United States Government Accountability Office

GAO Report to Congressional Requesters

GREAT LAKES 

EPA and States Have 

Made Progress in 

Implementing the 

BEACH Act, but 

Additional Actions 

Could Improve Public 

Health Protection 

May 2007 

 

GAO-07-591 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 2007

GREAT LAKES

EPA and States Have Made Progress in 

Implementing the BEACH Act, but 

Additional Actions Could Improve Public 

Health Protection 

Highlights of GAO-07-591, a report to 

Congressional Requesters 

Waterborne pathogens can

contaminate water and sand at 

beaches and threaten human 

health. Under the Beaches 

Environmental Assessment and 

Coastal Health (BEACH) Act, the 

Environmental Protection Agency

(EPA) developed limits on 

pathogens that states use to assess 

beach water quality. EPA can also

provide grants to states to develop 

water quality monitoring and public 

notification programs. 

GAO was asked to assess (1) the 

extent to which EPA implemented 

the BEACH Act including how it 

allocated grants to the states, (2)

the monitoring and notification 

programs developed by Great Lakes 

states, and (3) the effect of the 

BEACH Act on water quality

monitoring and contamination at 

Great Lakes beaches.

EPA has taken steps to implement most of the provisions of the BEACH Act 

but has missed statutory deadlines for two critical requirements. While EPA 

has developed a national list of beaches and improved the uniformity of state 

water quality standards, it has not (1) completed the pathogen and human 

health studies required by 2003 or (2) published the new or revised water 

quality criteria for pathogens required by 2005. Moreover, the formula EPA 

has used to distribute approximately $51 million in BEACH Act grants from 

2001-2006 does not accurately reflect the monitoring needs of the states. 

This is because the formula emphasizes the length of the beach season more 

than the other factors—beach miles and beach use. These other factors vary 

widely among the states, can greatly influence the amount of monitoring a 

state needs to undertake, and can increase the public health risk. 

All eight Great Lakes states have used BEACH Act grants to develop beach 

monitoring and public notification programs. However, because these 

programs vary among the states they may not provide consistent levels of 

public health protection within and across Great Lakes beaches. For 

example, GAO found that the states’ monitoring and notification programs 

varied considerably in the frequency with which beaches were monitored, 

the monitoring methods used, and how the public was notified of potential 

health risks. For example, some states monitor their high-priority beaches as 

little as one or two times per week, while others monitor their high-priority 

beaches daily. In addition, when local officials review similar water quality 

results, some may choose to only issue a health advisory while others may 

choose to close the beach. According to state and local officials, these 

inconsistencies are in part due to the lack of adequate funding for their 

beach monitoring and notification programs.

The frequency of water quality monitoring has increased at Great Lakes 

beaches since the passage of the BEACH Act, helping states and localities to 

identify the scope of contamination. However, in most cases, the underlying

causes of contamination remain unknown and unaddressed. This is because 

some state and local officials reported that they do not have the funds to 

investigate the source of the contamination or take actions to mitigate the 

problem, and EPA has concluded that BEACH Act grants generally may not 

be used for these purposes. For example, local officials at 67 percent of 

Great Lakes beaches reported that, when results of water quality testing 

indicated contamination at levels exceeding the applicable standards during 

the 2006 beach season, they did not know the source of the contamination, 

and only 14 percent reported that they had taken actions to address the 

sources of contamination. State and local officials indicated that an overall 

improvement in water quality throughout the Great Lakes will require longterm collaborative efforts to address the underlying causes of 

contamination, as well as increased funding.

What GAO Recommends

GAO recommends that EPA 

distribute grant funds in a way that 

reflects states’ monitoring needs 

and help states improve the 

consistency of their monitoring and 

notification activities. In addition,

Congress should consider 

providing EPA more flexibility to 

allow states to use BEACH Act 

grants to investigate and remediate 

contamination sources. 

EPA generally agreed with GAO’s

recommendations but stated that 

states may resist making 

substantial changes to the funding

formula because of their tight

budgets. 

www.gao.gov/cgi-bin/getrpt?GAO-07-591.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Anu K. Mittal at 

(202) 512-3841 or mittala@gao.gov. 
Contents 

Letter 1

Results in Brief 4

Background 6

EPA Has Taken Steps to Implement the BEACH Act, but Its Grant 

Distribution Formula Does Not Adequately Reflect States’ 

Monitoring Needs 11 

Great Lakes States’ Beach Monitoring and Public Notification

Programs Vary Across Localities and May Not Provide 

Consistent Levels of Public Health Protection 21 

The BEACH Act Has Helped Identify the Scope of Contamination, 

but Underlying Causes Remain Unaddressed 31 

Conclusions 40

Matter for Congressional Consideration 41 

Recommendations for Executive Action 41 

Agency Comments and Our Evaluation 42 

Appendix I Scope and Methodology 45 

Appendix II Map of 35 States and Territories with Coastal

Recreational Waters 49 

Appendix III GAO’s Calculations for an Alternative BEACH Act 

Grant Distribution Formula 50 

Appendix IV Comments from the Environmental Protection 

Agency 57 

Appendix V GAO Contact and Staff Acknowledgments 60 

Tables 

Table 1: BEACH Act Grant Distribution Formula 19 

Page i GAO-07-591 Great Lakes Beaches
Table 2: BEACH Act Funding Formula Inputs for Great Lakes 

States 20 

Table 3: Number of Great Lakes Beaches Identified, Number and 

Percentage of Beaches Being Monitored for the 2006

Beach Season 23 

Table 4: Great Lakes Prioritized Beaches Reported by States for 

Monitoring Using BEACH Act Grant Funds as of October 

2006 24 

Table 5: Monitoring Frequency of Great Lake Beaches by Priority 26 

Table 6: Variation in Great Lakes States’ Pathogen Indicator (E. 

coli) Thresholds and Responses to Water Quality 

Exceedances 29

Table 7: Great Lakes Beaches Reported Monitored by EPA in 2005, 

GAO Sample, and Sample Disposition by State 46 

Table 8: EPA Beach Season Length Factor and States Associated 

Funding Levels 50 

Table 9: EPA’s Formula for Distributing $30 Million in BEACH Act 

Grants 51

Table 10: EPA’s Formula for Distributing $10 Million in BEACH Act 

Grants 52

Table 11: Factors Used in BEACH Act Formula Allocations and 

Resulting 2006 Grants by State and Territory 52 

Table 12: Difference in Allocations Using Current and Alternative 

Formulas 55

Figures 

Figure 1: Map of the Five Great Lakes and Eight Great Lakes States 

with Population Density by County 7 

Figure 2: Potential Sources of Fecal Contamination at Beaches in 

the Great Lakes 9 

Figure 3: Time Lag Associated with Current Water Quality 

Monitoring and Public Notification Methods 17 

Figure 4: Reported Depth of Water Quality Sampling at Great Lakes 

Beaches 28

Figure 5: Variation in Public Notification Signs at Great Lakes

Beaches 30

Figure 6: Number of Identified Beaches and Number of Identified 

Beaches Monitored in the Great Lakes from 1999 to 2005 32 

Figure 7: Estimated Changes in Frequency of Monitoring at Great 

Lakes Beaches Since Passage of the BEACH Act 33 

Page ii GAO-07-591 Great Lakes Beaches
Figure 8: Number of Great Lakes Identified Beaches Monitored and 

Monitored Beaches with at Least One Closure or Advisory 

from 1999 to 2005 34 

Figure 9: Estimated Change in Ability to Make Decisions Based on 

Water Quality Data Since Passage of the BEACH Act 35 

Figure 10: Changes to Beach Grooming Process at a Racine, 

Wisconsin, Beach 37 

Figure 11: Estimated Change in Public Awareness of Personal 

Actions on Water Quality at Great Lakes Beaches Since 

Passage of the BEACH Act 38 

Abbreviations 

BEACH Act Beaches Environmental Assessment and Coastal Health Act 

EPA Environmental Protection Agency 

NOAA National Oceanic and Atmospheric Administration

USGS United States Geological Survey 

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

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reproduce this material separately. 

Page iii GAO-07-591 Great Lakes Beaches
United States Government Accountability Office

Washington, DC 20548 

May 1, 2007

Congressional Requesters

There are hundreds of beaches along the 5,000 miles of Great Lakes’ 

shoreline that spans eight states: Illinois, Indiana, Michigan, Minnesota, 

New York, Ohio, Pennsylvania, and Wisconsin. These beaches provide 

recreational opportunities to more than 30 million residents and visitors 

each year. However, waterborne pathogens—bacteria, viruses, and 

parasites that live in the gastrointestinal tract of humans and other warmblooded animals—can contaminate the water and sand at these beaches 

and threaten human health. The key contributors to this contamination are 

partially treated discharges from wastewater treatment plants; droppings 

from wildlife, such as gulls and geese; and agricultural and municipal 

waste that is often transported to beach-area waters by rain and storm 

water runoff. Contact with or accidental ingestion of contaminated water 

can cause vomiting, diarrhea, and other illnesses, and may be lifethreatening for susceptible populations such as children, the elderly, and

those with impaired immune systems. State and local health officials may 

issue health advisories or close beaches when they believe levels of 

waterborne pathogens are high enough to threaten human health. The 

Natural Resources Defense Council reported that, in 2005, the Great Lakes 

beaches had at least 2,740 days of health advisories or beach closures. 

