Report to Congressional Requesters

United States Government Accountability Office

GAO

September 2004 GREAT LAKES 

Organizational 

Leadership and 

Restoration Goals 

Need to Be Better 

Defined for 

Monitoring 

Restoration Progress 

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

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact John 

Stephenson (202) 512-3841 or 

stephensonj@gao.gov. 

Highlights of GAO-04-1024, a report to

congressional requesters 

September 2004

GREAT LAKES

Organizational Leadership and 

Restoration Goals Need to Be Better 

Defined for Monitoring Restoration 

Progress 

The Great Lakes remain 

environmentally vulnerable, 

prompting the United States and 

Canada to agree on actions to 

preserve and protect them. 

As requested, this report (1) 

determines the extent to which 

current EPA monitoring efforts 

provide information for assessing 

overall conditions in the Great 

Lakes Basin, (2) identifies existing 

restoration goals and whether 

monitoring is done to track goal 

progress, and (3) identifies the 

major challenges to setting 

restoration goals and developing a 

monitoring system. 

GAO recommends EPA develop 

controls to ensure the Great Lakes 

monitoring system inventory is 

complete, accurate, and consistent. 

Also, the Congress may wish to 

consider clarifying if GLNPO or the 

task force should lead restoration 

efforts and require development of 

measurable basin-wide goals with a 

monitoring system for measuring 

progress. 

EPA agreed with GAO’s 

recommendation regarding 

adequate inventory monitoring 

controls. EPA believes 

responsibilities and relationships 

for the task force and GLNPO are 

clearly stated in the executive 

order and statute but did not 

address GAO’s concerns about how 

GLNPO will exercise its leadership 

and coordination responsibilities. 

Current Environmental Protection Agency (EPA) monitoring does not 

provide the comprehensive information needed to assess overall conditions 

in the Great Lakes Basin because the required coordinated joint 

U.S./Canadian monitoring program has not been fully developed. 

Information collected from monitoring by other federal and state agencies 

does not, by design, provide an overall assessment of the Great Lakes 

because it is collected to meet specific program objectives or limited to 

specific geographic areas. 

Multiple restoration goals have been proposed through efforts by EPA and 

other organizations. EPA developed basin-wide goals through its Great 

Lakes Strategy 2002 and goals for plans addressing individual lakes. Other 

organizations have also identified basin-wide restoration goals and priorities. 

Monitoring of progress toward goals is generally limited to tracking specific 

action items proposed in the Great Lakes Strategy 2002; other proposed 

goals are generally not monitored to determine progress. 

Efforts to coordinate basin-wide goals and a monitoring system face several 

challenges. The lack of clearly defined organizational leadership poses a 

major obstacle. Both EPA’s Great Lakes National Program Office (GLNPO) 

and a newly created interagency task force have coordination roles raising 

uncertainty as to how leadership and coordination efforts will be exercised 

in the future. Second, coordinating existing restoration goals and 

monitoring activities among the many participating organizations within the 

United States, and between the United States and Canada is a significant 

challenge. Third, centralized information from monitoring activities is not 

yet available, making it difficult to assess restoration progress. In addition, 

an inventory system developed by EPA and Canada may not have adequate 

controls on voluntarily provided information. 

Great Lakes Basin Area in the United States and Canada 

St. Lawrence

River

WI

MN

IL IN

OH

PA

NY

Ontario

Quebec

L. Erie

L. Ontario

L. Huron

L. Mich gi an

L. Superior

Cleveland Chicago

Milwaukee

Great Lakes Basin

Source: GAO. 

Toronto

Detroit
Page i GAO-04-1024 Great Lakes 

Letter 1

Results in Brief 3 

Background 5 

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 10 

Multiple Goals Exist for Monitoring Restoration Progress 18 

Significant Challenges Exist for Setting Basin-Wide Goals and 

Developing a Monitoring System for the Great Lakes 21 

Conclusions 34 

Matter for Congressional Consideration 35 

Recommendation for Executive Action 36 

Agency Comments and Our Evaluation 36 

Appendix I Scope and Methodology 40 

Appendix II Federal, State, Canadian, and Other Organizations 

That Provided Great Lakes Monitoring and 

Research Information 42 

Appendix III Comments by Officials on Need for Indicators and 

Monitoring in the Great Lakes Basin 44 

Appendix IV State of Ohio Lake Erie Programs and Initiatives 

with Monitoring Activities 48 

Appendix V Observations on Goals and Monitoring Information 

Contained in LaMPs for Four Great Lakes 49 

Appendix VI Goals and Priorities Established by Three Great 

Lakes Organizations 52 

Contents 
Page ii GAO-04-1024 Great Lakes 

Appendix VII Comments from the Environmental Protection 

Agency 54 

Appendix VIII GAO Contact and Staff Acknowledgments 58 

GAO Contact 58 

Staff Acknowledgments 58 

Table 

Table 1: Summary Comments by Officials on the Need for 

Indicators and Comprehensive Monitoring in the Great 

Lakes Basin 44 

Figures 

Figure 1: Area Comprising the Great Lakes Basin 6 

Figure 2: GLNPO’s Water Quality Survey Sampling Stations 15 

Figure 3: Differences in Characteristics of Lake Superior and Lake 

 Erie 31 
Page iii GAO-04-1024 Great Lakes 

Abbreviations 

BEC Binational Executive Committee 

EC Environment Canada 

EPA Environmental Protection Agency 

FWS U.S. Department of Interior’s Fish and Wildlife Service 

GLERL Great Lakes Environmental Research Laboratory 

GLFC Great Lakes Fishery Commission 

GLISP Great Lakes International Surveillance Plan 

GLNPO Great Lakes National Program Office 

GLWQA Great Lakes Water Quality Agreement 

IADN International Atmospheric Deposition Network 

IJC International Joint Commission 

LaMP Lakewide Management Plan 

NAWQA National Water Quality Assessment 

NHEERL National Health Environmental Effects Research 

 Laboratory 

NRRI Natural Resources Research Institute 

NOAA National Oceanic and Atmospheric Administration 

ORD Office of Research and Development 

PCB polychlorinated biphenyl 

SOLEC State of the Lakes Ecosystem Conference 

TMDL Total Maximum Daily Load 

USGS U.S. Geological Survey 

USPC U.S. Policy Committee 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-04-1024 Great Lakes 

September 28, 2004 

Congressional Requesters 

The Great Lakes, the largest system of freshwater in the world, is 

recognized by the United States and Canada as a natural resource that is 

threatened on many environmental fronts. Recently discovered conditions 

such as the reemergence in Lake Erie of a “dead zone”—an area that has 

little or no dissolved oxygen and, therefore, cannot support aquatic life—

have renewed concerns about the overall ecological health of the Great 

Lakes Basin, which includes the five Great Lakes—Superior, Michigan, 

Huron, Erie, and Ontario—and a large land area that extends beyond the 

lakes, including their watersheds, tributaries, connecting channels, and a 

portion of the St. Lawrence River. While the two countries have made 

some progress in protecting and restoring the Great Lakes ecosystem—the 

air, water, land, and living organisms within the basin—polluted beaches 

are frequently closed to swimmers, fish are unsafe to eat for high-risk 

individuals, and raw sewage is still being dumped into the lakes. While 

some information on environmental conditions of the Great Lakes is 

available, questions remain as to overall conditions and the progress of 

restoration. 

As concern increased over the contamination of the Great Lakes, the 

United States and Canada signed the first international Great Lakes Water 

Quality Agreement (GLWQA) in 1972. In the agreement, the United States 

and Canada agreed to restore and maintain the chemical, physical, and 

biological integrity of the Great Lakes Basin. The overall goals of the 

GLWQA are to restore and enhance water quality in the lakes. In 1978, the 

parties signed another Great Lakes Water Quality Agreement that 

reaffirmed their determination to restore and enhance water quality and 

called for increasing control of toxic substances throughout the Great 

Lakes Basin. Subsequently, amendments were made to the 1978 agreement 

in 1983 and 1987. The 1987 Protocol amendments added several annexes 

that focused on specific environmental concerns and amended one, Annex 

11, on surveillance and monitoring. Annex 11 requires the two countries to 

undertake a joint program to, among other things, monitor restoration 

progress and assess the degree to which the parties are complying with the 

requirements and objectives of the agreement. Monitoring is accomplished 

through various sampling methods, such as using air monitoring 

equipment to measure the deposition of toxic chemicals. Monitoring may 

help identify the source and extent of problems and aid decision makers in 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-04-1024 Great Lakes 

setting restoration goals, taking action, and determining the extent to 

which goals are being met. Goals should be stated in measurable terms in 

order to monitor progress. In an effort to establish restoration strategies to 

meet the overall goals of the GLWQA, the U.S. Policy Committee 

(USPC)a forum of senior level representatives from the federal, state, 

and tribal government agencies that share responsibility for environmental 

protection and resource management in the Great Lakesdeveloped the 

Great Lakes Strategy 2002. EPA efforts in establishing goals also include 

helping to develop Lakewide Management Plans (LaMP) for each of the 

individual Great Lakes. 

In addition, a joint effort by the two countries to assess and report on 

environmental conditions in the Great Lakes began in 1994, with the first 

State of the Lakes Ecosystem Conference (SOLEC). The conference has 

convened every 2 years thereafter and its proceedings are used as a basis 

for reporting on the state of the lakes. In the late 1990s, SOLEC began 

developing a comprehensive set of indicators on the condition of the Great 

Lakes ecosystem. SOLEC’s reports have described indicators such as 

chemical contaminants in edible fish tissue and toxic chemical 

concentrations in offshore waters. 

The Clean Water Act charges the U.S. Environmental Protection Agency 

(EPA) with leading the effort to meet the requirements of the GLWQA. The 

act also statutorily established the Great Lakes National Program Office 

(GLNPO) within EPA, charging it with, among other things, cooperating 

with federal, state, tribal, and international agencies to develop and 

implement specific action plans to carry out the U.S. responsibilities under 

the agreement. In addition to the various governmental agencies involved 

in Great Lakes restoration, several nongovernmental organizations have 

established restoration goals. In 2003, we reported that an overall strategy 

was needed to guide numerous ongoing restoration activities and that 

indicators and a monitoring system were needed to measure overall 

restoration progress.1

You asked us to (1) determine the extent to which current EPA monitoring 

efforts provide information for assessing overall conditions in the Great 

Lakes Basin and what information is provided by other organizations 

conducting monitoring in the Great Lakes, (2) identify existing restoration 

 1

GAO, Great Lakes: An Overall Strategy and Indicators for Measuring Progress Are 

Needed to Better Achieve Restoration Goals, GAO-03-515 (Washington, D.C.: Apr. 30, 2003). 
Page 3 GAO-04-1024 Great Lakes 

goals and whether monitoring is done to track goal progress, and (3) 

identify the major challenges to setting basin-wide restoration goals and 

developing a monitoring system for the Great Lakes. 

