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.
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  The last review in 1999 found that certain sections of the agreement were  outdated and revisions were needed.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. Specifically, Annex 11 calls for the monitoring program to  include baseline data collection, sample analysis, and evaluation and  quality assurance programs to assess such things as whole lake data  including that for open waters and nearshore areas of the lakes as well as  fish and wildlife contaminants; inputs from tributaries, point source  discharges, atmosphere, and connecting channels; and total pollutant  loadings to and from the Great Lakes system.
The monitoring program under Annex 11 is to be based on the Great Lakes  International Surveillance Plan (GLISP) developed before the current  requirements for a surveillance and monitoring system. Developing the  surveillance plan, which involved developing a separate plan for each lake,  required extensive efforts by U.S. and Canadian officials over several  years. However, according to one Canadian official involved in the  process, the plans were not completed to the point where they could be  implemented. The IJC’s Water Quality Board was involved in the  management and development of the GLISP, but according to a binational  review of the GLWQA in 1999, the IJC’s role was reduced after the GLQWA  amendments of 1987 placed more of the responsibility for data analysis  and reporting on the state of the Great Lakes environment with the two  governments. IJC’s role today is one of assisting in the implementation of  the agreement and evaluating the actions of the two governments in  meeting the objectives of the GLWQA. After the GLISP effort, the  governments reduced support for the surveillance and monitoring called  for in the agreement, and abandoned the organizational structure created  to implement the monitoring plan, leaving in place only one of the plan’s  initiatives, the International Atmospheric Deposition Network (IADN), a  network of 15 air-monitoring stations located throughout the basin  developed in response to the GLWQA requirement of a monitoring  program to allow assessment of inputs from the atmosphere affecting the  Great Lakes. In addition, under a separate annex in the GLWQA (Annex 2),  LaMPs are required to include, among other things, a description of the  surveillance and monitoring to be used to track the effectiveness of  remedial measures and the elimination of critical pollutants. The  agreement requires that updates to the LaMPs be submitted to the IJC for  review and comment. IJC is considering whether to conduct a review of  the LaMPs in 2004.
The Water Quality Act of 1987 amended the Clean Water Act to state that  EPA should take the lead and work with other federal agencies and state  and local authorities to meet the goals in the agreement. It also established  within EPA, GLNPO, to among other things, coordinate EPA’s actions  aimed at improving Great Lakes water quality both at headquarters and at  the affected EPA regional offices, and to coordinate EPA’s actions with the  actions of other federal agencies. As of 2003, GLNPO’s budget was $16  million, including $5 million allocated for program costs, which includes  47 full-time EPA staff and 13 non-EPA staff. The remaining costs included  about $4.3 million per year for monitoring and monitoring-related  reporting, which included about $1.4 million to operate GLNPO’s research  vessel, the Lake Guardian. For Canada, Environment Canada (EC) is the  lead agency, which works in cooperation with the provinces of  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:    Council of Great Lakes Governors, a partnership of governors from the  eight Great Lakes states and the Canadian provinces of Ontario and  Quebec, encourages and facilitates environmentally responsible economic  growth throughout the Great Lakes region.
Great Lakes Commission, an organization promoting the orderly,  integrated, and comprehensive development, use, and conservation of  water and related natural resources of the Great Lakes Basin and the St.  Lawrence River, includes representatives from the eight Great Lakes states  and the Canadian provinces of Ontario and Quebec.
Great Lakes United, an international coalition group dedicated to  preserving and restoring the Great Lakes-St. Lawrence River ecosystem,  promotes effective policy initiatives, carries out education programs, and  promotes citizen action and grassroots leadership for Great Lakes  environmental activities. The coalition’s member organizations represent  environmentalists, conservationists, hunters and anglers, labor unions,  communities, and citizens of the United States, Canada, and First Nations  and Tribes.
United States Policy Committee, a group of senior level representatives  from federal, state, and tribal government agencies with environmental  protection or natural resource responsibilities in the Great Lakes Basin.  The group meets semiannually to coordinate agency actions and  commitments associated with the Great Lakes Strategy 2002.
Great Lakes Fishery Commission, a binational commission created by the  Convention on Great Lakes Fisheries between the United States and  Canada in 1955, whose primary objectives are to coordinate fisheries  management and research, and to control sea lamprey. The U.S.  Department of State and Canada’s Department of Fisheries and Oceans  provide funding for the commission.
Great Lakes Interagency Task Force, an organization created within EPA  by executive order to provide coordination of federal activities and  promote regional collaboration within the Great Lakes Basin and among  other things, to develop outcome based goals for the Great Lakes system.
Assisting the task force is a working group composed of regional federal  officials with GLNPO providing resources for both groups.