There are hundreds of beaches along the 5,000 miles of Great Lakes’ 

shoreline that spans eight states: Illinois, Indiana, Michigan, Minnesota, 

New York, Ohio, Pennsylvania, and Wisconsin. These beaches provide 

recreational opportunities to more than 30 million residents and visitors 

each year. However, waterborne pathogens—bacteria, viruses, and 

parasites that live in the gastrointestinal tract of humans and other warmblooded animals—can contaminate the water and sand at these beaches 

and threaten human health. The key contributors to this contamination are 

partially treated discharges from wastewater treatment plants; droppings 

from wildlife, such as gulls and geese; and agricultural and municipal 

waste that is often transported to beach-area waters by rain and storm 

water runoff. Contact with or accidental ingestion of contaminated water 

can cause vomiting, diarrhea, and other illnesses, and may be lifethreatening for susceptible populations such as children, the elderly, and

those with impaired immune systems. State and local health officials may 

issue health advisories or close beaches when they believe levels of 

waterborne pathogens are high enough to threaten human health. The 

Natural Resources Defense Council reported that, in 2005, the Great Lakes 

beaches had at least 2,740 days of health advisories or beach closures. 

Under the Clean Water Act, the Environmental Protection Agency (EPA) is 

responsible for publishing water quality criteria that establish thresholds 

at which contamination—including waterborne pathogens—may threaten 

human health. States are required to develop standards, or legal limits, for 

these pathogens by either adopting EPA’s recommended water quality 

criteria or other criteria that EPA determines are equally protective of 

human health. The states then use these pathogen standards to assess 

water quality at their recreational beaches. However, because many 

pathogens are difficult and costly to detect, state and local officials have

typically used more easily identified organisms that indicate that 

pathogens may be present. During the 1960s and 1970s, EPA evaluated 

several types of bacteria for use as pathogen indicators and recommended 

using fecal coliforms—bacteria found in the intestines of humans and 

warm-blooded animals––as a pathogen indicator for states’ recreational 

water quality standards. By 1986, new research questioned the reliability of 

using fecal coliforms as a pathogen indicator, prompting EPA to 

recommend new criteria using E.coli and enterococci as pathogen 

Under the Clean Water Act, the Environmental Protection Agency (EPA) is 

responsible for publishing water quality criteria that establish thresholds 

at which contamination—including waterborne pathogens—may threaten 

human health. States are required to develop standards, or legal limits, for 

these pathogens by either adopting EPA’s recommended water quality 

criteria or other criteria that EPA determines are equally protective of 

human health. The states then use these pathogen standards to assess 

water quality at their recreational beaches. However, because many 

pathogens are difficult and costly to detect, state and local officials have

typically used more easily identified organisms that indicate that 

pathogens may be present. During the 1960s and 1970s, EPA evaluated 

several types of bacteria for use as pathogen indicators and recommended 

using fecal coliforms—bacteria found in the intestines of humans and 

warm-blooded animals––as a pathogen indicator for states’ recreational 

water quality standards. By 1986, new research questioned the reliability of 

using fecal coliforms as a pathogen indicator, prompting EPA to 

recommend new criteria using E.coli and enterococci as pathogen 

Page 1 GAO-07-591 Great Lakes Beaches
indicators. However, as of 2000, only 11 states had adopted EPA’s 

recommended 1986 criteria for testing their recreational waters. 

Recognizing the need for consistent water quality criteria at recreational 

beaches, Congress passed the Beaches Environmental Assessment and 

Coastal Health (BEACH) Act of 2000 to improve states’ beach monitoring 

programs and processes for notifying the public of potential health risks 

from contamination at beaches. The BEACH Act amended the Clean Water 

Act to require the 35 eligible states and territories––including the 8 Great 

Lakes states—to update their recreational water quality standards using 

EPA’s 1986 criteria for pathogen indicators. In addition, the BEACH Act 

required EPA to (1) complete studies on pathogens in coastal recreational

waters and how they affect human health, including developing rapid 

methods of detecting pathogens by October 2003, and (2) publish new or 

revised water quality criteria by October 2005, to be reviewed and revised 

as necessary every 5 years thereafter.

The act also authorized EPA to award grants to states, localities, and tribes 

to develop comprehensive beach monitoring and public notification 

programs for their recreational beaches. To be eligible for BEACH Act 

grants, states are required to (1) identify their recreational beaches, (2) 

prioritize their recreational beaches for monitoring based on their use by 

the public and the risk to human health, and (3) establish a public 

notification program. EPA grant criteria give states some flexibility on the 

frequency of monitoring, methods of monitoring, and processes for 

notifying the public when pathogen indicators exceed state standards, 

including whether to issue health advisories or close beaches. The BEACH 

Act authorized EPA to provide $30 million in grants annually for fiscal 

years 2001 through 2005.

1

 However, since fiscal year 2001, congressional 

conference reports accompanying EPA’s appropriations acts have directed 

about $10 million annually for grants under the act. EPA has followed this 

congressional direction when allocating funds to the program. 

In the context of continuing health advisories and beach closures at Great 

Lakes beaches since passage of the BEACH Act, you asked us to (1) 

determine the extent to which EPA has implemented the act and evaluate

EPA’s formula for allocating BEACH Act grants, (2) describe and evaluate 

the monitoring and notification programs the eight Great Lakes states have

 1

Although the BEACH Act was originally authorized through 2005, Congress continued to

fund EPA’s efforts under the act in 2006 and 2007. 

Page 2 GAO-07-591 Great Lakes Beaches
developed using BEACH Act grants, and (3) determine the effect that the 

BEACH Act has had on water quality monitoring and contamination at 

Great Lakes beaches. 

To determine the status of EPA’s implementation of the BEACH Act, we 

analyzed the act, obtained and analyzed relevant agency documentation, 

and interviewed officials from EPA headquarters and Region 5 (Chicago) 

offices. To evaluate EPA’s formula for allocating BEACH Act grants, we 

obtained and analyzed EPA data on funding levels, interviewed officials 

that developed the allocation formula, and conducted simulations to 

demonstrate how alterations of the formula would shift funding and 

potentially affect current allocations. To evaluate the programs the eight 

Great Lakes states have developed using their BEACH Act grants, we 

conducted a survey of a random sample of 140 of the 563 beaches EPA 

identified as being monitored in the Great Lakes in 2005. Information 

obtained through this survey was used to produce estimates2

 of beach

monitoring and notification activities at monitored Great Lakes beaches 

for the 2006 beach season. We distributed an electronic questionnaire via 

e-mail to local officials at a random sample of 140 beaches, and 93 percent

of those surveyed responded to our questionnaire. Information obtained 

through this survey was used to produce estimates of beach monitoring 

and notification activities for the entire population of monitored Great 

Lakes beaches for the 2006 beach season. In addition, we interviewed 

BEACH Act administrators from each of the Great Lakes states. To 

determine the effect the BEACH Act has had on Great Lakes beach 

monitoring and contamination levels, we analyzed the results of our 

questionnaire and the information provided by the eight state BEACH Act 

administrators. We also met with and gathered information from other 

agencies and nonprofit organizations working on Great Lakes issues, such 

as the National Oceanic and Atmospheric Administration (NOAA), the U.S. 

Geological Survey (USGS), the Metropolitan Water Reclamation District of 

Greater Chicago, and the Natural Resources Defense Council. We took 

steps to assess the reliability of EPA data on monitored beaches. Appendix 

I includes more information about our scope and methodology. We 

conducted our work from June 2006 through March 2007 in accordance 

with generally accepted government auditing standards. 

 2

In this report, all percentages based on our survey are estimates and subject to sampling 

error. Unless otherwise noted, all percentage estimates from this survey have 95 percent

confidence intervals of within plus or minus 10 percentage points of the estimate. 

Page 3 GAO-07-591 Great Lakes Beaches
Results in Brief EPA has implemented seven of the BEACH Act’s nine requirements and 

provisions. For example, EPA promulgated water quality standards for the 

21 states and territories that had not adopted EPA’s 1986 water quality 

criteria and developed a national list of beaches. However, EPA has not 

(1) completed the pathogen and human health studies that were required 

by 2003 or (2) published new or revised water quality criteria for 

pathogens or pathogen indicators that were required by 2005. EPA told us 

that the required studies are ongoing, but may take an additional 4 to 5 

years to complete, and that the development of new pathogen indicators 

would follow completion of the studies. Although EPA has distributed 

approximately $51 million in BEACH Act grants between 2001 and 2006 to 

the 35 eligible states and territories, EPA’s formula for distributing BEACH 

Act grant funds does not reflect the states’ varied monitoring needs. EPA 

considered the BEACH Act’s emphasis on beach use and risk to human 

health in developing the formula, which is based on three factors—length 

of beach season; beach miles, as measured by length of shoreline; and 

beach use, as measured by coastal population. If the program had received 

its full funding of $30 million, each of the three factors would have had 

approximately the same level of influence on the amount of BEACH Act 

grant funds allocated to the states. However, because funding allocations 

have only been about $10 million annually, the beach season factor has 

had a greater influence (about 82 percent) on the total BEACH Act grants 

each state received, while beach miles and beach use, which vary widely 

among the states and can impact the public health risk, have had a 

significantly smaller impact (about 9 percent each). As a result, while the 

Great Lakes state’s beach monitoring needs vary widely because of their 

differing coastlines and coastal populations, the amount of each state’s 

BEACH Act grant is almost the same. For example, Indiana, which has 45 

miles of shoreline and a coastal population of 741,468, received about 

$205,800 in 2006 while Michigan, which has 3,224 miles of shoreline and a 

coastal population of 4,842,023, received about $278,450 in 2006. 