To address the extent to which information derived from monitoring is 

useful for assessing overall conditions in the Great Lakes Basin, we 

reviewed information on monitoring activities conducted by U.S. and 

Canadian federal agencies and the eight states and two Canadian 

provinces that share the basin. We also examined the monitoring 

requirements included in the GLWQA and compared these requirements 

with ongoing monitoring and SOLEC activities. To identify existing 

restoration goals, we reviewed the goals and monitoring efforts contained 

in the Great Lakes Strategy 2002 and EPA’s LaMPs for four of the five 

Great Lakes. We also examined the restoration goals of several 

organizations participating in the restoration of the Great Lakes. To 

identify major challenges to setting restoration goals and developing a 

monitoring system for the Great Lakes, we obtained and analyzed 

information on several barriers to progress and focused on four major 

challenges involving organizational leadership, coordinating goals and 

monitoring, centralized information on monitoring activities, and 

environmental differences between the lakes. We conducted our work 

from August 2003 to May 2004 in accordance with generally accepted 

government auditing standards. A more detailed discussion of our scope 

and methodology is outlined in appendix I. 

Current EPA monitoring does not provide the comprehensive information 

needed to monitor restoration progress and assess the degree to which the 

parties are complying with the requirements and objectives of the 

agreement because the coordinated joint U.S./Canadian monitoring 

program mandated under the GLWQA has not been fully developed. Other 

federal and state organizations are conducting monitoring efforts but, 

while useful, they are limited to specific purposes and geographical scope. 

Rather than developing a basin-wide monitoring system to assess overall 

conditions in the Great Lakes, EPA focused its efforts on supporting 

SOLEC in developing a comprehensive set of environmental indicators and 

using some of the indicators for reporting on overall conditions in the 

Great Lakes Basin. While SOLEC has identified and evaluated a large 

number of indicators, both Canadian and U.S. officials have questioned the 

value of the information reported by SOLEC from these indicators 

because, among other things, it is not based on their decision-making 

needs. Specifically, SOLEC attempts to describe overall conditions based 

on information voluntarily provided and maintained by others, and it does 

Results in Brief 
Page 4 GAO-04-1024 Great Lakes 

not assess whether conditions are improving or deteriorating based on 

measurable restoration goals. Additionally, most of the information 

collected from monitoring activities by other federal and state 

organizations does not, by design, provide an overall assessment of 

restoration progress in the Great Lakes Basin because it is collected to 

meet specific program objectives or limited to specific geographic areas

such as monitoring water quality to determine whether some beaches are 

safe for swimming or monitoring to support research in a particular area 

of the Great Lakes. State organizations generally conduct monitoring in 

the inland and nearshore areas while federal monitoring extends to the 

open lake water areas. 

EPA and other organizations have proposed multiple restoration goals; 

however, few have monitoring activities to track restoration progress 

called for in the goals. EPA developed basin-wide goals through its Great 

Lakes Strategy 2002 and devised goals for individual lakes in LaMPs. 

Monitoring progress toward achieving goals is generally limited to tracking 

action items proposed in the Great Lakes Strategy 2002; the LaMPs 

discuss indicators and monitoring, but they are not often linked to goals or 

do not show how progress toward goals will be measured. Other 

organizations concerned with Great Lakes restoration, such as the Council 

of Great Lakes Governors, have also identified basin-wide restoration 

goals and priorities. Several of the organizations’ goals are similar, 

representing a relative consensus among the groups. While these goals are 

useful in communicating what specific issues the groups believe are 

important to the Great Lakes, these organizations may not have the 

resources or capacity to engage in basin-wide monitoring, and additional 

specifics may be needed to determine whether the goals are being 

achieved. 

Those involved in protecting and restoring the Great Lakes face four 

significant challenges in setting measurable goals and developing a basinwide monitoring system: the lack of clearly defined organizational 

leadership, the inherent difficulty associated with coordinating existing 

goal setting and monitoring activities among the many participating 

organizations in the United States and between the United States and 

Canada, the lack of centralized information from monitoring activities to 

assess restoration progress, and the unique environmental dynamics of 

each of the lakes. First, responsibility for leading and coordinating U.S. 

efforts to meet GLWQA requirements rests with EPA and GLNPO, 

according to the Clean Water Act. However, this role has never been 

completely filled by GLNPO because it has not fully exercised its 

coordination authority. Other organizations have attempted to fill the void. 
Page 5 GAO-04-1024 Great Lakes 

Most recently, this executive order created a new interagency task force 

within EPA to coordinate Great Lakes activities, but its long-term 

effectiveness is unclear because executive orders may be changed or 

rescinded by future administrations, and this executive order cannot be 

enforced in court as is often the case with statutes. In addition, the future 

role of GLNPO and other organizations in relation to the task force is 

unclear. Second, existing restoration goals and monitoring activities in the 

United States and within Canada need to be coordinated if basin-wide 

goals are to be established and a joint monitoring system developed as 

called for in the GLWQA. Given the extensiveness of Canada’s efforts, and 

agreements between Canada and the provinces of Ontario and Quebec, it 

will be a challenge to coordinate with Canada in developing basin-wide 

goals for measuring restoration progress. Third, the lack of an accurate, 

complete, and centralized source of existing monitoring information for 

coordinating activities and assessing basin-wide conditions is a significant 

challenge. GLNPO and Environment Canada have developed an Internetbased inventory for existing monitoring systems, but this inventory will 

rely on voluntarily provided information, which will not ensure enough 

control over the information so that it will result in an inventory with 

complete, accurate, and consistent information. Fourth, because each of 

the five Great Lakes has unique environmental conditions, setting 

measurable goals that reflect these differences and yet provide consistent 

basin-wide information will be difficult. 

To help ensure the coordination of the U.S. efforts in developing basinwide measurable restoration goals with a monitoring system, we 

recommend that the Congress may wish to consider clarifying whether 

GLNPO or the interagency task force should lead restoration efforts for 

the United States and require the entity it selects to develop and prioritize 

measurable goals for the Great Lakes Basin and develop and implement a 

monitoring system to measure progress toward attaining goals along with 

identifying actions that could assist in achieving goals. 

In addition, we are recommending that the EPA Administrator direct 

GLNPO to develop controls for the automated inventory to ensure that the 

information it contains is complete, accurate, and consistent. 

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 

Background 
Page 6 GAO-04-1024 Great Lakes 

Lakes Basin, roughly 10 percent of the U.S. population and more than 30 

percent of the Canadian population. Spanning more than 750 miles from 

west to east, the basin encompasses nearly all of the state of Michigan and 

parts of Illinois, Indiana, Minnesota, New York, Ohio, Pennsylvania, 

Wisconsin, and the Canadian province of Ontario. Parts of the St. 

Lawrence River, the connecting channel between Lake Ontario and the 

Atlantic Ocean, flow through the provinces of both Ontario and Quebec. 

Figure 1: Area Comprising the Great Lakes Basin 

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 

MI

St. Lawrence

River

WI

MN

IL

IN OH

PA

NY

Ontario

Quebec

L. Erie

L. Ontario

L. Huron

L. Mich gi an

L. Superior

Cleveland Chicago

Milwaukee

Great Lakes Basin

Source: GAO. 

Toronto

Detroit
Page 7 GAO-04-1024 Great Lakes 

principal means of dealing with eutrophication in the lakes. Under the 

terms of the GLWQA, the two governments are required to conduct a 

comprehensive review of the operation and effectiveness of the agreement 

every 6 years. The next review is scheduled to begin in 2004, and based 

upon the results, the two countries may decide to amend the agreement. 

The last review in 1999 found that certain sections of the agreement were 

outdated and revisions were needed. 

As amended, the GLWQA has 17 annexes that define in detail the specific 

programs and activities that the two parties have agreed upon and 

committed to implement. Most of the annexes specify pollution prevention 

strategies. Annex 11 of the GLWQA calls for the parties to implement a 

joint surveillance and monitoring program that, among other things, 

evaluates water quality trends, identifies emerging problems, and supports 

the development of remedial action plans for contaminated areas—-

referred to as areas of concern—-and LaMPs for the open waters of each 

of the five lakes to reduce critical pollutants and to restore and protect 

beneficial uses.2

 Specifically, Annex 11 calls for the monitoring program to 

include baseline data collection, sample analysis, and evaluation and 

quality assurance programs to assess such things as whole lake data 

including that for open waters and nearshore areas of the lakes as well as 

fish and wildlife contaminants; inputs from tributaries, point source 

discharges, atmosphere, and connecting channels; and total pollutant 

loadings to and from the Great Lakes system. 

The monitoring program under Annex 11 is to be based on the Great Lakes 

International Surveillance Plan (GLISP) developed before the current 

requirements for a surveillance and monitoring system. Developing the 

surveillance plan, which involved developing a separate plan for each lake, 

required extensive efforts by U.S. and Canadian officials over several 

years. However, according to one Canadian official involved in the 

process, the plans were not completed to the point where they could be 

implemented. The IJC’s Water Quality Board was involved in the 

management and development of the GLISP, but according to a binational 

review of the GLWQA in 1999, the IJC’s role was reduced after the GLQWA 

amendments of 1987 placed more of the responsibility for data analysis 

and reporting on the state of the Great Lakes environment with the two 

 2

We reported no the progress made on remedial action plans in GAO, Great Lakes: EPA 

Needs to Define Organizational Responsibilities Better for Effective Oversight and 

Cleanup of Contaminated Areas, GAO-02-563 (Washington, D.C.: May 17, 2002). 
Page 8 GAO-04-1024 Great Lakes 

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, 
Page 9 GAO-04-1024 Great Lakes 

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. 
Page 10 GAO-04-1024 Great Lakes 

Assisting the task force is a working group composed of regional federal 

officials with GLNPO providing resources for both groups. 