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

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

		Current Efforts Do Not Fulfill Monitoring Requirements of the GLWQA

Annex 11 of the GLWQA calls for the United States and Canada to develop  a joint Great Lakes system-wide surveillance and monitoring program to,  among other things, provide information on restoration progress and  whether the objectives of the agreement are being achieved. This program,  however, has not been fully developed. Instead, officials from GLNPO look  upon SOLEC as the process by which indicators will be developed to  monitor environmental conditions and measure restoration progress in the  Great Lakes. However, as we reported in 2003, the SOLEC process of  holding conferences every 2 years to develop Great Lakes indicators and  monitor environmental conditions for subsequent reporting on the state of  the lakes falls short in several areas. First, indicators assessed through the  process do not provide an adequate basis for making an overall  assessment of Great Lakes restoration because they rely on limited  quantitative data and subjective judgments. Second, the SOLEC process is  dependent on the voluntary participation of officials from federal and state  agencies, academic institutions, and other organizations. As a result, their  future commitment to providing information on indicators and monitoring  results, along with their future participation, is not assured. Finally, most  of the stated objectives for SOLEC do not align with the surveillance and  monitoring program envisioned in the GLWQA. The stated objectives of  SOLEC are to    assess the state of the Great Lakes ecosystem based on accepted    strengthen decision making and management,  inform local decision makers of Great Lakes environmental issues, and   provide a forum for communication and networking among stakeholders.
Other than the objective for assessing the state of the ecosystem based on  accepted indicators, the SOLEC objectives do not address issues related to  monitoring. GLNPO officials stated that the objective of SOLEC is not to  be a monitoring program but rather a reporting venue for conditions in the  Great Lakes. However, it is the only ongoing effort to provide an overall  assessment of the Great Lakes and, according to 23 federal, state, and  other environmental program officials, a surveillance and monitoring  system is still needed. For example, a Michigan state official explained  that a monitoring system developed with the involvement of all  stakeholders and focused on the differences in individual lakes is needed.  Appendix III contains the specific comments from the officials we  contacted regarding the need for a monitoring system.

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

The monitoring information developed and reported by SOLEC is of  questionable value to officials responsible for making restoration  decisions for several reasons. First, the information is not based on their  decision-making needs. State and federal agency officials stated that the  SOLEC process is not connected with the policy-making process. For  example, a Minnesota Pollution Control Agency official stated that the  SOLEC process is oriented toward the needs of researchers and has not  connected with the policy-making process for which indicators are  needed. A Michigan Department of Environmental Quality official stated  that SOLEC provides information based on data from only one or two  sampling locations and is not relevant from a state program perspective.  Canadian program officials shared these opinions, and one official added  that SOLEC data does not address local community questions or program  objectives.
The comments by program officials are supported by results from a peer  review of SOLEC in 2003 by an international panel of experts in large  indicator systems. While the panel had many favorable observations of  SOLEC, they noted a disconnect between the development of the  indicators and their usefulness to policy makers. The peer review stated  that, to be effective, the actual users must define indicators, with policy  makers and environmental managers involved in the early stages of  indicator development. In addition to these observations, in the latest  report on the state of the Great Lakes, one of the management challenges  discussed is how to better assist managers given the large number of  indicators. Specifically, the challenge is to find a method of indexing  indicators that better assists managers and leads to more useful, informed  decision making. The disconnect between SOLEC and decision makers is  further illustrated by the fact that only two of the eight Great Lakes states  we contacted were reporting information from local monitoring efforts to  support the SOLEC process and that none of the states reported using the  monitoring information published by SOLEC to describe conditions of its  local water bodies or to measure restoration progress. One Minnesota  official stated that the former head of the state environmental agency  viewed SOLEC information as irrelevant to describe conditions within the  state.
A GLNPO official working on SOLEC stated that developing effective  indicators requires that you first ask what is to be measured, what the best  indicator is for this measurement, how much data are needed, who will  collect and handle the data for consistency, and how often the  measurement will take place. He stated that the need to ask these  questions dates back to the early 1980s, but actions to implement this  indicator-monitoring program never materialized. Instead, different  indicators and monitoring programs are being conducted by various  agencies using different sampling methodologies and protocols, and this  inconsistent local program information cannot, after the fact, be used to  make decisions about system-wide needs or environmental conditions.
Second, SOLEC information is based on limited data that further detracts  from its usefulness to decision makers. For example, of the 80 SOLEC  indicators reported to describe the Great Lakes Basin in 2003, evaluative  data were only available for 43 of them. Often this data was geographically  limited and did not address conditions within the entire basin.  Additionally, the IJC reported in its 2002 biennial report that sufficient  data were not being collected from around the Great Lakes and that the  methods of collection, the data collection time frames, the lack of uniform  protocols, and the incompatible nature of some data jeopardized their use  as indicators.
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. Therefore, there is no assurance  that the information will continue to be collected or consistently reported  over time. Environmental program officials from federal, state, and  provincial agencies stated that the process lacks sufficient and consistent  monitoring information to measure environmental restoration progress.  The SOLEC peer review group found that the SOLEC process has serious  flaws regarding lack of repeatability and transparency. According to  GLNPO officials, SOLEC organizers attempted to address the issue of  repeatability and transparency in 2003 by issuing a technical report, which  provides additional information on data sources. Further, the process is  lacking in standard methodology, and SOLEC has yet to establish standard  protocols to improve data comparability and reliability.
One attempt to measure restoration progress in the basin using SOLEC  indicators is presented in EPA’s fiscal year 2005 budget justification. To  measure progress, a single quantitative score is derived based on a formula  using eight SOLEC indicators. Each indicator is given a score from 1 to 5  based on the professional judgments of individuals providing the indicator  information. A score of 1 is considered poor, and 5 is considered good.  Totaling the individual indicator scores resulted in a score of 20 based on a  total 40-point scale for the Great Lakes. While this is an attempt to  measure overall progress, the scoring process is based on a limited  number of indicators, and the point scores are based on subjective  judgment. Further, the indicators described in the budget justification do  not align with the ones used in developing the scores. According to  GLNPO officials, this may have resulted from information being submitted  at different times during the development of the budget justification.