Each of the eight Great Lakes states has used its BEACH Act grant funding 

to develop beach monitoring and public notification programs, but these 

programs vary across states and localities and may not consistently 

protect public health. Prior to the BEACH Act, only five of the eight Great 

Lakes states had water quality monitoring programs, and now all eight 

have a program in place. However, the Great Lake states’ monitoring and 

notification programs vary considerably in the frequency with which they 

monitor their beaches, their monitoring methods, and their means of 

notifying the public of health risks. For example, some states monitor 

beaches they have designated as high priority as little as one or two times 

per week, while others monitor their high-priority beaches daily. These 

Page 4 GAO-07-591 Great Lakes Beaches
differences are due, in part, to the current BEACH Act funding levels, 

which some Great Lakes state officials reported are inadequate for 

sufficient monitoring. In addition, when local officials review water quality 

results, they may make different decisions on whether or not to issue a 

health advisory or close a beach even though the results show the same 

level of contamination. This happens because, according to Great Lakes 

states BEACH Act administrators, two states only issue health advisories, 

two states only close beaches, and four states may take either of these 

actions when water quality standards have been exceeded. 

Since the passage of the BEACH Act, the frequency of water quality 

monitoring at Great Lakes beaches has increased, helping states and 

localities to identify the scope of contamination; however, in most cases, 

the underlying causes of the contamination remain unknown and 

unaddressed. Local officials reported that the frequency of monitoring had 

increased at 45 percent of Great Lakes beaches since the passage of the 

BEACH Act. The increased monitoring has helped state and local officials 

determine which beaches are more likely to be contaminated. However, in 

most cases, local officials do not know the causes of contamination and,

consequently, have not been able to take actions to address those causes. 

Local officials at 67 percent of Great Lakes beaches did not know the 

sources of bacterial contamination causing their exceedances of water 

quality standards during the 2006 beach season. Furthermore, local

officials indicated that actions to address the sources of contamination 

had only been taken at an estimated 14 percent of the monitored beaches 

we surveyed. Local officials generally stated that they do not have the 

funds available to do the investigations necessary to identify specific 

sources of contamination or to take actions to mitigate the problem, and 

they can not use BEACH grant funds for this purpose. Our review of the 

BEACH Act and discussions with EPA officials indicate that it appears 

EPA cannot award BEACH Act grants for these purposes. According to 

state and local officials, an overall improvement in water quality 

throughout the Great Lakes will require a long-term collaborative effort to 

address the underlying causes of contamination and also will require 

increased funding. 

To assist states and localities in identifying and addressing sources of 

beach contamination, Congress should consider allowing states some 

flexibility to use their BEACH Act grants to undertake limited research to 

identify specific sources of contamination at monitored beaches and take

certain actions to mitigate these problems. In addition, we are

recommending that EPA establish a definitive time line for completing the

studies on pathogens and their effects on human health and for publishing 

Page 5 GAO-07-591 Great Lakes Beaches
new or revised water quality criteria for pathogens and pathogen 

indicators. To better account for states’ varied monitoring needs, if current 

funding levels remain the same, EPA should reevaluate the funding 

formula factors to determine if the weight of the beach season factor 

should be reduced, and the weight of the other factors should be 

increased. To better ensure consistent levels of public health protection,

EPA should also provide states and localities with specific guidance on

monitoring frequency and methods and public notification. In commenting 

on the draft report, EPA generally agreed with GAO’s recommendations 

and agreed to (1) take actions to establish an action plan and a definitive 

time frame to complete studies and publish revised water quality 

standards and (2) revise its guidance to states. With respect to our 

recommendation to revise the current funding formula to better reflect 

states’ needs, EPA agreed with this recommendation, but stated that the

states were reluctant to make any substantial changes to the formula and 

were supportive of EPA’s plan to make only minor changes to the formula. 

More than 30 million people in the United States rely on the five Great 

Lakes—Superior, Michigan, Huron, Erie, and Ontario—as a principal 

source of their drinking water, recreation, and economic livelihood. There 

are hundreds of beaches along the Great Lakes’ approximately 5,000 miles

of U.S. shoreline that spans eight states: Illinois, Indiana, Michigan, 

Minnesota, New York, Ohio, Pennsylvania, and Wisconsin. Figure 1 shows 

the five lakes and the eight states with Great Lakes shorelines, along with 

their population concentrations. 

Background 

Page 6 GAO-07-591 Great Lakes Beaches
Figure 1: Map of the Five Great Lakes and Eight Great Lakes States with Population Density by County 

Development on lands adjacent to the lakes has seriously degraded the 

lakes’ water quality and, in some areas, contaminated recreational waters 

with pathogens—including bacteria, viruses, and parasites—that can 

threaten human health and force restrictions on recreational activities 

such as swimming at the beaches. Contact with or accidental ingestion of

water contaminated with these pathogens can cause vomiting, diarrhea,

and other illnesses, and may be life-threatening for susceptible 

populations such as children, the elderly, and those with impaired immune

systems. When pathogen levels are high enough to threaten human health, 

County population

per square mile

4-50

51-100

101-500

501-1,000

1,001-2,000

2,001-5,538

Sources: United States Census Bureau Population Estimates, 2005. Map: Ginny Mason, Congressional Cartography,

Library of Congress, 2006.

0 50 miles

MICHIGAN

ILLINOIS

INDIANA OHIO PENNSYLVANIA

NEW YORK

IOWA

MINNESOTA

WISCONSIN

Lake Ontario

Lake 

Huron

Lake Superior

Lake Erie

Lake 

Michigan

Pittsburgh

Akron

Toledo

Fort

Wayne

Grand Buffalo

Milwaukee Rapids

Rockford

Madison

C evelan

Chic

Detro t

St. Pau

oli Minneapol s

Cleveland

Chicago

Detroit

St. Paul

Minneapolis

Rochester

Page 7 GAO-07-591 Great Lakes Beaches
officials from local health departments or municipalities restrict public 

access to beaches by issuing health advisories or through the use of beach 

closures to lower the risk of public exposure to these pathogens. 

One of the key contributors to this waterborne contamination is fecal 

matter from humans and other warm-blooded animals. While sources can 

vary from beach to beach, those close to urban areas are more likely to be

affected by sources such as wastewater treatment plants, combined sewer 

overflows, and municipal storm sewer systems that can directly contribute 

to high levels of bacterial contamination. Beaches in states with large 

confined animal feeding operations may be affected by runoff from these 

operations. Many beaches are affected by nonpoint source pollution when 

storm water runs off impervious surfaces such as streets and parking lots 

and picks up pollutants along the way. In addition, wildlife—in particular 

seagulls and geese—can congregate on beaches and lead to significant 

levels of fecal contamination. Figure 2 shows some of the potential 

sources of fecal contamination at beaches in the Great Lakes.

Page 8 GAO-07-591 Great Lakes Beaches
Figure 2: Potential Sources of Fecal Contamination at Beaches in the Great Lakes

Boat waste discharge Wastewater treatment facility

Storm water runoff

Stream/river discharge point

Wildlife

Contaminated sand

1

4

5

2

3

1

2

3

4

5

6

Septic systems

Agricultural runoff

7

7 8

8

Sources: GAO (data); EPA (photo insert).

6

Under the Clean Water Act, EPA is responsible for publishing water 

quality criteria that identify thresholds at which pathogens may constitute 

a risk to human health. States can then use EPA’s criteria, or propose 

Page 9 GAO-07-591 Great Lakes Beaches
other criteria that EPA deems are as protective of human health, to 

develop water quality standards for their recreational beaches.3

 Because 

pathogens are found sporadically in recreational waters and can be 

difficult and costly to detect, EPA has recommended other more easily 

identified organisms—called pathogen indicators—that can indicate the 

potential for the presence of pathogens. During the 1960s and 1970s, EPA 

evaluated several types of bacteria for use as pathogen indicators and 

recommended using fecal coliforms as a pathogen indicator for state 

recreational water quality standards. By 1986, new research questioned the 

reliability of using fecal coliforms as a pathogen indicator and prompted 

EPA to recommend new criteria using E. coli for freshwater and 

enterococci for fresh and marine recreational waters. 

In 1997, EPA announced a new national program to work with state, tribal, 

and local governments to compile information on beach contamination 

defining the national extent of the problem. EPA began gathering 

information on state and local beach programs through its National 

Health Protection Survey of Beaches in 1998. The survey collected 

information on monitoring methods used to issue advisories and closures 

and the sources of contamination at swimming beaches. In 1999, EPA 

published a multiyear strategy aimed at improving recreational water 

quality programs. This action plan noted that water quality monitoring 

programs varied widely at the state and local levels, and its objective was 

to enable the consistent management of recreational water quality 

programs. 

