutrients, aquatic and terrestrial species, and contaminants. For example,
    one objective addressing contaminants is that toxic chemical and
    biological contaminant loadings within the basin must decline to a level
    that would permit sustainable use of natural resources. Each of the
    objectives have two to four subobjectives that along with the objectives,
    are not expressed in quantitative terms, priorities, or with established
    time frames. One subobjective under the contaminants objective is that
    toxic substances shall not exist in amounts detrimental to human health or
    wildlife and that exotic species should be prevented from colonizing the
    ecosystem, controlled where feasible, and reduced to a point where they do
    not impair the ecological function of Lake Erie. The plan does not state
    how progress in achieving these objectives will be tracked or when the
    objectives should be met. According to the plan, indicators were discussed
    but not selected by a LaMP working group, and tracking progress toward
    goals will not begin until indicators are selected. While indicators were
    not selected for the LaMP, the LaMP stated that extensive monitoring
    activities were ongoing and that an inventory conducted by Environment
    Canada showed that there were over 90 independent monitoring programs
    under way within the Lake Erie Basin. According to the LaMP, the
    indicators ultimately chosen will determine whether current monitoring
    will continue or new monitoring efforts will be initiated.

    Lake Michigan The Lake Michigan LaMP sets forth one overall goalto
    restore and protect the integrity of the Lake Michigan ecosystem through
    collaborative partnerships-and 11 subgoals. These subgoals are stated as
    general questions, such as "can we drink the water," or "can we swim in
    the water," with additional detail on the status of reaching the subgoal,
    challenges, and key steps to be taken to achieve the subgoal's target.
    However, while these subgoals and key steps do contain some quantitative
    information and time frames, they are not prioritized and cannot be linked
    to indicators and monitoring so that progress under the subgoal can be
    measured. For example, under the subgoal "can we swim in the water," the
    LaMP states that there were 206 beach closures in 2000, and progress
    toward reaching the goal is "mixed." It further identifies a challenge to
    develop real-time beach monitoring and that, in 2004, the Great Lakes
    states should adopt criteria, standards, and monitoring programs for beach
    bacteria. The LaMP acknowledges that goals need to be linked to indicators
    and then to a monitoring strategy for tracking restoration progress.
    However, according to the LaMP Program Manager, the selection of
    indicators for Lake Michigan is still in process, and the scope of

    Appendix V: Observations on Goals and Monitoring Information Contained in
    LaMPs for Four Great Lakes

    monitoring efforts being conducted in the Lake Michigan basin needs to be
    determined and coordinated. As a first step in developing a coordinated
    strategic monitoring plan, a monitoring groupthe Lake Michigan
    Monitoring Coordination Councilhas an effort under way to
    determine ongoing monitoring activities in Lake Michigan at the state and
    federal levels, according to the official.

    Lake Ontario 	For Lake Ontario, U.S. and Canadian officials derived the
    LaMP's three overall ecosystem goals from an earlier planthe Lake
    Ontario Toxics Management Planthat was prepared in the late 1980s.
    For example, one goal derived from the plan for the LaMP is "to maintain
    the Lake Ontario ecosystem, and as necessary, restore or enhance it to
    support selfreproducing and diverse biological communities." Under the
    three overall ecosystem goals, the LaMP also included the management
    plan's ecosystem objectives in five areas: aquatic communities, wildlife,
    human health, habitat, and stewardship. These objectives describe in
    general terms the conditions necessary to achieve the overall ecosystem
    goals, but they are not stated in quantitative terms, prioritized, and do
    not contain time frames. The Lake Ontario LaMP also contains 11 indicators
    based on the Lake Ontario Toxics Management Plan and State of the Lakes
    Ecosystem Conference indicator work. According to the LaMP, most indicator
    monitoring needs are being met with existing monitoring programs, but
    further monitoring efforts are planned to provide a more complete
    assessment of lake conditions. The LaMP states that now that indicators
    have been adopted, U.S. and Canadian officials will work to develop a
    "cooperative monitoring" approach for promoting increased communication
    and coordination between their monitoring programs.

                                     Lake Superior

    The Lake Superior LaMP differs from other LaMPs in that it was developed
    from an ongoing programthe Lake Superior Binational Program. This
    program was established in 1991 to restore and protect Lake Superior, and
    it is a partnership between the United States; Canada; the states of
    Minnesota, Wisconsin and Michigan; and the province of Ontario and tribal
    government representatives that develop policies through a number of task
    forces, workgroups, and committees. The LaMP is one of the products
    developed by the program. The LaMP focuses on six areas: critical
    pollutants, habitat, terrestrial wildlife communities, aquatic
    communities, human health, and lake basin sustainability. While these
    areas are not

    Appendix V: Observations on Goals and Monitoring Information Contained in
    LaMPs for Four Great Lakes

    prioritized, for critical pollutants, the LaMP provides specific,
    measurable goals for reducing nine bioaccumulative toxic chemicals.1 For
    each chemical, a 1990 baseline amount was established, along with targets,
    for chemical load reductions to be achieved every 5 years. For example,
    reducing mercury sources 60 percent by 2000, 80 percent by 2010, and a 100
    percent by 2020. Similar goals are set for the other pollutants. While the
    goals are specific, the description of the monitoring process to measure
    progress is less specific with little detail on the monitoring required to
    measure progress toward goals. For the critical pollutants, a menu of
    possible monitoring activities is mentioned, and the LaMP states that more
    work is needed to develop a coordinated monitoring program to evaluate
    progress toward goals and that data from state sources is needed for
    measuring progress. According to Minnesota officials responsible for
    tracking progress, they have difficulty collecting information from state
    regulatory agencies and, therefore, do not have sufficient information to
    measure progress toward reaching goals. They added that funds are not
    available for the monitoring needed to measure progress.