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

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

			Monitoring by Federal Agencies

Four federal agencies, EPA, National Oceanic and Atmospheric  Administration (NOAA), U.S. Geological Survey (USGS), U.S. Department  of Interior’s Fish and Wildlife Service (FWS), and one international  commission, the Great Lakes Fishery Commission (GLFC), have ongoing  monitoring activities for specific purposes within limited areas of the  Great Lakes Basin. EPA’s GLNPO conducts four monitoring activities.  First, GLNPO conducts annual monitoring of open lake water areas for the  specific purpose of gathering information on water quality and biological  conditions. The information gathered includes toxic pollutant levels of  persistent substances, such as phosphorous. These sampling efforts are  generally conducted twice each year, once in spring and once in summer,  when the Lake Guardian travels to various fixed sampling sites on each of  the lakes (see fig. 2). Sampling information collected during these  assessments is stored in an automated database and is limited to assessing  long-term trends in open lake waters. GLNPO officials stated that it takes  about 6 to 7 years of data before enough information is available to  identify a long-term trend.
Second, GLNPO conducts monitoring of sediment contaminants in the  nearshore areas of the Great Lakes that involves biological and chemical  sampling for benthic-bottom soil-contamination. Data is collected from  several sampling stations throughout the lakes to assess, among other  things, the presence of small invertebrates in bottom sediments. These  data are assessed with open lake data to determine possible adverse  impacts on the food web that ultimately pose a human health risk. The  scope of sediment monitoring is limited to certain areas, and GLNPO  officials stated that they believe their main responsibility is open lake  monitoring under the GLWQA and that the Great Lakes states are  responsible for inland and tributary monitoring. Third, GLNPO conducts  the U.S. portion of IADN for the specific purpose of monitoring toxic  substances deposited through the air. Monitored toxic substances include  polychlorinated biphenyls (PCB) and trace metals, such as lead and  cadmium, that have entered the watershed. While GLNPO is responsible  for monitoring in the United States, EC is responsible for Canadian  locations. IADN consists of 5 master sampling stations and 10 satellite  stations located throughout the basin and is limited to identifying  substances deposited through the air. Fourth, GLNPO conducts an annual  fish program to monitor concentrations of contaminants in Great Lakes  fish. GLNPO has agreements with the Universities of Minnesota, Indiana,  and Wisconsin, along with USGS, to collect specific fish species from each  lake and grind them into paste to analyze for contaminants that might pose  a risk to humans if consumed.
In addition to GLNPO’s monitoring efforts, EPA’s Office of Research and  Development (ORD) funds research activities involving developing  indicators and Great Lakes monitoring. There are four divisions within  ORD’s National Health Environmental Effects Research Laboratory  (NHEERL), and one of 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.
USGS conducts monitoring in the Great Lakes through its Great Lakes  Science Center located in Ann Arbor, Michigan. This monitoring is  conducted in the open lake areas as part of its fish assessment program.  The center operates five research vessels, one for each of the five Great  Lakes, to conduct research and monitoring for specific purposes, such as  determining the volume and presence of predator fish. USGS also  conducts monitoring in the Great Lakes Basin through its National Water  Quality Assessment (NAWQA) program to determine the presence of  pesticides, nutrients, volatile organic compounds, and other contaminants  in streams, groundwater, and aquatic ecosystems. Of the 42 NAWQA  studies conducted nationwide, 2 are within the Great Lakes Basin.
Finally, FWS and other organizations conduct monitoring to determine the  sea lamprey impact on specific fish species, such as the lake trout. This  monitoring is funded by the GLFC and according to several restoration  officials, is the most comprehensive, coordinated, and consistently funded  monitoring efforts ongoing in the Great Lakes. The commission receives  about $16 million annually from the United States and Canada to carry out  activities to control the sea lamprey population and monitoring activities  to measure the success of these control efforts. In addition to monitoring  the sea lamprey, each of the Great Lakes states monitors fish populations  and their habitats as a major component of the fish monitoring program.  The primary objective of the fish monitoring program is to assess changes  in fish populations for the purpose of restocking to meet local community  and angler objectives. The fish monitoring programs are generally initiated  and funded by state agencies, with monitoring results coordinated by the  GLFC.

			Monitoring by State Organizations

In each state, monitoring in the Great Lakes Basin is a mix of activities  done for both federal and state requirements. Each of the Great Lakes  states conducts monitoring for federal program requirements, which  include identifying impaired water bodies within the state, including the  Great Lakes Basin, and developing Total Maximum Daily Load (TMDL)  limits for identified pollutants as required under the Clean Water Act.  However, because each state uses its own criteria and time schedule for  identifying impaired water bodies, the process is not done consistently  throughout the United States or the Great Lakes Basin. Another example  of a federal program involving state monitoring is the Beach Monitoring  Program under the Beach Act. This program involves sampling of only the  nearshore waters of state beaches for the presence of bacteria to  determine if the water is safe for swimming.
In addition, states conduct monitoring in the Great Lakes Basin for state  requirements. For example, in Ohio, two state agencies—the Ohio  Environmental Protection Agency and the Ohio Department of Natural  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 Goals Exist for Monitoring Restoration Progress

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

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

EPA’s efforts in developing the Great Lakes Strategy 2002 and LaMPs  have resulted in proposed goals for the overall basin and for individual  lakes. 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. 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. 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  measured. For example, the Lake Erie LaMP states that a working group  discussed indicators, but none were selected. While each LaMP describes  monitoring efforts to some extent, they usually do not define how progress  to achieve goals will be tracked. An exception to this is a section of the  Lake Superior LaMP addressing critical pollutants. See appendix V for  goals and monitoring information contained in LaMPs for four of the Great  Lakes.