Congress passed the BEACH Act in 2000, amending the Clean Water Act to 

improve beach water quality monitoring notification programs. The act 

defines coastal recreation waters as Great Lakes and marine coastal 

waters designated for swimming, bathing, or similar water contact 

activities; inland waters are not included in this definition. The BEACH Act

required states to adopt new or revised water quality standards by April 

10, 2004, for pathogens and pathogen indicators for their coastal 

recreation waters that were as protective as EPA’s published criteria. The

act required EPA to propose regulations setting forth new or revised water 

quality standards for states that had failed to meet this deadline. In 

addition, the BEACH Act required EPA to conduct studies of the 

relationship between pathogens and human health and to publish new or 

 3

Water quality standards include narrative and numeric criteria that support specific 

designated uses and also specify goals to prevent degradation of good quality waters. 

Page 10 GAO-07-591 Great Lakes Beaches
revised criteria based on those studies. The BEACH Act also authorized 

EPA to award grants to states, local governments, and tribes to develop

and implement beach monitoring and notification programs. The BEACH 

Act required EPA to develop and publish performance criteria that 

recipients must meet in order to receive these grants. 

EPA has implemented seven of the nine BEACH Act requirements and 

provisions and has distributed approximately $51 million in BEACH Act 

grants since 2001 and created a national water pollution database, among 

other requirements. However, EPA has missed statutory deadlines for two 

actions: (1) completing required studies on pathogens and human health 

for both marine and freshwater by 2003 and (2) using these studies to 

publish new or revised water quality criteria for pathogen indicators by 

2005. In addition, the grant distribution formula that EPA developed to 

distribute BEACH Act grants does not adequately reflect the states’ varied 

beach monitoring needs because it does not appropriately reflect the 

length of beach miles needing monitoring or the population using the 

beaches. 

Of the nine actions required by the BEACH Act, EPA has taken the 

following seven: 

Propose water quality standards and criteria—The BEACH Act required 

each state with coastal recreation waters4

 to incorporate EPA’s published 

criteria for pathogens or pathogen indicators, or criteria EPA considers 

equally protective of human health, into their state water quality standards 

by April 10, 2004. The BEACH Act also required EPA to propose 

regulations setting forth federal water quality standards for those states 

that did not meet the deadline. On November 16, 2004, EPA published in 

the Federal Register a final rule promulgating its 1986 water quality 

standards for E. coli and enterococci for the 21 states and territories that 

had not adopted water quality criteria that were as protective of human 

EPA Has Taken Steps 

to Implement the 

BEACH Act, but Its 

Grant Distribution 

Formula Does Not 

Adequately Reflect 

States’ Monitoring 

Needs 

EPA Has Implemented 

Some but Not All BEACH 

Act Requirements and 

Provisions 

 4

The BEACH Act defines coastal recreation waters as the Great Lakes and coastal waters 

(including coastal estuaries) that states, territories, and authorized tribes officially 

recognize (or “designate”) for swimming, bathing, surfing, or similar activities in the water. 

The BEACH Act applies to 30 coastal and Great Lakes states and 5 U.S. territories. See

appendix II for a map of the 35 states and territories with coastal recreational waters. 

Page 11 GAO-07-591 Great Lakes Beaches
health as EPA’s approved water quality criteria.5

 According to EPA, all 35

states with coastal recreational waters are now using EPA’s 1986 criteria, 

compared with the 11 states that were using these criteria in 2000. 

Provide BEACH Act grants—The BEACH Act authorized EPA to 

distribute annual grants to states, territories, tribes and, in certain 

situations, local governments to develop and implement beach monitoring 

and notification programs. While the BEACH Act authorized $30 million 

per year for BEACH Act grants, actual allocations have been about $10 

million a year in accordance with directions from Congressional 

conference reports. Since 2001, EPA has awarded approximately $51 

million in development and implementation grants for beach monitoring 

and notification programs to all 35 states. Alaska is the only eligible state 

that has not yet received a BEACH Act implementation grant because it is 

still in the process of developing a monitoring and public notification 

program consistent with EPA’s grant performance criteria. EPA expects to 

distribute approximately $10 million for the 2007 beach season subject to 

the availability of funds.

Publish beach monitoring guidance and performance criteria for 

grants—The BEACH Act required EPA to develop guidance and 

performance criteria for beach monitoring and assessment for states 

receiving BEACH Act grants by April 2002. After a year of consultations 

with coastal states and organizations, EPA responded to this requirement 

in 2002 by issuing its National Beach Guidance and Required

Performance Criteria for Grants. To be eligible for BEACH Act grants, 

EPA requires recipients to develop (1) a list of beaches evaluated and

ranked according to risk, (2) methods for monitoring water quality at their 

beaches, such as when and where to conduct sampling, and (3) plans for 

notifying the public of the risk from pathogen contamination at beaches, 

among other requirements. 

Develop a list of coastal recreational waters—The BEACH Act required 

EPA to identify and maintain a publicly available list of coastal

recreational waters adjacent to beaches or other publicly accessible areas, 

with information on whether or not each is subject to monitoring and 

 5

EPA worked with the states and territories to identify their existing water quality 

standards and to review them for consistency with the BEACH Act requirements. On April 

16, 2004, EPA sent a letter to environmental agencies at all 35 states with coastal 

recreational waters and proposed federal standards for those states that had not yet

adopted EPA’s 1986 criteria. 

Page 12 GAO-07-591 Great Lakes Beaches
public notification. In March 2004, EPA published its first comprehensive 

National List of Beaches based on information that the states had provided

as a condition for receiving BEACH Act grants. The list identified 6,099 

coastal recreational beaches, of which 3,472, or 57 percent, are being

monitored. The BEACH Act also requires EPA to periodically update its 

initial list and publish revisions in the Federal Register. However, EPA has 

not yet published a revised list, in part because some states have not 

provided updated information. 

Develop a water pollution database—The BEACH Act required EPA to 

establish, maintain, and make available to the public an electronic national 

water pollution database. In May 2005, EPA unveiled “eBeaches,” a 

collection of data pulled from multiple databases on the location of 

beaches, water quality monitoring, and public notifications of beach 

closures and advisories.6 This information has been made available to the 

public through an online tool called BEACON (Beach Advisory and 

Closing Online Notification). EPA officials acknowledge that eBeaches has 

had some implementation problems, including periods of downtime when 

states were unable to submit their data, and states have had difficulty 

compiling the data and getting it into EPA’s desired format. EPA is 

working to centralize its databases so that states can more easily submit 

information and expects the data reporting will become easier for states as 

they further develop their system. 

Provide technical assistance on floatable materials—The BEACH Act 

required EPA to provide technical assistance to help states, tribes, and 

localities develop their own assessment and monitoring procedures for 

floatable debris in coastal recreational waters. EPA responded by 

publishing guidance titled Assessing and Monitoring Floatable Debris in 

August 2002. The guidance provided examples of monitoring and 

assessment programs that have addressed the impact of floatable debris 

and examples of mitigation activities to address floatable debris. 

Provide a report to Congress on status of BEACH Act implementation—

The BEACH Act required EPA to report to Congress 4 years after 

 6

In order to house the water quality data, EPA decided to use EPA’s previously existing 

STORET (STORage and RETrieval) database. For beach advisory and closing data, EPA 

created the PRAWN (Program Tracking database for Advisories, Water Quality Standards, 

and Nutrients) database. STORET is the repository for water quality, biological, and 

physical data and is used by EPA offices, state environmental agencies, universities, and 

other organizations. PRAWN is a repository for beach advisory and closing data. 

Page 13 GAO-07-591 Great Lakes Beaches
enactment of the act and every 4 years thereafter on the status of 

implementation. EPA completed its first report for Congress, 

Implementing the BEACH Act of 2000: Report to Congress in October 

2006, which was 2 years after the October 2004 deadline. EPA officials 

noted that they missed the deadline because they needed additional time 

to include updates on current research and states’ BEACH Act 

implementation activities and to complete both internal and external 

reviews. 

EPA has not yet completed the following two BEACH Act requirements: 

Conduct epidemiological studies—The BEACH Act required EPA to 

publish new epidemiological studies concerning pathogens and the 

protection of human health for marine and freshwater by April 10, 2002,

and to complete the studies by October 10, 2003. The studies were to: (1) 

assess potential human health risks resulting from exposure to pathogens 

in coastal waters; (2) identify appropriate and effective pathogen 

indicator(s) to improve the timely detection of pathogens in coastal 

waters; (3) identify appropriate, accurate, expeditious, and cost-effective 

methods for detecting the presence of pathogens; and (4) provide 

guidance for state application of the criteria. EPA initiated its multiyear 

National Epidemiological and Environmental Assessment of 

Recreational Water Study in 2001 in collaboration with the Centers for 

Disease Control and Prevention. The first component of this study was to 

develop faster pathogen indicator testing procedures. The second 

component was to further clarify the health risk of swimming in 

contaminated water, as measured by these faster pathogen indicator 

testing procedures.7

 While EPA completed these studies for freshwater––

showing a promising relationship between a faster pathogen indicator and 

possible adverse health effects from bacterial contamination––they have

not completed the studies for marine water. EPA initiated marine studies 

in Biloxi, Mississippi, in the summer of 2005, 3 years past the statutory 

deadline for beginning this work, but the work was interrupted by 

Hurricane Katrina. EPA officials reported that additional studies are 

planned for the summer of 2007, pending funding. 