Current EPA monitoring efforts do not provide comprehensive 

information on the condition of the Great Lakes, and the coordinated joint 

surveillance and monitoring program called for in the GLWQA has yet to 

be fully developed. Other ongoing monitoring efforts by federal and state 

agencies yield information that is limited to specific purposes and 

geographical scope. The joint efforts by the United States and Canada to 

develop information on Great Lakes indicators through the SOLEC 

process does not fulfill the monitoring requirements of the GLWQA or 

adequately assess basin-wide conditions of the lakes. Further, the 

information reported from SOLEC is of questionable value to officials 

making restoration decisions because it is not based on their decisionmaking needs. Additionally, current monitoring efforts of federal and state 

organizations do not, by design, provide comprehensive information on 

the overall conditions of the Great Lakes. Most of the information 

collected under these monitoring activities is designed to meet specific 

program objectives or is limited to specific geographic areas as opposed to 

providing an overall assessment of the Great Lakes Basin. 

Annex 11 of the GLWQA calls for the United States and Canada to develop 

a joint Great Lakes system-wide surveillance and monitoring program to, 

among other things, provide information on restoration progress and 

whether the objectives of the agreement are being achieved. This program, 

however, has not been fully developed. Instead, officials from GLNPO look 

upon SOLEC as the process by which indicators will be developed to 

monitor environmental conditions and measure restoration progress in the 

Great Lakes. However, as we reported in 2003, the SOLEC process of 

holding conferences every 2 years to develop Great Lakes indicators and 

monitor environmental conditions for subsequent reporting on the state of 

the lakes falls short in several areas.3

 First, indicators assessed through the 

process do not provide an adequate basis for making an overall 

assessment of Great Lakes restoration because they rely on limited 

quantitative data and subjective judgments. Second, the SOLEC process is 

dependent on the voluntary participation of officials from federal and state 

agencies, academic institutions, and other organizations. As a result, their 

future commitment to providing information on indicators and monitoring 

 3

GAO-03-515. 

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 Efforts Do Not 

Fulfill Monitoring 

Requirements of the 

GLWQA 
Page 11 GAO-04-1024 Great Lakes 

results, along with their future participation, is not assured. Finally, most 

of the stated objectives for SOLEC do not align with the surveillance and 

monitoring program envisioned in the GLWQA. The stated objectives of 

SOLEC are to 

• assess the state of the Great Lakes ecosystem based on accepted 

indicators, 

• strengthen decision making and management, 

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

• provide a forum for communication and networking among stakeholders. 

Other than the objective for assessing the state of the ecosystem based on 

accepted indicators, the SOLEC objectives do not address issues related to 

monitoring. GLNPO officials stated that the objective of SOLEC is not to 

be a monitoring program but rather a reporting venue for conditions in the 

Great Lakes. However, it is the only ongoing effort to provide an overall 

assessment of the Great Lakes and, according to 23 federal, state, and 

other environmental program officials, a surveillance and monitoring 

system is still needed. For example, a Michigan state official explained 

that a monitoring system developed with the involvement of all 

stakeholders and focused on the differences in individual lakes is needed. 

Appendix III contains the specific comments from the officials we 

contacted regarding the need for a monitoring system. 

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. 

SOLEC’s Monitoring 

Information Is of 

Questionable Value in 

Decision Making 
Page 12 GAO-04-1024 Great Lakes 

The comments by program officials are supported by results from a peer 

review of SOLEC in 2003 by an international panel of experts in large 

indicator systems. While the panel had many favorable observations of 

SOLEC, they noted a disconnect between the development of the 

indicators and their usefulness to policy makers. The peer review stated 

that, to be effective, the actual users must define indicators, with policy 

makers and environmental managers involved in the early stages of 

indicator development. In addition to these observations, in the latest 

report on the state of the Great Lakes, one of the management challenges 

discussed is how to better assist managers given the large number of 

indicators.4

 Specifically, the challenge is to find a method of indexing 

indicators that better assists managers and leads to more useful, informed 

decision making. The disconnect between SOLEC and decision makers is 

further illustrated by the fact that only two of the eight Great Lakes states 

we contacted were reporting information from local monitoring efforts to 

support the SOLEC process and that none of the states reported using the 

monitoring information published by SOLEC to describe conditions of its 

local water bodies or to measure restoration progress. One Minnesota 

official stated that the former head of the state environmental agency 

viewed SOLEC information as irrelevant to describe conditions within the 

state. 

A GLNPO official working on SOLEC stated that developing effective 

indicators requires that you first ask what is to be measured, what the best 

indicator is for this measurement, how much data are needed, who will 

collect and handle the data for consistency, and how often the 

measurement will take place. He stated that the need to ask these 

questions dates back to the early 1980s, but actions to implement this 

indicator-monitoring program never materialized. Instead, different 

indicators and monitoring programs are being conducted by various 

agencies using different sampling methodologies and protocols, and this 

inconsistent local program information cannot, after the fact, be used to 

make decisions about system-wide needs or environmental conditions. 

Second, SOLEC information is based on limited data that further detracts 

from its usefulness to decision makers. For example, of the 80 SOLEC 

indicators reported to describe the Great Lakes Basin in 2003, evaluative 

data were only available for 43 of them. Often this data was geographically 

 4

Environment Canada and U.S. Environmental Protection Agency, State of The Great Lakes 

2003, EPA 905-R-03-004. 
Page 13 GAO-04-1024 Great Lakes 

limited and did not address conditions within the entire basin. 

Additionally, the IJC reported in its 2002 biennial report that sufficient 

data were not being collected from around the Great Lakes and that the 

methods of collection, the data collection time frames, the lack of uniform 

protocols, and the incompatible nature of some data jeopardized their use 

as indicators.5

Third, there is no guarantee that SOLEC information will be consistently 

collected or will be available in the future. As we reported earlier, the 

SOLEC process involves individuals providing information on a voluntary 

basis with the indicator data residing in a diverse number of sources with 

limited control by SOLEC organizers.6

 Therefore, there is no assurance 

that the information will continue to be collected or consistently reported 

over time. Environmental program officials from federal, state, and 

provincial agencies stated that the process lacks sufficient and consistent 

monitoring information to measure environmental restoration progress. 

The SOLEC peer review group found that the SOLEC process has serious 

flaws regarding lack of repeatability and transparency. According to 

GLNPO officials, SOLEC organizers attempted to address the issue of 

repeatability and transparency in 2003 by issuing a technical report, which 

provides additional information on data sources. Further, the process is 

lacking in standard methodology, and SOLEC has yet to establish standard 

protocols to improve data comparability and reliability. 

One attempt to measure restoration progress in the basin using SOLEC 

indicators is presented in EPA’s fiscal year 2005 budget justification. To 

measure progress, a single quantitative score is derived based on a formula 

using eight SOLEC indicators. Each indicator is given a score from 1 to 5 

based on the professional judgments of individuals providing the indicator 

information. A score of 1 is considered poor, and 5 is considered good. 

Totaling the individual indicator scores resulted in a score of 20 based on a 

total 40-point scale for the Great Lakes. While this is an attempt to 

measure overall progress, the scoring process is based on a limited 

number of indicators, and the point scores are based on subjective 

judgment. Further, the indicators described in the budget justification do 

not align with the ones used in developing the scores. According to 

GLNPO officials, this may have resulted from information being submitted 

at different times during the development of the budget justification. 

 5

IJC, 11th Biennial Report on Great Lakes Water Quality, (Sept. 12, 2002). 

6

GAO-03-515. 
Page 14 GAO-04-1024 Great Lakes 

In addition to EPA’s efforts, several federal and state agencies conduct 

monitoring for specific purposes within the open waters, nearshore, and 

inland areas of the Great Lakes Basin.7

 Monitoring is done in these areas 

for assessing environmental conditions, as part of ongoing federal or state 

programs, or for research purposes. The geographic areas monitored are 

generally limited and only specific conditions are monitored. In a few 

cases, such as monitoring the air deposition of toxic substances, 

monitoring of specific conditions covers an extensive area. Monitoring by 

state organizations is generally limited to federal or state program 

purposes and conducted in the nearshore or inland areas of the basin, 

such as identifying impaired waterways that may be tributaries to the 

lakes under the Clean Water Act. Open lake monitoring is generally done 

by federal agencies, like GLNPO, for specific research or program 

purposes and not as part of an overall assessment of the Great Lakes. 

Four federal agencies, EPA, National Oceanic and Atmospheric 

Administration (NOAA), U.S. Geological Survey (USGS), U.S. Department 

of Interior’s Fish and Wildlife Service (FWS), and one international 

commission, the Great Lakes Fishery Commission (GLFC), have ongoing 

monitoring activities for specific purposes within limited areas of the 

Great Lakes Basin. EPA’s GLNPO conducts four monitoring activities. 

First, GLNPO conducts annual monitoring of open lake water areas for the 

specific purpose of gathering information on water quality and biological 

conditions. The information gathered includes toxic pollutant levels of 

persistent substances, such as phosphorous. These sampling efforts are 

generally conducted twice each year, once in spring and once in summer, 

when the Lake Guardian travels to various fixed sampling sites on each of 

the lakes (see fig. 2). Sampling information collected during these 

assessments is stored in an automated database and is limited to assessing 

long-term trends in open lake waters. GLNPO officials stated that it takes 

about 6 to 7 years of data before enough information is available to 

identify a long-term trend. 

 7

Inland areas include rivers, tributaries, and streams flowing into the lakes; nearshore 

includes the shoreline out to where the open lake begins, which is where water is 30 feet 

deep or a distance of 2 miles from the shoreline, according to GLNPO officials. 

Information from Other 

Federal and State 

Monitoring Efforts Is 

Limited by Purpose and 

Geographic Scope 

Monitoring by Federal Agencies 
Page 15 GAO-04-1024 Great Lakes 

Figure 2: GLNPO’s Water Quality Survey Sampling Stations 

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.8

 These 

data are assessed with open lake data to determine possible adverse 

impacts on the food web that ultimately pose a human health risk. The 

scope of sediment monitoring is limited to certain areas, and GLNPO 

officials stated that they believe their main responsibility is open lake 

monitoring under the GLWQA and that the Great Lakes states are 

responsible for inland and tributary monitoring. Third, GLNPO conducts 

the U.S. portion of IADN for the specific purpose of monitoring toxic 

substances deposited through the air. Monitored toxic substances include 

 8

Small invertebrates in sediments are bottom-dwelling organisms that can become 

contaminated and consumed by birds or fish, which can adversely affect the food web once 

humans eat these birds or fish. 

