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		 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
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 [email protected].

r

                                       e

vi

                                      Recn

er

wa

                                       L

.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, 
               Science      conducted    center   Lakes, to               monitoring  Quality                                                              lamprey                                                $16  activities         the      the sea   and their         The      in fish   and angler   and funded                                                                              include       Great  limits for   because 
 USGS          Center          in the  operates     conduct  determining      in the  Assessment   pesticides,  in streams,   studies                       impact   monitoring   officials, is  monitoring   million  to control  success of     lamprey,    habitats     primary  populations  objectives.     by state                   In each                  done for both  states         identifying       Lakes  identified      each 
 conducts      located in   open lake      five    research  the volume        Great  (NAWQA)       nutrients,  groundwater,  conducted                         on    is funded        the most     efforts  annually     the sea       these  each of the  as a major   objective      for the     The fish    agencies,                   state,                   federal and    conducts          impaired  Basin, and  pollutants     state 
 monitoring    Ann Arbor,    areas as  research         and  and               Lakes  program to      volatile  and aquatic   nationwide,                 specific  by the GLFC  comprehensive,  ongoing in  from the     lamprey     control  Great Lakes   component      of the   purpose of   monitoring         with                   monitoring               state          monitoring           water  developing  as          uses its 
 in the Great  Michigan.      part of  vessels,  monitoring  presence of       Basin  determine        organic  ecosystems.   2 are         Finally, FWS      fish          and    coordinated,   the Great    United  population    efforts.       states      of the        fish   restocking     programs   monitoring  GLFC.            in the                   requirements.  for federal         bodies       Total  required         own 
 Lakes         This          its fish   one for         for  predator        through  the           compounds,  Of the 42     within the       and other  species,    according             and  Lakes. The    States         and          In     monitors        fish  monitoring      to meet          are      results                   Great                    Each of the    program         within the     Maximum  under the   criteria 
 through its   monitoring  assessment   each of    specific  fish. USGS          its  presence       and other  NAWQA         Great Lakes  organizations   such as   to several    consistently  commission       and  monitoring    addition         fish  monitoring  program is        local    generally  coordinated                   Lakes                    Great Lakes    requirements,       state,  Daily Load  Clean       and time 
 Great Lakes   is            program.  the five   purposes,  also           National  of          contaminants                Basin.             conduct  the lake  restoration          funded    receives    Canada  activities          to  populations    program.   to assess    community    initiated       by the                   Basin is a                              which            including      (TMDL)  Water Act.  schedule 
                                          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 
    States or     program 
    the Great   involving 
        Lakes       state 
      Basin.9  monitoring 
      Another      is the 
      example       Beach 
               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 ([email protected])

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.

  GAO's Mission

Obtaining Copies of GAO Reports and Testimony

The Government Accountability Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting its
constitutional responsibilities and to help improve the performance and
accountability of the federal government for the American people. GAO
examines the use of public funds; evaluates federal programs and policies;
and provides analyses, recommendations, and other assistance to help
Congress make informed oversight, policy, and funding decisions. GAO's
commitment to good government is reflected in its core values of
accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no cost
is through GAO's Web site (www.gao.gov). Each weekday, GAO posts newly
released reports, testimony, and correspondence on its Web site. To have
GAO e-mail you a list of newly posted products every afternoon, go to
www.gao.gov and select "Subscribe to Updates."

Order by Mail or Phone 	The first copy of each printed report is free.
Additional copies are $2 each. A check or money order should be made out
to the Superintendent of Documents. GAO also accepts VISA and Mastercard.
Orders for 100 or more copies mailed to a single address are discounted 25
percent. Orders should be sent to:

U.S. Government Accountability Office 441 G Street NW, Room LM Washington,
D.C. 20548

To order by Phone: 	Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
512-6061

  To Report Fraud, Contact:

Waste, and Abuse in Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: [email protected] Programs Automated answering system: (800)
424-5454 or (202) 512-7470

Gloria Jarmon, Managing Director, [email protected](202)
512-4400Congressional U.S. Government Accountability Office, 441 G Street
NW, Room 7125 Relations Washington, D.C. 20548

Public Affairs 	Jeff Nelligan, Managing Director, [email protected] (202)
512-4800 U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, D.C. 20548

                           PRINTED ON RECYCLED PAPER

           Presorted Standard Postage & Fees Paid GAO Permit No. GI00

United States
Government Accountability Office
Washington, D.C. 20548-0001

Official Business
Penalty for Private Use $300

Address Service Requested
*** End of document. ***