 7

EPA used quantitative polymerase chain reaction (PCR) method to quantify two types of 

bacteria, enterococci and bacteroides, at four freshwater beaches on Lake Michigan and 

Lake Erie. The results of the water quality tests were then correlated to health surveys of 

beachgoers who swam at the beaches, by interviewing beachgoers as they left the beach, 

and again by telephone 10 to 12 days after their beach visit to assess the levels of diarrhea 

and gastrointestinal illness, as well as other adverse health effects.

Page 14 GAO-07-591 Great Lakes Beaches
Publish new pathogen criteria—The BEACH Act required EPA to use the 

results of its epidemiological studies to identify new pathogen indicators 

with associated criteria, as well as new pathogen testing measures by 

October 2005. However, since EPA has not completed the studies on 

which these criteria were to be based, this task has been delayed. 

An EPA official reports that EPA has not established a time line for 

completing these two remaining provisions of the BEACH Act but 

estimates it may take an additional 4-5 years. One EPA official told us that 

the initial time frames in the act may not have been realistic. EPA’s failure 

to complete studies on the health effects of pathogens for marine waters 

and failure to publish revised water quality criteria for pathogens and 

pathogen indicators prompted the Natural Resources Defense Council to 

file suit against EPA on August 2, 2006, for failing to comply with the 

statutory obligations of the BEACH Act. 

In the absence of new criteria for pathogens and pathogen indicators, 

states continue to use EPA’s 1986 criteria. EPA reaffirmed the use of these

indicators when it published the draft Implementation Guidance for 

Ambient Water Quality for Bacteria in May 2002 and when it set forth 

state water quality standards in November 2004. However, there are two 

significant limitations to using these indicators: 

• The current approved methods of analyzing E.coli and enterococci require 

a long incubation period, during which time the bacteria grow to 

detectable levels. Local officials at 96 percent of Great Lakes beaches 

reported that it took 18-36 hours to get results on water quality samples 

once the samples reached the laboratory. Consequently, water quality 

sample results indicate the previous day’s bacterial levels, and health 

advisories or beach closures are based on those levels. By the time the 

results are compiled and health advisories or notices are posted, the 

contamination may or may not have cleared up. In any case, beach 

monitoring personnel would need to retest the water to determine 

whether there was still contamination and go through this 18-36 hour cycle 

again to establish the current conditions. Real-time or near-time analytical 

methods would enable officials to better protect human health because 

their actions would be based on more timely and current information. EPA 

scientists acknowledge that the public would like nearly immediate testing 

methods, but note that the technology does not yet exist. 

• The current pathogen indicators––E.coli and enterococci ––may not be 

good indicators of the presence of pathogens or health risks. EPA 

scientists also noted that E.coli may not be an effective indicator because 

Page 15 GAO-07-591 Great Lakes Beaches
it is ubiquitous and occurs naturally in many environments. In addition, 

current testing methods cannot distinguish whether fecal contamination is 

from a human or animal source. Human fecal contamination may indicate 

the presence of pathogens that pose a greater risk to humans than does 

the presence of fecal contamination from pets or wildlife. While there are 

methods to determine the source of fecal contamination, such as microbial 

source tracking, scientists we spoke with noted that this method is timeintensive, expensive, and not readily available. 

The lack of a reliable indicator and the lag time for test results using 

current methods could lead to unnecessary beach closures, or conversely, 

keeping beaches open when they should have been closed. Because local 

officials generally use the same laboratory tests to determine the results of 

water quality sampling, this is a potential problem for all 35 states and 

territories with coastal recreational waters and not just the Great Lakes 

states. A time lag of the entire process is shown in figure 3. 

Page 16 GAO-07-591 Great Lakes Beaches
Figure 3: Time Lag Associated with Current Water Quality Monitoring and Public Notification Methods

Sources: GAO and (left to right) PhotoDisc, Creatas, and Fish and Wildlife Service (photographs).

Monday morning: take 

water sample

Results in 24-36 hours

Tuesday morning to

midafternoon: make decision on 

beach advisory/closure

Take water samples

Incubate and test water samples

2

1

3

Make advisory/closure decision and

notify public

BEACH CLOSED

Note: Figure 3 represents a best case scenario where test results are available within 24 hours. In 

some cases, it may take officials upward of 36-48 hours to get water quality results and make 

notification decisions. 

EPA’s BEACH Act Grant 

Formula Does Not 

Adequately Reflect States’ 

Monitoring Needs 

While EPA distributed approximately $51 million in BEACH Act grants 

between 2001 and 2006 to the 35 eligible states and territories, its grant 

distribution formula does not adequately account for states’ widely varied 

beach monitoring needs. When Congress passed the BEACH Act in 2000, it 

authorized $30 million in grants annually, but the act did not specify how 

EPA should distribute grants to eligible states. Beginning in 2001, EPA 

consulted with representatives from the Coastal States Organization and 

the Association of State and Interstate Water Pollution Control 

Administrators to consider the states’ needs. EPA determined that initially 

$2 million would be distributed equally to all states to cover the base cost 

of developing water quality monitoring and notification programs. EPA 

then developed a distribution formula for future annual grants that 

Page 17 GAO-07-591 Great Lakes Beaches
reflected the BEACH Act’s emphasis on beach use and risk to human 

health. EPA’s funding formula includes the following three factors: 

• Length of beach season—EPA selected beach season length8 as a factor 

because states with longer beach seasons would require more monitoring. 

• Beach use—EPA selected beach use as a factor because more heavily used

beaches would expose a larger number of people to pathogens, increasing 

the public health risk and thus requiring more monitoring. EPA used 

coastal population9

 as a proxy for beach use because information on the 

number of beach visitors was not consistently available across all the 

states. 

• Beach miles—EPA selected beach miles because states with longer 

shorelines would require more monitoring. EPA used shoreline miles,10

which may include industrial and other nonpublicly accessible areas, as a 

proxy for beach miles because verifiable data for beach miles was not 

available. 

Once EPA determined which funding formula factors to use, EPA officials 

weighted the factors. EPA intended that the beach season factor would 

provide the base funding and would be augmented by the beach use and 

beach mile factors. EPA established a series of fixed amounts that 

correspond to states’ varying lengths of beach seasons to cover the general

expenses associated with a beach monitoring program. For example, EPA 

estimated that a 3-month, or less, beach season would require 

approximately two full-time employees costing $150,000, while states with 

beach seasons greater than 6 months would require $300,000. Once the 

allotments for beach season length are distributed, EPA determined that 

50 percent of the remaining funds would be distributed according to 

states’ beach use, and the other 50 percent would be distributed according 

to states’ beach miles, as shown in table 1. 

 8

EPA used information on the length of beach seasons reported in the National Health 

Protection Survey of Beaches for the states or territories that submitted a completed 

survey. EPA estimated the beach season length for Alaska based on several factors. 

9

EPA used the Census Bureau’s 2000 Census data as a surrogate for coastal population. 

10EPA used NOAA’s The Coastline of the United States to quantify shoreline miles.

Page 18 GAO-07-591 Great Lakes Beaches
Table 1: BEACH Act Grant Distribution Formula 

Formula factor Amount of grant 

Beach season length Less than 3 months: $150,000 

3-4 months: $200,000 

5-6 months: $250,000 

Greater than 6 months: $300,000 

Beach use 50% of funds remaining after allotment of beach season length 

funding. 

Beach miles 50% of funds remaining after allotment of beach season length 

funding. 

Source: EPA. 

a

States with less than a 3-month beach season only receive the $150,000 in beach season length 

funding. 

EPA officials told us that, originally, the factors would have received

relatively equal weight. Using the distribution formula above and assuming 

a $30 million authorization, this would have resulted in the following 

allocation across the 35 eligible states: beach season—27 percent (about 

$8 million); beach use—37 percent (about $11 million); and beach miles—

37 percent (about $11 million). However, since 2002, funding levels for 

BEACH Act grants have been about $10 million each year. Once the 

approximately $8 million, of the total $10 million available for grants, was 

allotted for beach season length, this left only $2 million, instead of nearly

$22 million, to be distributed equally between the beach use and beach

miles factors. This resulted in the following allocation across the 35 

eligible states: beach season—82 percent (about $8 million); beach use—9 

percent (about $1 million); and beach miles—9 percent (about $1 million). 

As a result, beach use and beach miles, which vary widely among the 

states, account for a much smaller portion of the distribution formula and, 

consequently, there is little variation in grant amounts across the states 

compared with their monitoring needs. 