Lake Huron

Lake Superior

Lake Michigan Lake Erie

Lake Ontario

MI

WI

IL IN OH

PA

NY

MN

Sources: EPA and GAO.
Page 16 GAO-04-1024 Great Lakes 

polychlorinated biphenyls (PCB) and trace metals, such as lead and 

cadmium, that have entered the watershed. While GLNPO is responsible 

for monitoring in the United States, EC is responsible for Canadian 

locations. IADN consists of 5 master sampling stations and 10 satellite 

stations located throughout the basin and is limited to identifying 

substances deposited through the air. Fourth, GLNPO conducts an annual 

fish program to monitor concentrations of contaminants in Great Lakes 

fish. GLNPO has agreements with the Universities of Minnesota, Indiana, 

and Wisconsin, along with USGS, to collect specific fish species from each 

lake and grind them into paste to analyze for contaminants that might pose 

a risk to humans if consumed. 

In addition to GLNPO’s monitoring efforts, EPA’s Office of Research and 

Development (ORD) funds research activities involving developing 

indicators and Great Lakes monitoring. There are four divisions within 

ORD’s National Health Environmental Effects Research Laboratory 

(NHEERL), and one of thesethe Mid-Continent Ecology Division located 

in Duluth, Minnesotaconducts research related to fresh water issues 

involving human health, which includes the Great Lakes. In addition to the 

research conducted by this office, ORD, through its National Center for 

Environmental Research, has an ongoing cooperative agreement with the 

Natural Resources Research Institute (NRRI) of the University of 

Minnesota, Duluth, to develop environmental indicators specifically for 

the nearshore areas of the Great Lakes. Once NRRI develops indicators for 

all of the nearshore areas, the results will be published and submitted to 

ORD for developing an implementation plan measuring environmental 

conditions in the Great Lakes, according to NRRI researchers. 

Two other federal agencies, NOAA and USGS, conduct monitoring for 

specific purposes within the basin. NOAA’s Great Lakes Environmental 

Research Laboratory (GLERL) located in Ann Arbor, Michigan, has 15 

specific legislative mandates for research or monitoring, according to a 

GLERL official. Specific research efforts by NOAA are in areas such as 

water quality, quantity, and levels. NOAA is also developing an 

experimental Great Lakes Observing network. This network will consist of 

observation buoys that are linked to satellites, strategically located 

throughout the five Great Lakes, for collecting specific chemical, physical, 

and biological information needed for ecosystem forecasting. A NOAA 

prototype system is deployed in Lake Erie, using three buoy sites, and 

focused on gathering information on the reemergence of the lake’s dead 

zone. 
Page 17 GAO-04-1024 Great Lakes 

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. 

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.9

 Another example 

of a federal program involving state monitoring is the Beach Monitoring 

 9

GAO, Water Quality: Inconsistent State Approaches Complicate Nation’s Efforts to 

Identify Its Most Polluted Waters, GAO-02-186 (Washington, D.C.: Jan. 11, 2002). 

Monitoring by State 

Organizations 
Page 18 GAO-04-1024 Great Lakes 

Program under the Beach Act. This program involves sampling of only the 

nearshore waters of state beaches for the presence of bacteria to 

determine if the water is safe for swimming. 

In addition, states conduct monitoring in the Great Lakes Basin for state 

requirements. For example, in Ohio, two state agencies—the Ohio 

Environmental Protection Agency and the Ohio Department of Natural 

Resourcesconduct routine monitoring in Lake Erie’s nearshore and 

inland areas for several state and federal programs. These agencies 

conduct monitoring to assess water quality in the state’s streams and 

rivers, ambient groundwater quality, tributary quality, and changes in fish 

and wildlife populations. Appendix IV contains information on nine 

programs involving monitoring activities in Ohio. In addition to federal 

program monitoring, some states fund and conduct their own monitoring 

activities in the Great Lakes Basin. The extent to which states conduct 

their own monitoring activities beyond federal requirements is closely tied 

to available state funding for monitoring. 

State organizations generally conduct monitoring activities in the 

nearshore or inland areas. For example, Michigan has a state program to 

address water quality issues with funding specifically devoted to 

monitoring. Voters approved a special state bond issue authoritythe 

Clean Michigan Initiativein 1998, which provided funding to the 

Michigan Department of Environmental Quality for surface water quality 

monitoring. Supported by initial Clean Michigan Initiative funding in 2000, 

the Michigan program funds monitoring activities in the state’s rivers, 

streams, tributaries, and Great Lakes water bodies. Among other things, 

monitoring is conducted to assess contaminant levels in fish and other 

wildlife, as well as water and sediment. 

Multiple restoration goals have been proposed by EPA and other 

organizations that could be a basis for monitoring restoration progress. 

EPA developed basin-wide goals in its Great Lakes Strategy 2002 and 

goals for individual lakes in LaMPs. Other organizations concerned with 

Great Lakes restoration, such as the Council of Great Lakes Governors, 

have also identified basin-wide restoration goals and priorities. Monitoring 

progress toward achieving goals is generally limited to tracking specific 

action items contained in the Great Lakes Strategy 2002; other proposed 

goals do not have associated monitoring activities or monitoring plans to 

determine progress. Additional specifics for many of the proposed goals 

and monitoring plans may be needed if the goals are to be used in 

determining whether progress is being achieved. 

Multiple Goals Exist 

for Monitoring 

Restoration Progress 
Page 19 GAO-04-1024 Great Lakes 

EPA’s efforts in developing the Great Lakes Strategy 2002 and LaMPs 

have resulted in proposed goals for the overall basin and for individual 

lakes. USPCa group of mainly federal and state officials from the Great 

Lakes states coordinated by GLNPOdeveloped and published the Great 

Lakes Strategy 2002, which sets forth 4 overarching goals, 33 subgoals, 23 

objectives, and 103 key actions for the Great Lakes. For example, one goal 

is “to protect human health and restore and maintain stable, diverse, and 

self-sustaining populations of plants, fish and other aquatic life, and 

wildlife in the Great Lakes ecosystem.” A key action under this goal is to 

continue human health studies under the Great Lakes Human Health 

Effects Research Program and make the results available to environmental 

managers and the public. For monitoring the progress in achieving the 

strategy’s goals, GLNPO is tracking the implementation status of the 

actions in the strategy and, as of May 2003, seven actions were reported by 

GLNPO as completed. 

In addition, EPA has participated in developing LaMPs that are the 

primary means for coordinating and planning ecosystem projects for each 

lake, according to the Great Lakes Strategy 2002. The GLWQA requires 

that LaMPs be developed for each lake, with the United States and Canada 

responsible for preparing the plans in consultation with relevant states 

and provincial governments.10 A GLNPO manager for each LaMP 

coordinates EPA’s efforts to develop the plans. In developing LaMPs, the 

parties have agreed that they will report progress every 2 years and that 

updates to each LaMP will be submitted to the IJC for review and 

comment. 

LaMPs have been prepared for four of the five Great LakesErie, 

Michigan, Ontario and Superiorand they present overviews of lake 

conditions and general restoration needs.11 For example, the Lake 

Michigan LaMP sets forth one overall goalto restore and protect the 

integrity of the Lake Michigan ecosystem through collaborative 

partnerships—and 11 subgoals. These subgoals are stated as general 

questions, such as “can we drink the water,” or “can we swim in the 

water.” The LaMPs also generally discuss indicators and monitoring, but 

they are not often linked to goals or how progress toward goals will be 

 10Lake Michigan lies entirely within the United States and, therefore, EPA is solely 

responsible for the Lake Michigan LaMP under the GLWQA and the Clean Water Act. 

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

LaMP. 

EPA’s Efforts Have 

Produced Basin-Wide and 

Lake-Wide Goals 
Page 20 GAO-04-1024 Great Lakes 

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. 

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 

Other Organizations Have 

Developed Basin-Wide 

Goals 
Page 21 GAO-04-1024 Great Lakes 

preventing the introduction or limiting the spread of invasive species. Its 

report outlining the seven major priorities identifies an overall goal for 

each priority.12 Each of the goals contains recommendations for actions, 

and many goals are stated in general terms with funding requests for a 

particular federal agency or organization for implementation. For 

example, one action item under the goal for cleaning up toxic hot spots 

recommends “ensure that polluters responsible for sediment 

contamination pay their fair share$5 million annually to the U.S. Fish 

and Wildlife Servicefor Great Lakes projects.” While the Great Lakes 

Commission lists their seven priorities, it is unclear what specific actions 

are necessary to achieve the priorities. 

Great Lakes United, a binational coalition that promotes citizen action and 

grassroots leadership for Great Lakes environmental activities, published a 

citizen’s action agenda for the Great Lakes in 2003. This document, and its 

summary version, describes what members consider to be the seven major 

challenges to be addressed in the Great Lakes, such as toxic cleanup, 

protecting and restoring species, and sustaining and restoring water 

flows.13 Under each challenge, the agenda recommends several action 

items for restoring the Great Lakes Basin. Some of these action items have 

established time frames. 

Coordinating the establishment of measurable goals and developing a 

monitoring system for tracking progress in the Great Lakes are difficult 

tasks that face significant challenges. Of great importance, no single 

organizational entity has exercised leadership responsibility for 

coordinating the establishing of specific goals and a monitoring system. As 

we reported previously, under the Clean Water Act, GLNPO has 

coordination authority over many Great Lakes activities but has not fully 

exercised it. Further, it is uncertain whether the Executive Order issued in 

May 2004, creating a Great Lakes Interagency Task Force, will provide the 

needed stability in leadership.14 Second, the restoration goal setting and 

monitoring efforts ongoing by numerous governmental and 

nongovernmental organizations in the United States and Canada will 

 12Great Lakes Commission, Great Lakes Program to Ensure Environmental and 

Economic Prosperity (March 2004). 

13Great Lakes United, Citizen’s Action Agenda for Restoring the Great LakesSt. 

Lawrence River Ecosystem, and Great Lakes Green Book (June 2003). 

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

Significant Challenges 

Exist for Setting 

Basin-Wide Goals and 

Developing a 

Monitoring System for 

the Great Lakes 
Page 22 GAO-04-1024 Great Lakes 

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. 

Organizational leadership for setting goals and developing a monitoring 

system has yet to be realized for the Great Lakes. Several attempts at 

providing organizational leadership have not resulted in a stable structure 

for leading Great Lakes restoration efforts. We previously reported that, 

within the Great Lakes several entities are involved in coordinating and 

planning, which has resulted in confusion by federal and state officials as 

to which entity bears ultimate responsibility.15 We further reported that the 

responsibility for leading the U.S.’s Great Lakes efforts rests with GLNPO 

and that it is not fully exercising its authority under the Clean Water Act 

for coordinating Great Lakes restoration programs. We recommended 

GLNPO fulfill its coordinating responsibilities and develop an overarching 

Great Lakes restoration strategy. EPA promised to provide a detailed 

response to our recommendations, but has not yet done so. However, in 

2003 an EPA official stated in congressional testimony that the Clean 

Water Act does require EPA, and more specifically GLNPO, to serve as the 

lead entity for coordinating the protection and restoration of the Great 

Lakes system. The same official stated in 2004 congressional testimony 

that our recommendations are answered by the Executive Order and again 

promised a detailed response to these recommendations. However, the 

Executive Order does not address our recommendations. 