    The goals for the other five areas in the Lake Superior LaMP are not as
    specific and do not link indicators and monitoring to goals leaving
    unclear how progress toward goals will be measured. For example, the LaMP
    lists several strategies for pursuing sustainability, such as developing
    recycling programs and attracting industries that use recycled material
    but no quantitative information, prioritization, or time frames are given
    for these strategies. The LaMP mentions several indicators that have been
    developed to track progress in promoting sustainability, however, these
    are not linked to specific measurable goals. Sustainability indicators
    will be used, according to the LaMP, to assess how fully the Binational
    Program's vision statement is being realized. Ecosystem indicators for
    aquatic and terrestrial species are still under development.

    1The targeted critical pollutants are dioxin, mercury, polychlorinated
    biphenyls, hexachlorobenzene, octachlorostyrene, and the pesticides
    chlordane, DDT, dieldrin/aldrin, and toxaphene.

    Appendix VI: Goals and Priorities Established by Three Great Lakes Organizations

    Council of Great Lakes GovernorsPriorities Task Force

    o  	Ensure the sustainable use of water resources while confirming that
    the Great Lakes states retain authority over water use and diversion of
    Great Lakes waters.

    o  	Promote programs to protect human health against adverse effects of
    pollution in the Great Lakes ecosystem.

    o  Control pollution from diffuse sources into the water, land, and air.

    o  	Continue to reduce the introduction of persistent bioaccumulative
    toxics into the Great Lakes ecosystem.

    o  Stop the introduction and spread of non-native aquatic invasive
    species.

    o  	Enhance fish and wildlife by restoring and protecting coastal
    wetlands, fish, and wildlife habitats.

    o  	Restore to environmental health the areas of concern identified by the
    International Joint Commission as needing remediation.

    o  	Standardize and enhance the methods by which information is collected,
    recorded, and shared within the region.

    o  	Adopt sustainable use practices that protect environmental resources
    and may enhance the recreational and commercial value of our Great Lakes.

    Great Lakes Commission-The Great Lakes Program to Ensure Environmental and
    Economic Prosperity

    o  	Restore and maintain beneficial uses in each of the 31 U.S. and
    binational areas of concern or "toxic hot spots," with a special emphasis
    on remediation of contaminated sediment.

    o  	Restore and protect the ecological and economic health of the Great
    Lakes by preventing the introduction of new invasive species and limiting
    the spread of established ones.

    o  	Improve Great Lakes water quality and economic productivity by
    controlling nonpoint source pollution from water, land, and air pathways.

    o  	Restore 100,000 acres of wetlands and critical coastal habitat while
    protecting existing high quality fish and wildlife habitat in the Great
    Lakes Basin.

    Appendix VI: Goals and Priorities Established by Three Great Lakes
    Organizations

    o  	Ensure the sustainable use and management of Great Lakes water
    resources to protect environmental quality and provide for water-based
    economic activity in the Great Lakes states.

    o  	Meet domestic and international Great Lakes commitments through
    adequate funding for, and the efficient and targeted operation of,
    federally funded and management and research agencies.

    o  	Maximize the commercial and recreational value of Great Lakes
    waterways and other coastal areas by maintaining and constructing critical
    infrastructure and implementing programs for sustainable use.

    Great Lakes UnitedA Citizens Action Agenda for Restoring the Great
    Lakes and St. Lawrence River Ecosystem

    o  	Toxic Cleanup Action Agenda Lists five areas where action is needed,
    such as funding toxic cleanups, coordinating cleanup efforts, and treating
    contaminants.

    o  	Clean Production Action Agenda Lists seven areas where action is
    needed, such as design of manufacturing products, minimizing resource
    extraction, and planning and managing food production and agriculture in
    relation to the surrounding ecosystem.

    o  	Green Energy Action Agenda List five areas where action is needed,
    such as promoting energy efficiency, conservation, and renewable energy
    sources.

    o  	Sustainable Water Quantities and Flows Action Agenda Lists eight areas
    where action is needed such as implementing water withdrawal reform and
    restoring basin ecosystem functions damaged or lost due to harmful water
    withdrawal practices.

    o  	Protecting and Restoring Species Action Agenda Lists 13 areas where
    action is needed to address invasive aquatic and terrestrial species, and
    protect threatened species.

    o  	Protecting and Restoring Habitats Action Agenda Lists 24 areas where
    action is needed to protect and restore aquatic, forest, urban, and
    interconnecting habitats; and limit sprawl.

                            Appendix VII: Comments from the
                            Environmental Protection Agency

     Appendix VII: Comments from the Environmental Protection Agency Appendix VII:
     Comments from the Environmental Protection Agency Appendix VII: Comments from
                          the Environmental Protection Agency

    Appendix VIII: GAO Contact and Staff Acknowledgments

    GAO Contact John B. Stephenson (202) 512-3841 (stephensonj@gao.gov)

    Staff 	In addition to the individual named above, Willie Bailey, Greg
    Carroll, Nancy Crothers, John Delicath, Michael Hartnett, Karen Keegan,
    Amy

    Acknowledgments Webbink, and John Wanska made key contributions to this
    report.

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