Across the Great Lakes, there is significant variation in coastal populations

and in miles of shoreline, but the current BEACH Act grant allocations are 

relatively flat. For example, Indiana, which has 45 miles of shoreline and a 

coastal population of 741,468, received about $205,800 in 2006, while 

Michigan, which has 3,224 miles of shoreline and a coastal population of 

4,842,023, received about $278,450 in 2006. If EPA were to reweight the 

factors so that they were still roughly equal given the $10 million 

Page 19 GAO-07-591 Great Lakes Beaches
appropriation, states’ grants would better reflect these variations.11 Table 2 

shows the Great Lakes states’ beach season lengths; beach use, as 

indicated by coastal populations; and beach miles, as indicated by 

shoreline miles; and compares their current BEACH Act grants with 

estimates of how much their grants would be if EPA reweighted the 

formula given the current appropriation levels of approximately $10 

million.12

Table 2: BEACH Act Funding Formula Inputs for Great Lakes States 

State 

Beach

season

length 

Beach use 

(coastal 

population in

2000) 

Beach miles 

(shoreline 

miles)

Grant allocation

(based on $10 million 

appropriation)

Estimated grant 

allocation using 

reweighted factors 

(based on $10 million 

appropriation)

Estimated

difference

Illinois 4 6,021,097 63 $246,646 $250,310 $3,664

Indiana 4 741,468 45 206,304 91,485 -114,819

Michigan 4 4,842,023 3,224 285,214 402,148 116,934

Minnesota 4 236,946 189 204,639 84,932 -119,707

New Yorka4 16,088,089 2,625 361,565 702,739 341,174

Ohio 4 2,767,328 312 225,694 167,821 -57,873

Pennsylvania 4 2,946,892 140 224,471 163,007 -61,464

Wisconsin 4 1,992,393 820 $227,448 $174,729 -$52,719

Sources: EPA and GAO. 

a

Includes Atlantic and Great Lake coasts. 

Because of the current formula allocations, some states and localities have

expressed concerns that their BEACH Act grants are insufficient to 

adequately monitor their beaches. For example, state officials in Michigan

and Wisconsin reported that, due to limited financial resources and the 

large number of beaches in their states, they are unable to test all of their

beaches, or to test them more than once per week. Similarly, local officials 

 11We conducted a simulation to allocate funding based on the ratios obtained when the $30

million authorizations was anticipated. We constructed the formula to maintain the 27

percent weight for beach season while allocating a $10 million appropriation amount. This 

simulation demonstrates how altering the formula would shift funding, affecting current 

allocations for the Great Lakes states. 

12GAO conducted a simulation for all 35 coastal states and territories to determine how

their grants funding levels would change if EPA reweighted the formula given the current

appropriation levels of approximately $10 million. See appendix III for a description of this 

simulation and results for all states. 

Page 20 GAO-07-591 Great Lakes Beaches
at 44 percent of the beaches we surveyed reported that their BEACH Act 

grants were either inadequate or very inadequate for the purpose of 

monitoring their beaches; while 31 percent reported that their BEACH Act 

grants were adequate or very adequate.13 One state official indicated that if 

their state’s funding level decreases, several of their localities would prefer 

to end their beach monitoring programs. 

EPA recognizes that there are limitations to the factors in its grant 

distribution formula and that, as a result of current funding allocations, the 

factors are no longer relatively equally weighted. Beginning in February 

2006, EPA convened six workshop meetings to evaluate potential changes 

to the formula, with 25 of the 35 eligible states participating. The work 

group considered several modifications to the formula including: (1) 

reducing the fixed factor based on beach season length from a base of 

$150,000 to $100,000, so that other factors have more weight; (2) replacing 

shoreline miles data with actual beach length data now available from the 

BEACON database; and (3) replacing coastal county population with data 

from a NOAA marine survey of the number of participants in beach 

recreation activities. EPA notes that the work group has also discussed 

including a factor related to the number of water samples collected. At the 

time of this report’s release, EPA had not changed the funding formula. 

All eight Great Lakes states have used BEACH Act grants to develop beach 

monitoring and public notification programs. However, the frequency with 

which they monitor their beaches, the methods to monitor beaches, and 

the processes for notifying the public of health advisories and beach

closures vary within and across states. These variations may lead to 

inconsistent levels of public health protection across beaches in the Great 

Lakes. 

Great Lakes States’ 

Beach Monitoring and 

Public Notification 

Programs Vary Across 

Localities and May 

Not Provide 

Consistent Levels of 

Public Health 

Protection 

 13Based on our survey, an estimated 41 percent believe that their grants were inadequate, 

and an estimated 3 percent believe that these grants are very inadequate. Further, about 30 

percent believe that their grants were adequate, and 1 percent believe that these grants are

very adequate. 

Page 21 GAO-07-591 Great Lakes Beaches
Great Lakes States Used 

BEACH Act Grants to 

Develop Beach Monitoring 

and Public Notification 

Programs 

All eight Great Lakes states have used BEACH Act grants to develop beach 

monitoring and public notification programs. Three of the eight Great 

Lakes states—Indiana, Minnesota, and Wisconsin—did not have water 

quality monitoring programs prior to the BEACH Act and used their 

BEACH Act grants to implement such programs. The remaining five states 

expanded their existing beach monitoring programs. In most cases, EPA 

gives the BEACH Act grants directly to state environmental protection 

agencies, which administer the grants, compile and submit water quality 

monitoring and public notification data to EPA, and prepare grant 

applications and annual reports.14 The states usually distribute the funds 

they receive to localities who implement or develop monitoring and 

notification programs. The localities, through local health departments or 

other public health agencies, usually collect water samples at local 

beaches and post results. EPA notes that localities have traditionally 

played the lead role in implementing these programs because they are 

often more familiar with local problems and may be better suited to 

address them. 

To be eligible for BEACH Act grants, EPA requires states, tribes, or local 

governments to develop, among other things: (1) a list of beaches 

evaluated and ranked according to risk; (2) methods for monitoring water 

quality at their beaches, such as when and where to conduct sampling, and 

(3) plans for notifying the public of the risk from pathogen contamination. 

Develop a list of beaches. EPA required states and territories that received 

BEACH Act grants to develop and submit to EPA lists of their beaches that 

identified whether there was a monitoring program in place for each 

beach. EPA’s BEACH Act grant performance criteria also required states 

and local government to rank their beaches based on beach use and risk to 

human health from pathogens. In developing their beach classification and 

prioritization schemes, the Great Lakes states considered beach use and 

accessibility, historical contamination problems, and proximity to known 

sources of contamination. Table 3 shows the number of Great Lakes 

beaches and the percentage being monitored, as reported by officials from 

the Great Lakes states for the 2006 beach season. 

 14The only exception is Pennsylvania, where all of the state’s beaches are in Erie County. As

such, in 2006, Pennsylvania became the only state in the country with a county-run 

program, and Erie County is the only locality that receives grants directly from EPA. 

Page 22 GAO-07-591 Great Lakes Beaches
Table 3: Number of Great Lakes Beaches Identified, Number and Percentage of

Beaches Being Monitored for the 2006 Beach Season

State 

Number of Great Lakes 

beaches identified

Number of beaches 

monitored

Percentage of

beaches monitored

Illinois 69 54 78%

Indiana 30 25 83

Michigan 905 212 23

Minnesota 79 39 49

New Yorka38 38 100

Ohio 54 54 100

Pennsylvania 12 12 100

Wisconsin 192 123 64

Total 1,379 557 40%

Source: GAO analysis of information provided by state BEACH Act officials. 

a

New York has shoreline miles both along the Atlantic Ocean and along Lake Erie and Lake Ontario. 

There are 348 beaches in the state of New York, and all are monitored. 

Develop methods for monitoring water quality. EPA also recommended 

that states and localities develop a three-tiered plan that prioritizes 

beaches for monitoring. EPA intended the beach prioritization scheme to 

allow beach managers to devote more resources and intensive monitoring 

and notification efforts to those high-use and/or high-risk beaches. A tier 1 

classification indicates that the beach is a high-use and/or high-risk beach 

and, therefore, is a high priority for monitoring. A tier 2 beach is a 

medium-use and/or medium-risk beach and is a lower priority for 

monitoring. A tier 3 beach is a low-use and/or low-risk beach and is a low 

priority for monitoring. All eight Great Lakes states prioritized their 

beaches for monitoring according to EPA’s suggested factors of beach use 

and risk to human health. Great Lakes beaches have varying numbers of 

high, medium, and low-priority beaches, as shown in table 4. 

Page 23 GAO-07-591 Great Lakes Beaches
Table 4: Great Lakes Prioritized Beaches Reported by States for Monitoring Using

BEACH Act Grant Funds as of October 2006 

Number of beaches by priority 

State High Medium Low

Beaches prioritized

for monitoring 

Illinoisa49 5 15b54

Indiana 7 10 6 23

Michigan 207 Variesc334 207

Minnesota 9 30 0 39

New York 20 13 5 38

Ohio 41 0 11 52

Pennsylvania 11 1 0 12

Wisconsin 34 39 50 123

Source: GAO analysis of information provided by state BEACH Act officials. 

a

Does not include Chicago beaches because Chicago did not originally apply for BEACH Act grants.

b

llinois does not monitor its 15 tier 3 beaches. 

c

Michigan reported that the number of tier 2 (medium) priority beaches varies. Michigan does not 

monitor its 334 tier 3 beaches. 

Develop public notification plans. EPA’s grant performance criteria 

require states and localities that find their beach water contamination 

exceeds EPA’s criteria to notify the public or resample the water. EPA’s 

guidelines allow states to monitor for two pathogen indicators in 

freshwater––E. coli and enterococci––using two water quality testing 

options––a single sample or a geometric mean (“geomean”) based on no 

fewer than five samples equally spaced over a 30-day period. Health 

departments may also use observations of the presence of visible 

debris/contaminants, as well as predicted high levels of rainfall or sewage 

releases.15 If there is a water quality exceedance, states or localities may 

resample if there is reason to doubt the accuracy or certainty of the 

sample results. If the second sample indicates that a water quality 

standard has been exceeded, states and localities must provide prompt 

public notification. State or local health officials decide whether or not to 

issue a health advisory or close a beach. EPA’s performance criteria allow 

states and localities to develop signs or “functionally equivalent” 

 15In the case of predicted high levels of rainfall or sewage releases, local officials 

responding to our survey reported that about 13 percent of Great Lakes beaches issue 

preemptive closures. 