As a result of the Executive Order issued in May 2004, which created a 

Great Lakes Interagency Task Force within EPA, how GLNPO’s leadership 

 15GAO-03-515. 

Great Lakes Restoration 

Efforts Lack Clearly 

Defined Organizational 

Leadership 
Page 23 GAO-04-1024 Great Lakes 

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. 
Page 24 GAO-04-1024 Great Lakes 

Coordinating Great Lakes research is another responsibility provided to 

the task force under the Executive Order, but other organizations have 

research responsibilities by statute. Specifically, NOAA’s Great Lakes 

Research Office, acting through the GLERL and other entities, is 

responsible under the Clean Water Act for conducting Great Lakes 

research and monitoring activities and annually reporting issues, on which 

Great Lakes research is needed, to the Congress.16 Each year GLERL and 

GLNPO are to prepare a joint research plan and to provide a health 

research report to the Congress. Thus far, GLERL and GLNPO have not 

prepared these plans or reported to the Congress because funds were not 

requested or provided for the coordination and reporting activities, 

according to agency officials. The GLERL Director stated that they have 

about 15 specific legislative mandates involving Great Lakes research. 

Coordinating and prioritizing research is also an activity of the IJC’s 

binational Council of Great Lakes Research Managers. This council, 

established in 1984, proposes priority research areas for the Great Lakes, 

and some of the proposals are priorities for GLERL, in part, because the 

council is currently co-chaired by the GLERL Director. Future councils, 

however, may not be co-chaired by the GLERL Director, and priority 

research areas may not be addressed because research managers are not 

bound to follow council priorities. 

Finally, the creation of the task force and working group by the Executive 

Order also raises questions about the permanency of this organizational 

structure for addressing the long-term restoration needs of the Great 

Lakes. Executive orders, such as the one creating the task force, stay in 

effect despite changes in administrations, but they may be amended or 

rescinded by a subsequent President. Moreover, the Executive Order 

cannot be enforced in court, unlike statutory provisions that can often be 

judicially enforced. Therefore, the task force may prove to be a temporary 

rather than a permanent attempt at coordinating and developing goals for 

the Great Lakes. Legislation was proposed in 2004 to enact the provisions 

of the Executive Order into law, but this legislation remains pending in the 

Congress. 

 1633 U.S.C. § 1268(d). 
Page 25 GAO-04-1024 Great Lakes 

Many organizations participating in the restoration of the Great Lakes have 

independently developed goals for the Great Lakes Basin. However, these 

organizations have tended to develop goals independently of EPA and one 

another, resulting in duplicative efforts and the lack of prioritization of 

goals. We previously reported that the numerous restoration strategies 

containing goals developed by various organizations did not provide an 

overarching approach that can be used as a blueprint to guide overall 

restoration activities.17 The situation remains the same today with several 

organizations developing strategies and goals, without clearly defined 

leadership responsibilities to bring together or coordinate the various 

efforts. In some cases, the goals developed are very similar to each other. 

For example, the Council of Great Lakes Governors and the Great Lakes 

Commission both have similar goals relating to cleaning up of areas of 

concern18 and stopping the spread of invasive species. Yet, consensus has 

not been reached by the various organizations as to specifically how such 

goals should be measured. 

The leadership to coordinate goal setting efforts has not yet materialized. 

There is no one organization or group of organizations that is recognized 

as the leader. For example, at a Senate hearing on Great Lakes restoration 

efforts in 2003, the hearing chairman asked a panel of federal agency 

officials, including the Great Lakes National Program Manager, if there 

was an orchestra leader for the efforts in the Great Lakes, and none of the 

panel members volunteered a response. Similarly, during an IJC 

conference session in 2003, where the leadership for the various Great 

Lakes organizations was addressed, the Great Lakes National Program 

Manager stated that because of the number of groups involved in the Great 

Lakes, there is a need to find a way to work together toward goals; 

however, he was reluctant to lead this effort. The recently created Great 

Lakes Interagency Task Force was charged with establishing a process for 

collaboration among task force members to, among other things, develop 

outcome-based goals for the Great Lakes system. The desired outcomes 

are conditions such as cleaner water or sustainable fisheries. 

Federal and state program officials acknowledge that limited coordination 

of monitoring activities now exists and that there is no single organization 

in place to direct the coordination of monitoring efforts. One attempt to 

coordinate monitoring involving research vessels on the Great Lakes 

 17GAO-03-515. 

18Areas of concern are specific areas of contamination in the Great Lakes. 

Coordinating Restoration 

Goals and Monitoring 

Activities within the 

United States and Canada 

Poses Challenges for a 

Basin-Wide Approach 
Page 26 GAO-04-1024 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, 
Page 27 GAO-04-1024 Great Lakes 

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 
Page 28 GAO-04-1024 Great Lakes 

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. 

There is currently no centralized repository of information on monitoring 

activities. As a result, it is difficult to coordinate existing data and 

determine what additional information is needed to establish baseline 

conditions and assess progress toward restoration goals. Two related 

efforts are, however, under way to develop inventories of the existing 

monitoring programs within the Great Lakes. One effort is being led by the 

Great Lakes Commission, funded by grants from the Joyce Foundation and 

GLNPO, to develop a comprehensive inventory of environmental 

monitoring programs in the Great Lakes Basin. Information is being 

gathered from existing sources and through surveys and interviews with 

program officials. The information will be placed in a database, analyzed 

to identify monitoring gaps in existing programs, and used by the BEC to 

develop a monitoring coordination framework, according to Great Lakes 

Commission officials. This project, however, was funded on a one-time 

basis and does not include plans for updating the inventory of monitoring 

data. 

A related effort is being conducted by GLNPO and EC under the direction 

of the BEC and is focused on developing an Internet-based inventory of 

existing monitoring systems. The inventory will not contain monitoring 

data, but rather a database of monitoring sources, referred to as metadata 

by GLNPO officials.19 The inventory of existing monitoring sources will 

 19Metadata are data about databases describing various attributes such as who is 

responsible for the database and the data content. 

Lack of Centralized 

Information from 

Monitoring Activities 

Makes Coordination to 

Assess Restoration 

Progress Difficult 
Page 29 GAO-04-1024 Great Lakes 

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. 
Page 30 GAO-04-1024 Great Lakes 

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.) 

Unique Environmental 

Conditions for Each Lake 

Makes Setting Basin-Wide 

Goals Difficult 
Page 31 GAO-04-1024 Great Lakes 

Figure 3: Differences in Characteristics of Lake Superior and Lake Erie 
Page 32 GAO-04-1024 Great Lakes 

Lake Superior is a larger, deeper lake with a relatively sparse human 

population within its watershed. Most of the shoreline of Lake Superior is 

forested and not host to the extensive urban development along its shores 

that Lake Erie has. For Lake Superior, the overarching concern is to 

preserve current conditions and keep pollutants and invasive species from 

entering the lake. Lake Erie has other unique environmental problems, the 

most recent being the reemergence of a dead zone in the central basin of 

the lake that is void of oxygen and cannot support aquatic life. Recently, 

the phosphorus levels of the lake have exceeded acceptable levels as the 

result of unknown causes. Research efforts are now focused on 

determining the cause of the rise in phosphorous levels, which cause 

harmful algae blooms. Because Lake Erie is the shallowest of the Great 

Lakes and is subject to urban pressures, it is sometimes cited as the lake 

that first develops environmental problems within the Great Lakes Basin. 

The differences between the Great Lakes pose a challenge to setting basinwide goals. While goals are needed to determine basin-wide progress, 

goals for each lake are also needed to address specific problems or public 

concerns for each lake. For Lake Superior, a major concern is stopping 

pollutants from entering the lake, which is addressed through a program 

that established a goal of zero-discharge for point source pollutants.20 For 

Lake Erie, goals developed by the Lake Erie Commission address other 

problems, such as how remediating contaminated sediments in Lake Erie’s 

harbors and tributaries. The future challenge will be how to build on the 

existing goal-setting efforts for each lake in developing measurable goals 

for the Great Lakes Basin as a whole. 

The Chesapeake Bay Program, a restoration effort lead by EPA, has 

demonstrated that quantifiable and prioritized goals with definitive time 

frames can be developed for measuring restoration progress. While the 

Great Lakes have unique challenges, such as coordination with Canada, 

the bay program also provides an example of how an organizational 

structure can be created to successfully coordinate goal setting. 

Unlike the restoration goals prepared for the Great Lakes, the Chesapeake 

Bay Program has specific, measurable goals with definitive time frames 

 20Point source pollutants are those that contribute pollutants directly to a body of water 

from a pipe or other discrete conveyance. 

Chesapeake Bay Program 

May Offer Lessons Learned 

for Developing an 

Organizational Structure 

and Setting Restoration 

Goals 
Page 33 GAO-04-1024 Great Lakes 

that are linked to indicators and a monitoring and modeling program.21

Overall goals developed for the program are stated in a general fashion 

similar to many developed for the Great Lakes and are to (1) address 

water quality and clarity problems caused by excess nutrients, sediments, 

and toxics; (2) maintain and restore living resources of the bay, such as 

controlling exotic species and protecting crabs and oysters; (3) protect 

and restore vital habitats, such as wetlands and submerged aquatic 

vegetation; (4) make sound land use decisions, such as land conservation; 

and (5) engage the community through education and outreach. However, 

the general goals are further defined as specific commitments that are 

used to measure program progress. 

As of December 2003, the program was endorsing over 40 measurable 

environmental commitments for the watershed. The program has 

prioritized commitments included in the most recent bay agreement, 

Chesapeake 2000, by identifying the 10 most important “keystone 

commitments” for the bay for focusing their efforts on critical needs and 

making the best use of resources and capabilities. For example, one 

keystone commitment for the overall goal of maintaining and restoring 

living resources in the bay, is that by 2010, at a minimum, a tenfold 

increase in native oysters should be achieved in the Chesapeake Bay, 

using a 1994 baseline. In addition, this commitment involves developing 

appropriate research and management strategies for attaining this 

increase. 