		Other Organizations Have Developed Basin-Wide Goals

Three organizationsthe Council of Great Lakes Governors, Great Lakes  Commission, and Great Lakes Unitedhave independently of EPA  developed goals for the Great Lakes Basin. The goals are presented in  general terms, such as stopping the spread of invasive species or cleaning  up contaminated areas. Several of the organizations’ goals are similar,  representing a relative consensus among the organizations. While the goals  are useful in communicating what specific issues the groups believe are  important to the Great Lakes, additional specifics, such as which invasive  species are to be controlled or by what time frame, may be needed to  determine whether the goals are being achieved. It should be noted that  these organizations do not have the resources of federal or state agencies  to address proposed goals and priorities and must rely on others to take  action. For some of the priorities, specific federal agencies are identified  to take actions. The goals or priorities developed by the three  organizations are summarized in appendix VI.
One recent set of priorities was prepared by the Great Lakes Governors’  Priorities Task Force, which consisted of governors’ representatives for  the eight Great Lakes states. After deliberating for approximately 2 years,  this group reached consensus in 2003, on nine priorities to guide Great  Lakes restoration and protection efforts. These priorities addressed a  range of issues including protecting human health and enhancing  information collection and standardization. The priorities are defined in  general terms, such as “control pollution from diffuse sources into water,  land, and air.” Details on the type and causes of pollution to be assessed  and the desired outcomes are not further defined. After the priorities were  reported, public sessions were held in Great Lakes states to obtain  reaction and input on the Governors’ goals. These sessions, however, are  not expected to result in further refinement of the priorities.
Similarly, the Great Lakes Commission, which includes representatives  from the eight Great Lakes states and the Canadian provinces of Ontario  and Quebec, established seven priorities for the Great Lakes such as  cleaning up toxic hot spots, controlling nonpoint source pollution, and  preventing the introduction or limiting the spread of invasive species. Its  report outlining the seven major priorities identifies an overall goal for  each priority. 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. Under each challenge, the agenda recommends several action  items for restoring the Great Lakes Basin. Some of these action items have  established time frames.

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

Coordinating the establishment of measurable goals and developing a  monitoring system for tracking progress in the Great Lakes are difficult  tasks that face significant challenges. Of great importance, no single  organizational entity has exercised leadership responsibility for  coordinating the establishing of specific goals and a monitoring system. As  we reported previously, under the Clean Water Act, GLNPO has  coordination authority over many Great Lakes activities but has not fully  exercised it. Further, it is uncertain whether the Executive Order issued in  May 2004, creating a Great Lakes Interagency Task Force, will provide the  needed stability in leadership. Second, the restoration goal setting and  monitoring efforts ongoing by numerous governmental and  nongovernmental organizations in the United States and Canada will  create a challenge for coordinating within and between the two countries.  Specific obstacles include coordinating the goal setting efforts of the  various Great Lakes organizations and accounting for ongoing agreements  within Canada when developing the joint monitoring system called for in  the GLWQA. Third, coordinating information derived from the various  monitoring activities of the numerous groups involved in the Great Lakes  is a significant challenge. The lack of a centralized repository of  monitoring information makes it difficult to assess restoration progress.  Fourth, because each of the five Great Lakes has unique environmental  conditions, it will be difficult to establish measurable goals that reflect  these differences and yet provide consistent basin-wide information. One  restoration effort, the Chesapeake Bay Program, has developed  measurable goals and a defined organizational structure that may offer  valuable lessons for restoration efforts in the Great Lakes.