Page 24 GAO-07-591 Great Lakes Beaches
communication measures, which may include press releases, signs posted 

at the beach, or Internet sites, among other things. All of the Great Lakes 

states have developed public notification plans and may post beach 

advisory and/or closure decisions on signs on the beach, or on the 

Internet, among other methods. 

Variation in Beach 

Monitoring and Public 

Notification Methods May 

Lead to Inconsistent 

Protection of Public Health 

While the Great Lakes states and localities have generally adhered to 

EPA’s criteria for receiving BEACH Act grants, their beach monitoring and 

public notification programs vary considerably. EPA grant criteria and the 

BEACH Act give states and localities some flexibility as to: (1) the 

frequency of monitoring; (2) which beaches are selected for monitoring, 

methods of monitoring; and (3) processes for notifying the public when 

pathogen indicator levels exceed state standards, including the decision to

close beaches or issue a public health advisory. Nevertheless, we 

identified significant variability in the Great Lakes states beach monitoring 

and public notification programs, including the frequency at which they 

monitor high-priority beaches, the depths at which they take water 

samples, and the processes they use for notifying the public of health risks 

from pathogen criteria. 

Frequency of monitoring. Some Great Lakes states are monitoring their 

high-priority beaches almost daily, while other states monitor their highpriority beaches as little as one to two times per week. The frequency with 

which the Great Lakes states monitor their beaches varies, due in part to 

the availability of funding. For example, state officials in Michigan and 

Wisconsin reported a lack of funding for monitoring. While EPA officials 

reported that daily beach monitoring is recommended for high-priority 

beaches, EPA acknowledges that frequency and location of monitoring 

may be limited by funding and staffing levels. Table 5 shows the variation

in monitoring at Great Lakes beaches. 

Page 25 GAO-07-591 Great Lakes Beaches
Table 5: Monitoring Frequency of Great Lake Beaches by Priority 

State High-priority Medium-priority Low-priority

Illinois 5-7 days per week 1 day per week Not monitored 

Indiana 5 days per week 5 days per week 5 days per week 

Michigan 1-2 days per week 1 day per year Not monitored 

Minnesota 2 days per week 1 day per week Not monitored 

New York 1-2 days per week Once every 2 weeks 1 day per month 

Ohio 4 days per week Not applicablea1 day per week 

Pennsylvania 2 days per week 1 day per week Not applicableb

Wisconsin 4-7 days per week 2 days per week 1 day per week 

Source: GAO analysis of information provided by state BEACH Act officials. 

a

Ohio reported that the state does not currently classify any beaches as tier 2. 

b

Pennsylvania reported that the state does not currently classify any beaches as tier 3. 

Because of the variation in the number of days beaches are tested, more 

information is known about some beaches than others, and it is difficult to 

compare data across beaches. For example, local officials at one highpriority beach in our sample reported that their beach was monitored on 

10 days out of the 90-day beach season. On 1 of these 10 testing days––or 

10 percent, the samples exceeded the applicable water quality standards, 

causing the beach to be closed. In contrast, local officials at another highpriority beach in our sample reported that their beach was monitored on 

92 days of its 95 day beach season. On 22 of these 92 testing days––or 24

percent, the samples exceeded the applicable water quality standards, 

causing the beach to be closed. At first glance, the first beach would 

appear to have better water quality than the second beach. However, 

because the first beach was tested on only 10 days, conclusions cannot be 

reliably drawn about the water quality for the remaining 80 days of the 

beach season. One state official commented that human health could be

better protected if the managers were taking more samples. 

Without daily testing at all beaches, conclusions also cannot be drawn 

about the number of safe days at beaches. However, EPA appears to do 

just that in its annual performance report, which concluded that beaches 

were “open and safe for swimming” on 97 percent of the days of the 2005

season nationwide, exceeding EPA’s 94 percent benchmark goal for fiscal

year 2006. This percentage assumes that any day that a beach was open it 

Page 26 GAO-07-591 Great Lakes Beaches
was safe for swimming, even if it was not tested.16 Additionally, according 

to EPA data, in 2005, 3,245 of the possible 58,710 beach days in the Great 

Lakes, or 5.5 percent, were under an advisory or closure and unsafe for 

recreational use.17 Based on EPA’s methodology, the beaches were open 

and safe for swimming on the other 94.5 percent of the days during the 

season. However, this conclusion cannot be drawn because nothing is 

known about the quality of the water on days that water is not tested. 

According to EPA officials, the balance of the other 94.5 percent of the

days for which no advisory or closure action was in effect—days on which 

the beaches are open—is subject to the limitations and uncertainties of 

current monitoring practices, including relatively infrequent monitoring 

for the most part, and testing methods that require 18-36 hours to obtain 

results. EPA officials indicated that the benefits of water quality 

monitoring generally outweigh these limitations and uncertainties. 

Methods of sampling. Most of the Great Lakes states and localities use 

similar sampling methods to monitor water quality at local beaches. For 

example, officials at 79 percent of the beaches we surveyed reported that 

they collected water samples during the morning, and 78 percent reported 

that they always collected water samples from the same location. 

Collecting data at the same time of day and from the same site ensures 

more consistent water quality data. However, we found significant 

variations in the depth at which local officials in the Great Lakes states 

were taking water samples. According to EPA, depth is a key determinant 

of microbial indicator levels.18 EPA’s guidance recommends that beach 

officials sample at the same depth—knee depth, or approximately 3-feet 

deep—for all beaches to ensure consistency and comparability among 

samples. Great Lakes states, however, varied considerably in the depths at 

which they sampled water, with some sampling occurring at 1-6 inches 

and other sampling at 37-48 inches. Figure 4 shows the variation in the 

depths at which Great Lakes state officials took water quality samples. 

 16If a sample exceeds a standard, a locality will typically resample until the test is normal. 

17EPA calculates the total number of beach days by estimating a beach season (number of

days the beach is open) for each beach and summing this across all beaches in the Great

Lakes. 

18EPA’s Environmental Monitoring for Public Access and Community Tracking 

(EMPACT) project examined five beach environments to determine if beach-specific 

characteristics impact beach monitoring results and found that the depth of water sample

collection influences bacterial densities. 

Page 27 GAO-07-591 Great Lakes Beaches
Figure 4: Reported Depth of Water Quality Sampling at Great Lakes Beaches

Source: Responses to GAO’s survey of monitored beaches in the Great Lakes.

37-48 inches

7-12 inches

25-36 inches

3%

Don’t know

1%

1-6 inches

Other

13-24 inches

17%

9%

21%

14%

36%

Note: Percentages may not sum to 100 percent due to rounding. 

Public notification. Local officials in the Great Lakes differ in the 

information they use to decide whether to issue a health advisory or close 

beaches when water contamination exceeds EPA criteria and in how to 

notify the public of their decision. The EPA criteria for single-sample tests 

or a 5-day geometric mean for E. coli indicate that single-sample test 

results cannot exceed 235 bacteria colonies per 100/ml sample, and 

geomean results cannot exceed 126 bacteria colonies per 100/ml sample.19

However, even with these designated testing thresholds, the decisions on 

whether or not to issue a public health advisory or close a beach can vary

within and across the Great Lakes states. This happens because states 

have established different standards for triggering an advisory or closure,

and states vary in whether they will issue advisories or closures or both. 

 19EPA’s 1986 Ambient Water Quality Criteria for Bacteria. Michigan, New York, and 

Wisconsin also continue to test for fecal coliforms in addition to E. coli. 

Page 28 GAO-07-591 Great Lakes Beaches
For example, Minnesota and Ohio only issue health advisories; Indiana, 

Michigan, and Wisconsin issue both health advisories and beach closures; 

and Illinois, New York, and Pennsylvania only issue beach closures. In 

addition, while most states will issue an advisory or close a beach 

following the first water quality standard exceedance, in some cases, 

officials will resample and not close the beach until the standard is 

exceeded on 2 consecutive days. Table 6 shows the variation in states’ 

pathogen indicator thresholds and responses to water quality 

exceedances. 

Table 6: Variation in Great Lakes States’ Pathogen Indicator (E. coli) Thresholds and Responses to Water Quality 

Exceedances

State Issue advisory Advisory thresholda

Issue closure Closure threshold 

Illinois NobNot applicable Yes 235 single sample 

Indiana Yes 235 single sample or 126 geomean Yes 235 single sample or 126 geomean 

Michigan Yes 300 single sample or 130 geomean Yes 300 single sample or 130 geomean 

Minnesota Yes 235 single sample or 126 geomeancNo Not applicable

New York No Not applicable Yesd235 single sample or 126 geomean 

Ohio Yes 235 single sample No Not applicable

Pennsylvania No Not applicable Yes 235 single sample or 126 geomean 

Wisconsin Yes 235 single sample or 126 geomean Yes 1,000 single sample 

Source: GAO analysis of information provided by state BEACH Act officials. 

a

Colonies per 100/mL. 

b

The Chicago Park District issues advisories following a 235 single sample and issues closures

following a 1,000 single sample. 

c

EPA approved Michigan’s threshold in 1993 determining that there was no statistical difference 

between 235 and 300 based on the estimated number of gastrointestinal illnesses per 1,000 

swimmers. 

d

New York state officials indicated that a 235 single sample or 126 geomean would generally prompt 

a beach closure, however the state sanitary code provides local health departments some flexibility to 

conduct site specific assessments to determine if a beach closure is appropriate. 