According to program officials, defining measurable goals and 

commitments up front is the key to the success of the Chesapeake Bay 

Program. If the goals are developed first, then they can be linked to the 

appropriate measurement and tracking activities and indicators to 

evaluate progress. Once program officials analyze the data collected from 

monitoring, modeling, and tracking programs to determine progress, they 

can decide on the appropriate actions to take to maintain or improve 

conditions. Officials from organizations involved in the restoration and 

protection of the bay agree that defining goals up front is important to the 

restoration effort and that the Chesapeake Bay Program has done a good 

 21The Chesapeake Bay Agreement in 1983 established the Chesapeake Executive Council to 

assess and oversee the implementation of coordinated plans to improve and protect the 

water quality and living resources of the Chesapeake Bay estuarine systems. Subsequent 

Chesapeake Bay agreements in 1987, 1992, and 2000 defined the agenda for the Chesapeake 

Bay Program setting forth strategic plans with measurable goals and objectives for the bay 

watershed. 
Page 34 GAO-04-1024 Great Lakes 

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. 

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, 

Conclusions 
Page 35 GAO-04-1024 Great Lakes 

it is uncertain whether this task force will provide definitive, stable 

leadership needed over time because it may be readily changed by future 

executive orders. Additionally, while GLNPO has existing statutory 

responsibility for coordinating Great Lakes activities, it is unclear how its 

responsibilities and those of other organizations fit with the coordination 

activities of the new task force. EPA is now taking steps to implement the 

Executive Order; however, it is unclear whether this fulfills its 

responsibilities under the Clean Water Act. Absent a clearly defined 

leadership structure, setting measurable goals and monitoring progress in 

the Great Lakes is unlikely to be accomplished, and duplicative 

responsibilities for coordination, goal setting, and monitoring may be 

inevitable. EPA has recently demonstrated leadership on monitoring by 

developing an inventory of all monitoring activities in the Great Lakes. 

While we believe this is a worthwhile effort, controls should be in place to 

ensure the completeness and accuracy of the data in the inventory. 

In light of the uncertainty regarding how GLNPO’s responsibilities fit with 

the newly created Great Lakes Interagency Task Force and to help ensure 

the coordination of U.S. efforts in developing basin-wide measurable 

restoration goals for the Great Lakes, as well as the development of a joint 

monitoring system based on those goals, the Congress may want to 

consider 

• 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. 

Matter for 

Congressional 

Consideration 
Page 36 GAO-04-1024 Great Lakes 

To facilitate the coordination of monitoring activities by the various 

federal, state, and other organizations within the Great Lakes Basin, we 

recommend that the EPA Administrator direct GLNPO to develop 

adequate controls for the inventory of monitoring systems to ensure that 

inventory data is accurate, current, and complete so as to facilitate users’ 

efforts to coordinate monitoring activities. 

GAO provided EPA with a draft of this report for its review and comment. 

The agency generally agreed with the findings and recommendations in 

the report. EPA stated that the inventory of monitoring activities is a 

critical component for monitoring and reporting efforts, and adequate 

controls are needed to ensure that data are accurate, current, and 

complete in order to facilitate users’ efforts to coordinate monitoring 

activities. Accordingly, EPA stated it has begun taking steps to develop 

these controls. Specifically, GLNPO will lead the U.S. efforts to track 

entries into the inventory database to ensure that data from all agencies 

are included. GLNPO will also request annual verification and updating by 

organizations of their information to ensure that the database is accurate 

and current. If effectively implemented, these steps should help ensure the 

accuracy and usefulness of the inventory for coordination purposes. 

Regarding our matter for the Congress to consider clarifying leadership 

responsibilities, EPA stated that it believes the responsibilities for 

organizational leadership in the Great Lakes for both GLNPO and Great 

Lakes Interagency Task Force are clearly stated in the Clean Water Act 

and the Executive Order, respectively. While EPA describes the overall 

structure and responsibilities of the task force and GLNPO to support its 

position, it does not address our concern that similar coordination 

responsibilities are assigned to different organizations under the 

Executive Order and the Clean Water Act. EPA states that the Executive 

Order appoints the Great Lakes National Program Manager as chair of the 

Great Lakes Regional Working Group and that this will enhance GLNPO’s 

ability to meet its statutory obligation to coordinate federal restoration 

activities. However, this does not address our point that the Clean Water 

Act assigns GLNPO the responsibility of implementing specific action 

plans to carry out U.S. responsibilities under the act, while under the 

Executive Order, it is the task force, not GLNPO that will implement 

recommendations of the working group. Further, EPA did not address our 

concern that the task force does not provide the definitive, stable 

leadership that is needed over time given that its responsibilities may be 

changed by future executive orders. The full text of EPA’s comments is 

included in appendix VII. 

Recommendation for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 37 GAO-04-1024 Great Lakes 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to appropriate 

Congressional Committees; the EPA Administrator; various other federal 

departments and agencies; and the International Joint Commission. We 

also will make copies available to others upon request. In addition, the 

report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you or your staff have any questions, please call me at (202) 512-3841. 

Key contributors to this report are listed in appendix VIII. 

John B. Stephenson

Director, Natural Resources 

 and Environment 
Page 38 GAO-04-1024 Great Lakes 

List of Congressional Requesters 

The Honorable Mike DeWine 

United States Senate 

The Honorable Russell Feingold 

United States Senate 

The Honorable Carl Levin 

United States Senate 

The Honorable Debbie Stabenow 

United States Senate 

The Honorable George Voinovich 

United States Senate 

The Honorable John Conyers, Jr. 

House of Representatives 

The Honorable John Dingell 

House of Representatives 

The Honorable Rahm Emanuel 

House of Representatives 

The Honorable Vernon Ehlers 

House of Representatives 

The Honorable Marcy Kaptur 

House of Representatives 

The Honorable Dale Kildee 

House of Representatives 

The Honorable Ron Kind 

House of Representatives 

The Honorable Mark Kirk 

House of Representatives 

The Honorable Dennis Kucinich 

House of Representatives 
Page 39 GAO-04-1024 Great Lakes 

The Honorable Steven LaTourette 

House of Representatives 

The Honorable Sander Levin 

House of Representatives 

The Honorable Candice Miller 

House of Representatives 

The Honorable James Oberstar 

House of Representatives 

The Honorable Jack Quinn 

House of Representatives 

The Honorable Bart Stupak 

House of Representatives 
Appendix I: Scope and Methodology 

Page 40 GAO-04-1024 Great Lakes 

To determine the extent to which information derived from monitoring is 

useful for assessing overall conditions in the Great Lakes Basin, we 

gathered and analyzed information on efforts to develop indicators 

through the State of the Lakes Ecosystem Conferences (SOLEC), which is 

a jointly sponsored effort by EPA’s Great Lakes National Program Office 

(GLNPO) and Environment Canada (EC). We also gathered and analyzed 

information on monitoring activities obtained from state agency officials 

in each of the eight Great Lakes statesIllinois, Indiana, Ohio, Michigan, 

Minnesota, New York, Pennsylvania, and Wisconsin; eight federal 

agencies; two Canadian federal agencies; and provincial agencies in 

Ontario and Quebec, Canada. For each agency, we obtained information 

about ongoing monitoring efforts including the purpose of the monitoring 

efforts, type of information collected during monitoring, how the 

information was analyzed and used, and how monitoring was coordinated 

with other federal or state agencies. A detailed listing of the federal, state, 

and Canadian agencies that provided monitoring information is included 

as appendix II. We reviewed the monitoring requirements contained in the 

Great Lakes Water Quality Agreement (GLWQA) and compared these 

requirements with the ongoing monitoring activities. 

To identify existing restoration goals and whether monitoring is done to 

track goal progress, we obtained and analyzed Great Lakes restoration 

goals prepared by several organizations including the Council of Great 

Lakes Governors, Great Lakes Commission, Great Lakes United, and U.S. 

Policy Committee. We analyzed the goals contained in the Great Lakes 

Strategy 2002 and reviewed information on monitoring the progress in 

achieving the goals. We further reviewed the restoration goals and 

monitoring efforts contained in Lakewide Management Plans (LaMP) 

prepared for four of the five Great Lakes. We interviewed LaMP managers 

to determine the process followed for setting goals and related monitoring 

activities. We also interviewed officials conducting the monitoring for the 

Great Lakes Strategy 2002 and reviewed monitoring progress reports. 

To identify major challenges to setting restoration goals and developing a 

monitoring system for the Great Lakes, we identified barriers to 

accomplishing these tasks and gathered information on four major 

challenges involving organizational responsibilities, coordination of 

monitoring activities with Canada, centralized information on monitoring 

activities, and unique lake environmental conditions. We gathered and 

analyzed information on existing organization responsibilities, including 

those established by the GLWQA, statutes, and administrative decisions, 

along with the organizational responsibilities set forth in a May 2004 

executive order. We interviewed officials and gathered information from 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 41 GAO-04-1024 Great Lakes 

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 

Page 42 GAO-04-1024 Great Lakes 

Environmental Protection Agency 

• Great Lakes National Program Office 

• Office of Research and Development 

• Chesapeake Bay Program 

• Region V 

Department of Interior 

• U. S. Fish and Wildlife Service 

• U. S. Geological Survey 

Department of Commerce 

• National Oceanic and Atmospheric Administration 

Department of Agriculture 

• Forest Service 

Illinois 

• Illinois Environmental Protection Agency 

Indiana 

• Indiana Department of Environmental Management 

Ohio 

• Ohio Environmental Protection Agency 

• Ohio Department of Natural Resources 

Michigan 

• Michigan Department of Environmental Quality 

Minnesota 

• Minnesota Pollution Control Agency 

New York 

Appendix II: Federal, State, Canadian, and 

Other Organizations That Provided Great 

Lakes Monitoring and Research Information 

Federal Agencies 

State Agencies 
Appendix II: Federal, State, Canadian, and 

Other Organizations That Provided Great 

Lakes Monitoring and Research Information 

Page 43 GAO-04-1024 Great Lakes 

• New York State Department of Environmental Conservation 

Pennsylvania 

• Pennsylvania Department of Environmental Protection 

Wisconsin 

• Wisconsin Department of Natural Resources 

• Environment CanadaOntario Region 

• Environment CanadaQuebec Region 

• Ontario Ministry of Natural Resources 

• Ontario Ministry of the Environment 

• Ontario Great Lakes Fisheries Management 

• Conservation Ontario 

• Quebec Ministry of the Environment 

• Great Lakes Commission 

• The Nature Conservancy 

• Great Lakes Cities Initiative 

• International Joint Commission 

• University of Minnesota’s Natural Resources Research Institute 

Canadian Agencies 

Other Organizations 
Appendix III: Comments by Officials on Need 

for Indicators and Monitoring in the Great 

Lakes Basin 

Page 44 GAO-04-1024 Great Lakes 

Nearly all of the officials we contacted endorsed the need for a 

comprehensive surveillance and monitoring system and their comments 

include why a system is needed or factors to consider in developing a 

system. See table 1 for a summary of these comments. 