		Great Lakes Restoration Efforts Lack Clearly Defined Organizational Leadership

Organizational leadership for setting goals and developing a monitoring  system has yet to be realized for the Great Lakes. Several attempts at  providing organizational leadership have not resulted in a stable structure  for leading Great Lakes restoration efforts. We previously reported that,  within the Great Lakes several entities are involved in coordinating and  planning, which has resulted in confusion by federal and state officials as  to which entity bears ultimate responsibility. We further reported that the  responsibility for leading the U.S.’s Great Lakes efforts rests with GLNPO  and that it is not fully exercising its authority under the Clean Water Act  for coordinating Great Lakes restoration programs. We recommended  GLNPO fulfill its coordinating responsibilities and develop an overarching  Great Lakes restoration strategy. EPA promised to provide a detailed  response to our recommendations, but has not yet done so. However, in  2003 an EPA official stated in congressional testimony that the Clean  Water Act does require EPA, and more specifically GLNPO, to serve as the  lead entity for coordinating the protection and restoration of the Great  Lakes system. The same official stated in 2004 congressional testimony  that our recommendations are answered by the Executive Order and again  promised a detailed response to these recommendations. However, the  Executive Order does not address our recommendations.
As a result of the Executive Order issued in May 2004, which created a  Great Lakes Interagency Task Force within EPA, how GLNPO’s leadership  role and coordination responsibilities will be exercised in the future is  unclear. Task force members include representatives from EPA, eight  other federal agencies with Great Lakes program responsibilities, and the  Council on Environmental Quality. Under the Executive Order, one of the  purposes of the task force is to coordinate government action associated  with the Great Lakes. The EPA Administrator chairs the task force that is  also charged with developing outcome-based goals and collaborating with  Canada and its provinces and with other binational bodies involved in the  Great Lakes region regarding policies, strategies, projects, and priorities  for the Great Lakes. The head of GLNPO, the Great Lakes National  Program Manager, chairs the working group, and GLNPO staff are to assist  both the task force and the working group in performing their duties.  While the Executive Order addresses GLNPO’s role with respect to the  task force and working group, it does not address GLNPO’s existing  responsibilities under the Clean Water Act for coordinating EPA’s  activities with other federal agencies and state and local authorities to  meet GLWQA goals. The coordination role for the task force under the  Executive Order is very similar to GLNPO’s coordination role under the  Clean Water Act. However, because the Executive Order does not affect  the statutory obligations of federal agencies, GLNPO is still under a  statutory obligation to fulfill its coordination role. Moreover, under the  Clean Water Act, GLNPO is required to not only develop but also  implement specific action plans to carry out the responsibilities under  GLWQA. However, according to the Executive Order, GLNPO will  participate on a Great Lakes Regional Working Group that is responsible  for coordinating and making recommendations for implementing the task  force polices and strategies, but it will be the task force that actually  implements recommendations.
Existing coordination activities of USPC are also uncertain in light of the  Executive Order. The USPC is focused on coordinating federal, state, and  tribal government activities related to fulfilling the GLWQA, and it  developed the Great Lakes Strategy 2002 to set restoration goals and  actions. Membership on the USPC is similar to the newly formed working  group in that it includes regional federal officials, and the GLNPO program  manager chairs both groups and also serves as the Acting Assistant  Administrator for EPA’s Office of Enforcement and Compliance  Assurance. According to the Director of GLNPO, as of July 2004, when the  last USPC semiannual meeting was held, there were no plans to change  the role of the USPC. Therefore, the USPC, the task force working group,  and GLNPO all seemingly are engaged in coordinating federal regional  activities in the Great Lakes Basin.
Coordinating Great Lakes research is another responsibility provided to  the task force under the Executive Order, but other organizations have  research responsibilities by statute. Specifically, NOAA’s Great Lakes  Research Office, acting through the GLERL and other entities, is  responsible under the Clean Water Act for conducting Great Lakes  research and monitoring activities and annually reporting issues, on which  Great Lakes research is needed, to the Congress. Each year GLERL and  GLNPO are to prepare a joint research plan and to provide a health  research report to the Congress. Thus far, GLERL and GLNPO have not  prepared these plans or reported to the Congress because funds were not  requested or provided for the coordination and reporting activities,  according to agency officials. The GLERL Director stated that they have  about 15 specific legislative mandates involving Great Lakes research.  Coordinating and prioritizing research is also an activity of the IJC’s  binational Council of Great Lakes Research Managers. This council,  established in 1984, proposes priority research areas for the Great Lakes,  and some of the proposals are priorities for GLERL, in part, because the  council is currently co-chaired by the GLERL Director. Future councils,  however, may not be co-chaired by the GLERL Director, and priority  research areas may not be addressed because research managers are not  bound to follow council priorities.
Finally, the creation of the task force and working group by the Executive  Order also raises questions about the permanency of this organizational  structure for addressing the long-term restoration needs of the Great  Lakes. Executive orders, such as the one creating the task force, stay in  effect despite changes in administrations, but they may be amended or  rescinded by a subsequent President. Moreover, the Executive Order  cannot be enforced in court, unlike statutory provisions that can often be  judicially enforced. Therefore, the task force may prove to be a temporary  rather than a permanent attempt at coordinating and developing goals for  the Great Lakes. Legislation was proposed in 2004 to enact the provisions  of the Executive Order into law, but this legislation remains pending in the  Congress.

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

Many organizations participating in the restoration of the Great Lakes have  independently developed goals for the Great Lakes Basin. However, these  organizations have tended to develop goals independently of EPA and one  another, resulting in duplicative efforts and the lack of prioritization of  goals. We previously reported that the numerous restoration strategies  containing goals developed by various organizations did not provide an  overarching approach that can be used as a blueprint to guide overall  restoration activities. The situation remains the same today with several  organizations developing strategies and goals, without clearly defined  leadership responsibilities to bring together or coordinate the various  efforts. In some cases, the goals developed are very similar to each other.  For example, the Council of Great Lakes Governors and the Great Lakes  Commission both have similar goals relating to cleaning up of areas of  concern and stopping the spread of invasive species. Yet, consensus has  not been reached by the various organizations as to specifically how such  goals should be measured.
The leadership to coordinate goal setting efforts has not yet materialized.  There is no one organization or group of organizations that is recognized  as the leader. For example, at a Senate hearing on Great Lakes restoration  efforts in 2003, the hearing chairman asked a panel of federal agency  officials, including the Great Lakes National Program Manager, if there  was an orchestra leader for the efforts in the Great Lakes, and none of the  panel members volunteered a response. Similarly, during an IJC  conference session in 2003, where the leadership for the various Great  Lakes organizations was addressed, the Great Lakes National Program  Manager stated that because of the number of groups involved in the Great  Lakes, there is a need to find a way to work together toward goals;  however, he was reluctant to lead this effort. The recently created Great  Lakes Interagency Task Force was charged with establishing a process for  collaboration among task force members to, among other things, develop  outcome-based goals for the Great Lakes system. The desired outcomes  are conditions such as cleaner water or sustainable fisheries.
Federal and state program officials acknowledge that limited coordination  of monitoring activities now exists and that there is no single organization  in place to direct the coordination of monitoring efforts. One attempt to  coordinate monitoring involving research vessels on the Great Lakes  began in 1997, by the IJC’s Council of Great Lakes Research Managers. The  impetus for this effort was that over 60 research vessels were operating  independently in the basin without coordination or collaboration and with  limited monitoring funds. Since that time the IJC has been developing an  inventory of Great Lakes research vessels that was placed on a Web site  designed to identify the ships, scientific equipment, general research  schedules, and points of contact to aid in coordinating operations and  sharing resources. The extent that this inventory has facilitated  coordination has yet to be determined, however, coordination has begun  through sharing of information on research vessels, according to an IJC  official.
Further, existing agreements on restoration goals and monitoring between  Canada and its provincial governments of Ontario and Quebec will need to  be considered in developing basin-wide goals if a joint U.S.-Canada  monitoring system is to be developed as required under the GLWQA. Four  of the five Great Lakes are shared by the United States and Canada and  share many of the same environmental problems. The restoration goals  and monitoring efforts developed in Canada to address these problems are  important for a coordinated effort by the two countries. One set of goals to  consider are in an agreement reached in 2002, between the governments of  Canada and Ontario on overall goals and actions to be taken to protect,  restore, and conserve the Great Lakes Basin ecosystem. This  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. The inventory of existing monitoring sources will  rely on common data fields and terminology for standardization of  information, and GLNPO plans to manage the database. To create the  database, the BEC will request the various federal and state agencies and  other organizations conducting monitoring activities to input information  into the database, according to GLNPO officials. Ultimate responsibility  for data completeness and quality rests with the BEC. However, it is  unclear how this will be accomplished since the BEC has limited  resources to carry out this responsibility. Further, since the input and  annual update of monitoring information is voluntary, it is unclear how a  complete and accurate inventory can be assured since there is no  independent verification of the data. GLNPO officials stated that, as of July  2004, the Web-based system is developed, and they are awaiting  organizations to enter information on monitoring systems into the  database.