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

Agency/organization Comments 

Department of Interior: U. S. Geological 

Survey (USGS) 

• A comprehensive surveillance and monitoring system with indicators is needed and 

should be developed cooperatively between federal and state agencies. 

• No one agency has the capability to adequately monitor and assess the Great Lakes 

ecosystem. 

• The Environmental Protection Agency’s (EPA) Great Lakes National Program Offices’ 

(GLNPO) strength is in open lake surveillance monitoring, but the other agencies like 

USGS that have expertise in tributary, wetland, and groundwater issues should come 

together to develop a monitoring system. 

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

the Great Lakes. 

• The Great Lakes Science Center integrates monitoring systems and indicators with 

scientifically based proactive research; a similar approach should be used to develop a 

comprehensive system. 

Department of Commerce: National 

Oceanic and Atmospheric Administration 

(NOAA) 

• It is strongly believed that a comprehensive surveillance and monitoring system, with 

indicators, is needed for the Great Lakes. 

• The International Joint Commission’s (IJC) Science Advisory Board recommended that 

the U.S. and Canadian governments, while considering revisions to the Great Lakes 

Water Quality Agreement (GLWQA), consider requiring implementation of a 

systematic, science-based program that has data quality objectives and data collection 

plans driven by ecosystem behavior and contaminant fate and develop binational 

surveillance programs for water quality management similar to the Integrated 

Atmospheric Deposition Network. 

Department of Interior: Fish and Wildlife 

Service 

• A well-coordinated, comprehensive basin-wide surveillance and monitoring system with 

indicators for the Great Lakes is needed to measure outcomes of programs, public 

investment, and status of ecosystem health, while targeting actions strategically and 

allowing for informed environmental decisions. 

• A real-time comprehensive system of mapping, modeling, and statistical assessment is 

needed to evaluate conservation and restoration efforts. 

Department of Agriculture: 

Forest Service 

• It would be valuable to have comprehensive monitoring of social, economic, and 

environmental conditions in the Great Lakes Basin. 

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

• Comprehensive monitoring could cover the range of economic sectors; be grounded in 

suitable scientific disciplines; and address information needs of city, county, state, and 

federal governments, as well as other agencies, organizations, and individuals that 

invest resources for public benefit. 

Appendix III: Comments by Officials on Need 

for Indicators and Monitoring in the Great 

Lakes Basin 
Appendix III: Comments by Officials on Need 

for Indicators and Monitoring in the Great 

Lakes Basin 

Page 45 GAO-04-1024 Great Lakes 

Agency/organization Comments 

Environmental Protection Agency: GLNPO • A comprehensive surveillance and monitoring system, with associated environmental 

indicators, is necessary for the Great Lakes if we are to be able to track environmental 

trends, understand emerging threats to the ecosystem, implement appropriate control 

strategies, and assess the effectiveness of our programs. 

• With programs such as the State of the Lakes Ecosystem Conference (SOLEC), the 

Binational Executive Committee’s inventory of monitoring programs, and the 

Presidents’ recently signed an executive order calling for a Great Lakes Interagency 

Task Force to plan and coordinate Great Lakes activities, improvements are expected. 

Illinois Environmental Protection Agency • A comprehensive surveillance and monitoring system with indicators is needed and 

should be developed as a joint effort of the Great Lake states, GLNPO, the Great 

Lakes Commission, and others, including university researchers, to identify current and 

future potential problems, develop and implement monitoring strategies, and seek 

options for both short-term and long-term problem resolution. 

Indiana Department of Environmental 

Management 

• A comprehensive surveillance and monitoring system with indicators is needed. It 

should be developed in a cooperative effort by EPA Region 5 and GLNPO, the 

International Joint Commission, the Great Lakes Commission, Environment Canada, 

and the EPA Region 5 states. 

Michigan Department of Environment 

Quality 

• A comprehensive monitoring system for the Great Lakes is needed; however, such a 

system must be developed with involvement from all parties that have a stake in what 

happens in the Great Lakes. 

• Each lake must be looked upon individually when it comes to indicators because of 

their differences. One set of indicators will not fit all the lakes. 

• To address environmental conditions and know if things are getting better or worse 

requires quantitative answers to specific problems related to each individual lake. 

Minnesota Pollution Control Agency • A comprehensive system is needed, but it must address both ambient indicators such 

as fish, water, and beaches and the source indicators needed to assess regional 

progress. The system should also be flexible since there is no single set of indicators 

that apply to all the lakes. 

• A lake trout indicator for Lake Superior might not be appropriate for Lake Erie, and a 

yellow perch indictor well suited for Lake Erie would not make sense for Lake Superior. 

The system should also use existing monitoring and indicator systems as much as 

possible. 

New York State Department of 

Environment Conservation 

• A comprehensive system is needed, but it must be mandated by law and adequately 

funded to support staff and equipment resourcing, analytical analysis, and reporting 

over a long-term period. 

Ohio Environmental Protection Agency 

and Ohio Department of Natural 

Resources 

• It is important for the Great Lakes to have a long-term surveillance and monitoring 

system with indicators. Appropriate indicators are probably the most important things 

needed. 

• A carefully chosen set of indicators that provide the best information on the state of the 

lakes should be established before the monitoring program is designed. We need to 

know the reasons why we should monitor. 

• Comprehensive monitoring for surface and groundwater in the Great Lakes basin is 

needed to understand the availability, limits and impacts of water withdrawals, as well 

as to support science-based decision making under the agreement. 
Appendix III: Comments by Officials on Need 

for Indicators and Monitoring in the Great 

Lakes Basin 

Page 46 GAO-04-1024 Great Lakes 

Agency/organization Comments 

Pennsylvania Office of Environmental 

Protection 

• There are a number of systems already in place to survey and monitor environmental 

parameters within the Great Lakes, such as SOLEC and Lakewide Management Plans 

(LaMP). 

• The bigger problem is in coordinating the surveillance and monitoring and having 

enough resources to do a comprehensive job. A lot of resources go into monitoring and 

surveillance, but the results are not always shared with those who need the 

information. 

Wisconsin Department of Natural 

Resources 

• One environmental official believes existing systems are adequate to accomplish the 

stated tasks. Instead, better acceptance is needed by concerned agencies and a 

willingness to provide funds for efficient and technically credible monitoring efforts. 

• Another environmental official believes some surveillance and monitoring is needed; 

however, it should involve a limited number of indicators and biological measures 

established by system ecologists as a starting point. More in-depth comprehensive 

surveillance and monitoring should be targeted to problem areas and resource 

management concerns across the Great Lakes.a

Great Lakes Commission • There is a great need for a comprehensive monitoring plan for the Great Lakes, but to 

be effective it must have buy-in from all federal state and local organizations with 

responsibility for activities in the Great Lakes. 

• The GLWQA is believed to be the tool needed to harmonize the U.S. and Canadian 

governments’ objectives for the Great Lakes; however, a comprehensive indicator and 

monitoring system is required to accomplish this. 

Nature Conservancy • The lack of monitoring activity is a problem throughout the ecosystem, and the 

development of a comprehensive monitoring system is becoming more and more 

important each day. However, monitoring must be based on documented and tested 

scientific information because of the turnover of staff personnel in environmental and 

conservation areas. 

Great Lakes Cities Initiatives • Because of philosophical differences and complexities among Great Lakes Governors, 

monitoring at the state level is even more difficult and requires the input of city mayors. 

There is a grave need for someone to set priorities for restoration activities. 

• With tight state budgets, there must be a collective body to set priorities and oversee 

projects to prohibit duplicative spending. There is a need for indicators and monitoring 

to say whether things are getting better or worse in the Great Lakes. 

• Currently, people are deciding independently what is most important, and sufficient and 

accurate information is not available to assess conditions. 

Environment Canada

Ontario Region 

• Developing indicators for the Great Lakes is a work in progress, and it is essential that 

these efforts continue. Appropriate indicators must be developed and they must have 

linkage. 

• A comprehensive monitoring system with indicators is needed, but everyone with a 

vested interest in the Great Lakes must take part in developing the indicators and the 

surveillance process to monitor them. 

Ontario Ministry of Natural Resources • A comprehensive monitoring strategy and indicators are needed for the Great Lakes; 

however, the development of such a strategy will be a significant challenge. There has 

been significant progress made in restoration of the Great Lakes by various federal, 

state, and provincial organizations. 

• The problem is that there are too many different people with different interests who do 

not always talk to each other. The sum of the parts from various Great Lakes projects 

has been good, but the results are by fluke, not by plan. There must be a process 

where everyone participates and talks to each other. 
Appendix III: Comments by Officials on Need 

for Indicators and Monitoring in the Great 

Lakes Basin 

Page 47 GAO-04-1024 Great Lakes 

Agency/organization Comments 

Ontario Great Lakes Fisheries 

Management 

• A comprehensive monitoring system is needed. Threats to the biological, physical, and 

chemical integrity of the Great Lakes require an ecosystem and collaborative approach 

to objective setting, indicator development, monitoring, and reporting. 

Environment Canada Quebec Region • Such a program is definitely needed to report on the state and evolution of the 

ecosystem. Considering the size of the drainage basin, such a program should answer 

questions at the lake, river, and basin levels. It should be based on a wide array of 

environmental indicators and not just on a few highlighted ones. 

• These indicators need to be useful and significant for government and nongovernment 

managers and interested communities in order to have a lasting impact. The indicators 

and monitoring must support the decision-making process. 

Quebec Ministry of the Environment • There is a need to monitor all the Great Lakes and the St. Lawrence to determine 

progress toward restoring these watersheds. We must know where we are and where 

we want to go before we can know if things are getting better. 

• There must be a relationship between the state of the environment and the pressures 

placed on it from various contaminants and users. We can’t just monitor the lakes for 

the sake of monitoring. 

• Monitoring in and of itself is not a good goal. Monitoring must be done to answer 

specific management questions and make decisions about what needs to be done. 

IJC • A system of monitoring to measure indicators of ecosystem health is essential for the 

Great Lakes. Without it we have no way of knowing either the state of the lakes or 

whether our policies and programs are effective in protecting the Great Lakes and 

those who rely on them for drinking water, commerce, and quality of life. 

• We need a coordinated approach across a multiplicity of institutions to include EPA; 

Environment Canada; fisheries and natural resource agencies; and federal, state, and 

provincial governments. 

• Presently there is growing enthusiasm for a Great Lakes observing system, possibly 

lead by NOAA and coordinated with help from the IJC’s Council of Great Lakes 

Research Managers. 

Sources: USGS, NOAA, FWS, FS, EPA, IL, IN, MI, MN, NY, OH, PA, WI, Great Lakes Commission, Nature Conservancy, Great Lakes 

Cities Initiatives, Environment Canada, Ontario Ministry of Natural Resources, Quebec Ministry of the Environment, Ontario Great 

Lakes Fisheries Management, International Joint Commission, and GAO. 

a

There was no definitive yes or no response from Wisconsin officials, see the comment box. 
Appendix IV: State of Ohio Lake Erie 

Programs and Initiatives with Monitoring 

Activities 

Page 48 GAO-04-1024 Great Lakes 

Programs and initiatives with 

monitoring activities Program objectives or focus Program responsibility 

Fish Consumption Advisory 

Program 

Analysis of sport fish caught in Ohio waters for 

toxins; results are basis for fish consumption 

advisories. 

State funded program, state administered. 

Clean Water Act, Section 305 (b) Biennially assess Ohio’s water bodies and report 

the status of impaired waters. 

Federally requirement, jointly funded by 

federal and state; administered by stste. 

Clean Water Act, Section 303 (d) Protect impaired or threatened waters by 

developing total maximum daily load limits by 

2013. 

Federally requirement, jointly funded by 

federal and state; administered by state. 

Ohio Department of Natural 

Resources Coastal Urban Streams 

Program 

Conduct nonpoint pollution abatement program 

with focus on urban, residential, and commercial 

sources. 

State initiated, jointly funded by federal and 

state. 

Phosphorus Reduction Strategy Long-term program to reduce phosphorus loading 

into Lake Erie. 

Joint federal and state funded program; 

administered by state. 

Ohio Department of Natural 

Resources Bald Eagle Management 

Program 

Program to reestablish the bald eagles throughout 

Ohio 

State initiated and funded. 

Biological Indices Program Indices measuring the health of streams based 

on health and diversity of aquatic communities. 

State initiated jointly funded by federal and 

state. 

Bacterial Beach Monitoring 

Program 

Monitor swimming beaches for fecal bacteria 

contamination using E. coli as test organism. 

Joint federal and state funded program; 

administered by state. 

Ohio Tributary Monitoring Program An analysis of water samples collected within the 

Lake Erie basin to assess sediment, nutrient, and 

metal compositions. 

State initiated and funded. 

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

Appendix IV: State of Ohio Lake Erie 

Programs and Initiatives with Monitoring 

Activities 
Appendix V: Observations on Goals and 

Monitoring Information Contained in LaMPs 

for Four Great Lakes 

Page 49 GAO-04-1024 Great Lakes 

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. 

The Lake Michigan LaMP sets forth one overall goalto restore and 

protect the integrity of the Lake Michigan ecosystem through collaborative 

partnerships—and 11 subgoals. These subgoals are stated as general 

questions, such as “can we drink the water,” or “can we swim in the 

water,” with additional detail on the status of reaching the subgoal, 

challenges, and key steps to be taken to achieve the subgoal’s target. 

However, while these subgoals and key steps do contain some quantitative 

information and time frames, they are not prioritized and cannot be linked 

to indicators and monitoring so that progress under the subgoal can be 

measured. For example, under the subgoal “can we swim in the water,” the 

LaMP states that there were 206 beach closures in 2000, and progress 

toward reaching the goal is “mixed.” It further identifies a challenge to 

develop real-time beach monitoring and that, in 2004, the Great Lakes 

states should adopt criteria, standards, and monitoring programs for beach 

bacteria. The LaMP acknowledges that goals need to be linked to 

indicators and then to a monitoring strategy for tracking restoration 

progress. However, according to the LaMP Program Manager, the selection 

of indicators for Lake Michigan is still in process, and the scope of 

Appendix V: Observations on Goals and 

Monitoring Information Contained in LaMPs 

for Four Great Lakes 

Lake Erie 

Lake Michigan 
Appendix V: Observations on Goals and 

Monitoring Information Contained in LaMPs 

for Four Great Lakes 

Page 50 GAO-04-1024 Great Lakes 

monitoring efforts being conducted in the Lake Michigan basin needs to be 

determined and coordinated. As a first step in developing a coordinated 

strategic monitoring plan, a monitoring groupthe Lake Michigan 

Monitoring Coordination Councilhas an effort under way to determine 

ongoing monitoring activities in Lake Michigan at the state and federal 

levels, according to the official. 

For Lake Ontario, U.S. and Canadian officials derived the LaMP’s three 

overall ecosystem goals from an earlier planthe Lake Ontario Toxics 

Management Planthat was prepared in the late 1980s. For example, one 

goal derived from the plan for the LaMP is “to maintain the Lake Ontario 

ecosystem, and as necessary, restore or enhance it to support selfreproducing and diverse biological communities.” Under the three overall 

ecosystem goals, the LaMP also included the management plan’s 

ecosystem objectives in five areas: aquatic communities, wildlife, human 

health, habitat, and stewardship. These objectives describe in general 

terms the conditions necessary to achieve the overall ecosystem goals, but 

they are not stated in quantitative terms, prioritized, and do not contain 

time frames. The Lake Ontario LaMP also contains 11 indicators based on 

the Lake Ontario Toxics Management Plan and State of the Lakes 

Ecosystem Conference indicator work. According to the LaMP, most 

indicator monitoring needs are being met with existing monitoring 

programs, but further monitoring efforts are planned to provide a more 

complete assessment of lake conditions. The LaMP states that now that 

indicators have been adopted, U.S. and Canadian officials will work to 

develop a “cooperative monitoring” approach for promoting increased 

communication and coordination between their monitoring programs. 

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 

Lake Ontario 

Lake Superior 
Appendix V: Observations on Goals and 

Monitoring Information Contained in LaMPs 

for Four Great Lakes 

Page 51 GAO-04-1024 Great Lakes 

prioritized, for critical pollutants, the LaMP provides specific, measurable 

goals for reducing nine bioaccumulative toxic chemicals.1

 For each 

chemical, a 1990 baseline amount was established, along with targets, for 

chemical load reductions to be achieved every 5 years. For example, 

reducing mercury sources 60 percent by 2000, 80 percent by 2010, and a 

100 percent by 2020. Similar goals are set for the other pollutants. While 

the goals are specific, the description of the monitoring process to 

measure progress is less specific with little detail on the monitoring 

required to measure progress toward goals. For the critical pollutants, a 

menu of possible monitoring activities is mentioned, and the LaMP states 

that more work is needed to develop a coordinated monitoring program to 

evaluate progress toward goals and that data from state sources is needed 

for measuring progress. According to Minnesota officials responsible for 

tracking progress, they have difficulty collecting information from state 

regulatory agencies and, therefore, do not have sufficient information to 

measure progress toward reaching goals. They added that funds are not 

available for the monitoring needed to measure progress. 

The goals for the other five areas in the Lake Superior LaMP are not as 

specific and do not link indicators and monitoring to goals leaving unclear 

how progress toward goals will be measured. For example, the LaMP lists 

several strategies for pursuing sustainability, such as developing recycling 

programs and attracting industries that use recycled material but no 

quantitative information, prioritization, or time frames are given for these 

strategies. The LaMP mentions several indicators that have been 

developed to track progress in promoting sustainability, however, these 

are not linked to specific measurable goals. Sustainability indicators will 

be used, according to the LaMP, to assess how fully the Binational 

Program’s vision statement is being realized. Ecosystem indicators for 

aquatic and terrestrial species are still under development. 

 1

The targeted critical pollutants are dioxin, mercury, polychlorinated biphenyls, 

hexachlorobenzene, octachlorostyrene, and the pesticides chlordane, DDT, dieldrin/aldrin, 

and toxaphene. 
Appendix VI: Goals and Priorities Established 

by Three Great Lakes Organizations 

Page 52 GAO-04-1024 Great Lakes 

• 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. 

• 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. 

Appendix VI: Goals and Priorities Established 

by Three Great Lakes Organizations 

Council of Great Lakes 

GovernorsPriorities 

Task Force 

Great Lakes 

Commission—The Great 

Lakes Program to Ensure 

Environmental and 

Economic Prosperity 
Appendix VI: Goals and Priorities Established 

by Three Great Lakes Organizations 

Page 53 GAO-04-1024 Great Lakes 

• 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. 

• Toxic Cleanup Action Agenda 

Lists five areas where action is needed, such as funding toxic cleanups, 

coordinating cleanup efforts, and treating contaminants. 

• Clean Production Action Agenda 

Lists seven areas where action is needed, such as design of manufacturing 

products, minimizing resource extraction, and planning and managing 

food production and agriculture in relation to the surrounding ecosystem. 

• Green Energy Action Agenda 

List five areas where action is needed, such as promoting energy 

efficiency, conservation, and renewable energy sources. 

• Sustainable Water Quantities and Flows Action Agenda 

Lists eight areas where action is needed such as implementing water 

withdrawal reform and restoring basin ecosystem functions damaged or 

lost due to harmful water withdrawal practices. 

• Protecting and Restoring Species Action Agenda 

Lists 13 areas where action is needed to address invasive aquatic and 

terrestrial species, and protect threatened species. 

• Protecting and Restoring Habitats Action Agenda 

Lists 24 areas where action is needed to protect and restore aquatic, forest, 

urban, and interconnecting habitats; and limit sprawl. 

Great Lakes UnitedA 

Citizens Action Agenda 

for Restoring the Great 

Lakes and St. Lawrence 

River Ecosystem 
Appendix VII: Comments from the 

Environmental Protection Agency 

Page 54 GAO-04-1024 Great Lakes 

Appendix VII: Comments from the 

Environmental Protection Agency 
Appendix VII: Comments from the 

Environmental Protection Agency 

Page 55 GAO-04-1024 Great Lakes 
Appendix VII: Comments from the 

Environmental Protection Agency 

Page 56 GAO-04-1024 Great Lakes 
Appendix VII: Comments from the 

Environmental Protection Agency 

Page 57 GAO-04-1024 Great Lakes 
Appendix VIII: GAO Contact and Staff 

Acknowledgments 

Page 58 GAO-04-1024 Great Lakes 

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

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. 

Appendix VIII: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(360387) 
The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help 

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost 

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To 

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov(202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER
United States

Government Accountability Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Service Requested

Presorted Standard

Postage & Fees Paid

GAO

Permit No. GI00