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

While basin-wide goals are useful, existing goal-setting efforts are  complicated by the unique characteristics of each lake. The physical  magnitude of the basin is often recognized as a daunting challenge for  setting measurable restoration goals. Although the Great Lakes are  connected through rivers and channels, they are not one contiguous water  body but rather distinct lakes with unique environmental conditions. The  Great Lakes Basin area spans 750 miles and has multiple environmental  challenges. This presents challenges to setting goals and developing a  monitoring system that can be used to describe restoration progress  across the basin and also capture the uniqueness of each lake. The distinct  physical characteristics of the lakes are illustrated by the differences  between Lakes Superior and Erie. (See fig. 3.)
Lake Superior is a larger, deeper lake with a relatively sparse human  population within its watershed. Most of the shoreline of Lake Superior is  forested and not host to the extensive urban development along its shores  that Lake Erie has. For Lake Superior, the overarching concern is to  preserve current conditions and keep pollutants and invasive species from  entering the lake. Lake Erie has other unique environmental problems, the  most recent being the reemergence of a dead zone in the central basin of  the lake that is void of oxygen and cannot support aquatic life. Recently,  the phosphorus levels of the lake have exceeded acceptable levels as the  result of unknown causes. Research efforts are now focused on  determining the cause of the rise in phosphorous levels, which cause  harmful algae blooms. Because Lake Erie is the shallowest of the Great  Lakes and is subject to urban pressures, it is sometimes cited as the lake  that first develops environmental problems within the Great Lakes Basin.
The differences between the Great Lakes pose a challenge to setting basin- wide goals. While goals are needed to determine basin-wide progress,  goals for each lake are also needed to address specific problems or public  concerns for each lake. For Lake Superior, a major concern is stopping  pollutants from entering the lake, which is addressed through a program  that established a goal of zero-discharge for point source pollutants. For  Lake Erie, goals developed by the Lake Erie Commission address other  problems, such as how remediating contaminated sediments in Lake Erie’s  harbors and tributaries. The future challenge will be how to build on the  existing goal-setting efforts for each lake in developing measurable goals  for the Great Lakes Basin as a whole.

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

The Chesapeake Bay Program, a restoration effort lead by EPA, has  demonstrated that quantifiable and prioritized goals with definitive time  frames can be developed for measuring restoration progress. While the  Great Lakes have unique challenges, such as coordination with Canada,  the bay program also provides an example of how an organizational  structure can be created to successfully coordinate goal setting.
Unlike the restoration goals prepared for the Great Lakes, the Chesapeake  Bay Program has specific, measurable goals with definitive time frames  that are linked to indicators and a monitoring and modeling program.  Overall goals developed for the program are stated in a general fashion  similar to many developed for the Great Lakes and are to (1) address  water quality and clarity problems caused by excess nutrients, sediments,  and toxics; (2) maintain and restore living resources of the bay, such as  controlling exotic species and protecting crabs and oysters; (3) protect  and restore vital habitats, such as wetlands and submerged aquatic  vegetation; (4) make sound land use decisions, such as land conservation;  and (5) engage the community through education and outreach. However,  the general goals are further defined as specific commitments that are  used to measure program progress.
As of December 2003, the program was endorsing over 40 measurable  environmental commitments for the watershed. The program has  prioritized commitments included in the most recent bay agreement,  Chesapeake 2000, by identifying the 10 most important “keystone  commitments” for the bay for focusing their efforts on critical needs and  making the best use of resources and capabilities. For example, one  keystone commitment for the overall goal of maintaining and restoring  living resources in the bay, is that by 2010, at a minimum, a tenfold  increase in native oysters should be achieved in the Chesapeake Bay,  using a 1994 baseline. In addition, this commitment involves developing  appropriate research and management strategies for attaining this  increase.
According to program officials, defining measurable goals and  commitments up front is the key to the success of the Chesapeake Bay  Program. If the goals are developed first, then they can be linked to the  appropriate measurement and tracking activities and indicators to  evaluate progress. Once program officials analyze the data collected from  monitoring, modeling, and tracking programs to determine progress, they  can decide on the appropriate actions to take to maintain or improve  conditions. Officials from organizations involved in the restoration and  protection of the bay agree that defining goals up front is important to the  restoration effort and that the Chesapeake Bay Program has done a good  job in this regard. For example, an official from the Chesapeake Bay  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,  it is uncertain whether this task force will provide definitive, stable  leadership needed over time because it may be readily changed by future  executive orders. Additionally, while GLNPO has existing statutory  responsibility for coordinating Great Lakes activities, it is unclear how its  responsibilities and those of other organizations fit with the coordination  activities of the new task force. EPA is now taking steps to implement the  Executive Order; however, it is unclear whether this fulfills its  responsibilities under the Clean Water Act. Absent a clearly defined  leadership structure, setting measurable goals and monitoring progress in  the Great Lakes is unlikely to be accomplished, and duplicative  responsibilities for coordination, goal setting, and monitoring may be  inevitable. EPA has recently demonstrated leadership on monitoring by  developing an inventory of all monitoring activities in the Great Lakes.  While we believe this is a worthwhile effort, controls should be in place to  ensure the completeness and accuracy of the data in the inventory.

	Matter for Congressional Consideration

In light of the uncertainty regarding how GLNPO’s responsibilities fit with  the newly created Great Lakes Interagency Task Force and to help ensure  the coordination of U.S. efforts in developing basin-wide measurable  restoration goals for the Great Lakes, as well as the development of a joint  monitoring system based on those goals, the Congress may want to  consider    clarifying whether GLNPO or the task force should lead the U.S. efforts in  restoring the Great Lakes and requiring this entity, in consultation with  Canada, the governors of the Great Lakes states, federal agencies, and  other organizations, to develop and prioritize specific measurable  restoration goals for the Great Lakes Basin within a certain time frame;  and  requiring the entity to develop and implement monitoring activities to  measure progress toward attaining goals and identify actions that could  assist in achieving these goals.
If the Congress decides that the task force should have the leadership role,  it may also want to consider whether additional Great Lakes Basin  stakeholders should be task force members, such as representatives of  states and other organizations.

	Recommendation for Executive Action

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

	Agency Comments and Our Evaluation

GAO provided EPA with a draft of this report for its review and comment.  The agency generally agreed with the findings and recommendations in  the report. EPA stated that the inventory of monitoring activities is a  critical component for monitoring and reporting efforts, and adequate  controls are needed to ensure that data are accurate, current, and  complete in order to facilitate users’ efforts to coordinate monitoring  activities. Accordingly, EPA stated it has begun taking steps to develop  these controls. Specifically, GLNPO will lead the U.S. efforts to track  entries into the inventory database to ensure that data from all agencies  are included. GLNPO will also request annual verification and updating by  organizations of their information to ensure that the database is accurate  and current. If effectively implemented, these steps should help ensure the  accuracy and usefulness of the inventory for coordination purposes.  Regarding our matter for the Congress to consider clarifying leadership  responsibilities, EPA stated that it believes the responsibilities for  organizational leadership in the Great Lakes for both GLNPO and Great  Lakes Interagency Task Force are clearly stated in the Clean Water Act  and the Executive Order, respectively. While EPA describes the overall  structure and responsibilities of the task force and GLNPO to support its  position, it does not address our concern that similar coordination  responsibilities are assigned to different organizations under the  Executive Order and the Clean Water Act. EPA states that the Executive  Order appoints the Great Lakes National Program Manager as chair of the  Great Lakes Regional Working Group and that this will enhance GLNPO’s  ability to meet its statutory obligation to coordinate federal restoration  activities. However, this does not address our point that the Clean Water  Act assigns GLNPO the responsibility of implementing specific action  plans to carry out U.S. responsibilities under the act, while under the  Executive Order, it is the task force, not GLNPO that will implement  recommendations of the working group. Further, EPA did not address our  concern that the task force does not provide the definitive, stable  leadership that is needed over time given that its responsibilities may be  changed by future executive orders. The full text of EPA’s comments is  included in appendix VII.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to appropriate  Congressional Committees; the EPA Administrator; various other federal  departments and agencies; and the International Joint Commission. We  also will make copies available to others upon request. In addition, the  report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staff have any questions, please call me at (202) 512-3841.  Key contributors to this report are listed in appendix VIII.

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  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

	State Agencies

	Canadian Agencies

	Other Organizations

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.

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

Appendix IV: State of Ohio Lake Erie  Programs and Initiatives with Monitoring  Activities Analysis of sport fish caught in Ohio waters for  toxins; results are basis for fish consumption  advisories.
State funded program, state administered.
Biennially assess Ohio’s water bodies and report  the status of impaired waters.
Federally requirement, jointly funded by  federal and state; administered by stste.
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.
Conduct nonpoint pollution abatement program  with focus on urban, residential, and commercial  sources.
State initiated, jointly funded by federal and  state.
Long-term program to reduce phosphorus loading  into Lake Erie.
Joint federal and state funded program;  administered by state.
State initiated and funded.
Indices measuring the health of streams based   on health and diversity of aquatic communities.
State initiated jointly funded by federal and  state.
Monitor swimming beaches for fecal bacteria  contamination using E. coli as test organism.
Joint federal and state funded program;  administered by state.
An analysis of water samples collected within the  Lake Erie basin to assess sediment, nutrient, and  metal compositions.
State initiated and funded.

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  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 self- reproducing and diverse biological communities.” Under the three overall  ecosystem goals, the LaMP also included the management plan’s  ecosystem objectives in five areas: aquatic communities, wildlife, human  health, habitat, and stewardship. These objectives describe in general  terms the conditions necessary to achieve the overall ecosystem goals, but  they are not stated in quantitative terms, prioritized, and do not contain  time frames. The Lake Ontario LaMP also contains 11 indicators based on  the Lake Ontario Toxics Management Plan and State of the Lakes  Ecosystem Conference indicator work. According to the LaMP, most  indicator monitoring needs are being met with existing monitoring  programs, but further monitoring efforts are planned to provide a more  complete assessment of lake conditions. The LaMP states that now that  indicators have been adopted, U.S. and Canadian officials will work to  develop a “cooperative monitoring” approach for promoting increased  communication and coordination between their monitoring programs.

	Lake Superior

The Lake Superior LaMP differs from other LaMPs in that it was developed  from an ongoing 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  prioritized, for critical pollutants, the LaMP provides specific, measurable  goals for reducing nine bioaccumulative toxic chemicals. 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.

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

	Council of Great Lakes GovernorsPriorities Task Force

Ensure the sustainable use of water resources while confirming that the  Great Lakes states retain authority over water use and diversion of Great  Lakes waters.
Promote programs to protect human health against adverse effects of  pollution in the Great Lakes ecosystem.
Control pollution from diffuse sources into the water, land, and air.
Continue to reduce the introduction of persistent bioaccumulative toxics  into the Great Lakes ecosystem.
Stop the introduction and spread of non-native aquatic invasive species.
Enhance fish and wildlife by restoring and protecting coastal wetlands,  fish, and wildlife habitats.
Restore to environmental health the areas of concern identified by the  International Joint Commission as needing remediation.
Standardize and enhance the methods by which information is collected,  recorded, and shared within the region.
Adopt sustainable use practices that protect environmental resources and  may enhance the recreational and commercial value of our Great Lakes.

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

Restore and maintain beneficial uses in each of the 31 U.S. and binational  areas of concern or “toxic hot spots,” with a special emphasis on  remediation of contaminated sediment.
Restore and protect the ecological and economic health of the Great Lakes  by preventing the introduction of new invasive species and limiting the  spread of established ones.
Improve Great Lakes water quality and economic productivity by  controlling nonpoint source pollution from water, land, and air pathways.
Restore 100,000 acres of wetlands and critical coastal habitat while  protecting existing high quality fish and wildlife habitat in the Great Lakes  Basin.
Ensure the sustainable use and management of Great Lakes water  resources to protect environmental quality and provide for water-based  economic activity in the Great Lakes states.
Meet domestic and international Great Lakes commitments through  adequate funding for, and the efficient and targeted operation of, federally  funded and management and research agencies.
Maximize the commercial and recreational value of Great Lakes  waterways and other coastal areas by maintaining and constructing  critical infrastructure and implementing programs for sustainable use.

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

Lists five areas where action is needed, such as funding toxic cleanups,  coordinating cleanup efforts, and treating contaminants.
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.
List five areas where action is needed, such as promoting energy  efficiency, conservation, and renewable energy sources.
Sustainable Water Quantities and Flows Action Agenda  Lists eight areas where action is needed such as implementing water  withdrawal reform and restoring basin ecosystem functions damaged or  lost due to harmful water withdrawal practices.
Protecting and Restoring Species Action Agenda  Lists 13 areas where action is needed to address invasive aquatic and  terrestrial species, and protect threatened species.
Protecting and Restoring Habitats Action Agenda  Lists 24 areas where action is needed to protect and restore aquatic, forest,  urban, and interconnecting habitats; and limit sprawl.

Appendix VII: Comments from the Environmental Protection Agency

Appendix VIII: GAO Contact and Staff Acknowledgments

	GAO Contact

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

	Staff Acknowledgments

In addition to the individual named above, Willie Bailey, Greg Carroll,  Nancy Crothers, John Delicath, Michael Hartnett, Karen Keegan, Amy  Webbink, and John Wanska made key contributions to this report.

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Summary:
Why GAO Did This Study

The Great Lakes remain environmentally vulnerable, prompting the United States and Canada to agree on actions to preserve and protect them. As requested, this report (1) determines the extent to which current EPA monitoring efforts provide information for assessing overall conditions in the Great Lakes Basin, (2) identifies existing restoration goals and whether monitoring is done to track goal progress, and (3) identifies the major challenges to setting restoration goals and developing a monitoring system.

What GAO Found

Current Environmental Protection Agency (EPA) monitoring does not provide the comprehensive information needed to assess overall conditions in the Great Lakes Basin because the required coordinated joint U.S./Canadian monitoring program has not been fully developed. Information collected from monitoring by other federal and state agencies does not, by design, provide an overall assessment of the Great Lakes because it is collected to meet specific program objectives or limited to specific geographic areas. Multiple restoration goals have been proposed through efforts by EPA and other organizations. EPA developed basin-wide goals through its Great Lakes Strategy 2002 and goals for plans addressing individual lakes. Other organizations have also identified basin-wide restoration goals and priorities. Monitoring of progress toward goals is generally limited to tracking specific action items proposed in the Great Lakes Strategy 2002; other proposed goals are generally not monitored to determine progress. Efforts to coordinate basin-wide goals and a monitoring system face several challenges. The lack of clearly defined organizational leadership poses a major obstacle. Both EPA's Great Lakes National Program Office (GLNPO) and a newly created interagency task force have coordination roles raising uncertainty as to how leadership and coordination efforts will be exercised in the future. Second, coordinating existing restoration goals and monitoring activities among the many participating organizations within the United States, and between the United States and Canada is a significant challenge. Third, centralized information from monitoring activities is not yet available, making it difficult to assess restoration progress. In addition, an inventory system developed by EPA and Canada may not have adequate controls on voluntarily provided information.