In addition to using information from water quality samples, officials in at 

least four Great Lakes states—Indiana, Illinois, Ohio, and Wisconsin—are 

using predictive models that use real-time data such as rainfall and water 

temperature to predict water quality conditions and to help make more 

timely decisions about beach closings and advisories. Officials in Lake 

County, Illinois, have used BEACH Act grants in the development of 

SwimCast, a predictive model that has proven to be 89-95 percent accurate

when comparing measured results versus predicted conditions. In Indiana, 

officials have used BEACH Act grants and worked with officials from 

Page 29 GAO-07-591 Great Lakes Beaches
USGS to develop Project SAFE (Swimming Advisory Forecast Estimate), 

which uses real-time information on weather and water data collected at 

several locations to predict E. coli count probability. EPA guidance states 

that predictive models can effectively supplement but not replace beach

monitoring programs to provide conservative estimates during the lag time 

between sampling and water quality test results. 

Also, states’ and localities’ means of notifying the public of health 

advisories or beaches closures vary across the Great Lakes. Some states 

post water quality monitoring results on signs at beaches; some provide 

results on the Internet or on telephone hotlines; some distribute the 

information to local media. When asked to rank the most effective method

of notifying the public of a water quality exceedance, six state BEACH Act 

Administrators indicated that posting signs at the beach is the single most 

effective method; however, states also vary in the form and content of 

their beach signage. Of the beach signs that we reviewed, the appearance 

and wording varied considerably and, although it was recommended in 

EPA’s performance criteria, not all included the effective date(s) of the 

health advisory or beach closure or the date the water quality sampling 

was conducted, as shown in figure 5.

Figure 5: Variation in Public Notification Signs at Great Lakes Beaches 

Sources: (left to right) Minnesota Pollution Control Agency, Wisconsin Department of Natural Resources, and GAO.

Page 30 GAO-07-591 Great Lakes Beaches
Since the passage of the BEACH Act, increased monitoring has improved 

the overall understanding of the scope of contamination in the Great Lakes 

and helped local officials determine which of their beaches are more likely 

to be contaminated. However, the underlying causes of contamination are 

largely unknown and remain unaddressed. Although a few localities have 

been able to use the results of monitoring to identify and take steps to 

address sources of bacterial contamination, most do not know the sources 

of the contamination and, consequently, have not taken actions to address 

them. State and local officials generally stated that they did not have the 

funds available to investigate and address specific sources of 

contamination. 

Because the frequency of monitoring has increased at Great Lakes beaches 

since the passage of the BEACH Act, states and localities have a better 

understanding of the overall scope of contamination. BEACH Act officials 

from six of the eight states—Illinois, Michigan, Minnesota, New York, 

Ohio, and Wisconsin—reported that the number of beaches being 

monitored in their state has increased since the passage of the BEACH Act 

in 2000. For example, in Minnesota, state officials reported that only one 

beach was being monitored prior to the BEACH Act, and there are now 39 

beaches being monitored in three counties. In addition, EPA data shows 

that, in 1999, the number of identified beaches in the Great Lakes was 

about 330, with about 250 of those being monitored. In 2005, the most 

recent year for which data are available, the Great Lakes states identified 

almost 900 beaches and were monitoring about 550, as shown in figure 6.20

The BEACH Act Has 

Helped Identify the 

Scope of 

Contamination, but 

Underlying Causes 

Remain Unaddressed 

Increased Monitoring Has 

Helped States Identify the 

Scope of Contamination 

 20EPA officials have had difficulty tracking the total number of monitored and unmonitored 

beaches because states have changed their beach inventories over the years. In addition, 

double counting of beaches has occurred in the past as historical data were not always

vetted by the state officials, and because local counties with dual jurisdictions may have

double counted beach data. 

Page 31 GAO-07-591 Great Lakes Beaches
Figure 6: Number of Identified Beaches and Number of Identified Beaches 

Monitored in the Great Lakes from 1999 to 2005 

Number of beaches

0

100

200

300

400

500

600

700

800

900

1,000

Monitored beaches

Identified beaches

1999 2000 2001 2002 2003 2004 2005

Source: EPA.

Year

Note: From 1998-2002, EPA collected information on beach monitoring from states through a series

of voluntary surveys; participation rates in these surveys varied from year to year. States receiving 

BEACH Act grants are now required to submit information on the number of beaches in their state, 

number of monitored beaches, and other related information to EPA. 

In addition to an increase in the number of beaches being monitored, the 

frequency of monitoring at many of the beaches in the Great Lakes has 

increased. For example, state BEACH Act officials in Pennsylvania and 

Indiana reported that, although the number of beaches being monitored in 

their states had not increased, the frequency with which the beaches were

monitored did. Indiana officials noted that, prior to the BEACH Act, 

monitoring was done a few times per week; now monitoring is done 5-7 

days per week. In addition, based on our survey, an estimated 45 percent 

of Great Lakes beaches increased the frequency of their monitoring since

the passage of the BEACH Act, as shown in figure 7. For example, local 

officials in one Ohio county reported testing some beaches along Lake 

Erie twice a month prior to the BEACH Act; they are now tested once a 

week. 

Page 32 GAO-07-591 Great Lakes Beaches
Figure 7: Estimated Changes in Frequency of Monitoring at Great Lakes Beaches

Since Passage of the BEACH Act 

Source: Responses to GAO’s survey of monitored beaches in the Great Lakes.

Greatly increased

Increased

3%

Decreased

1%

Greatly dreceased

Not applicable/no basis to judge

Neither increased nor decreased

20%

12%

25%

39%

The increased scope and frequency of monitoring, in response to the 

BEACH Act, is helping to identify the overall scope of contamination in the 

Great Lakes. While the number of beaches being monitored in the Great 

Lakes has increased, the percentage of beaches reporting at least one 

health advisory or closure remained around 40 percent from 1999 to 2005. 

Figure 8 shows the number of monitored beaches with at least one 

advisory or closure from 1999 to 2005. 

Page 33 GAO-07-591 Great Lakes Beaches
Figure 8: Number of Great Lakes Identified Beaches Monitored and Monitored

Beaches with at Least One Closure or Advisory from 1999 to 2005 

Number of beaches

0

100

200

300

400

500

600

Monitored beaches with advisory or closure 

Identified beaches monitored

1999 2000 2001 2002 2005 2003 2004

Source: GAO analysis of EPA data.

Year

Note: From 1998-2002, EPA collected information on beach monitoring from states through a series

of voluntary surveys; participation rates in these surveys varied from year to year. States receiving 

BEACH Act grants are now required to submit information on the number of beaches in their state, 

number of monitored beaches, and other related information to EPA. 

Because of the information available from BEACH Act monitoring 

activities, state and local beach officials are now better able to determine 

which of their beaches are more likely to be contaminated, which are 

relatively clean, and which may require additional monitoring resources to 

help them better understand the levels of contamination that may be 

present. For example, state BEACH Act officials reported that they now 

know which beaches are regularly contaminated or are being regularly 

tested for elevated levels of contamination. Officials at 54 percent of Great 

Lakes beaches we surveyed believe that their ability to make advisory and 

closure decisions has increased or greatly increased since the BEACH Act 

initiated water quality monitoring, as shown in figure 9. 

Page 34 GAO-07-591 Great Lakes Beaches
Figure 9: Estimated Change in Ability to Make Decisions Based on Water Quality 

Data Since Passage of the BEACH Act 

Source: Responses to GAO’s survey of monitored beaches in the Great Lakes.

Greatly increased

Increased

1%

Decreased

Not applicable/no basis to judge

Neither increased nor decreased

17%

15%

31%

37%

Note: Percentages may not add to 100 percent due to rounding. 

Most of the Underlying 

Causes of Contamination 

Remain Unknown and 

Unaddressed 

While some localities have been able to identify and address local sources

of contamination, the specific sources of contamination at most Great 

Lakes beaches are not known. States and localities report that, because

they lack funding to investigate and mitigate sources of contamination, the 

underlying causes of contamination at most beaches have not been 

identified or addressed. Based on our survey, local officials at 67 percent 

of Great Lakes’ beaches did not know the sources of bacterial 

contamination causing their exceedances of water quality standards 

during the 2006 beach season. 

Nonetheless, five of the eight Great Lakes state BEACH Act officials 

reported that the increased monitoring has helped some local officials in 

their state identify the sources of contamination. These officials identified

the following examples of localities where contamination sources have 

been identified and, in some cases, local actions have been taken to 

address them: 

Page 35 GAO-07-591 Great Lakes Beaches
• Illinois—Beach monitoring led officials at one beach in Chicago to 

identify a sewer break, prompting the city to fix the leaking sewer and 

remove 6 million cubic yards of sand. 

• Michigan—In Traverse City, local officials have used monitoring data to 

identify problems at their wastewater treatment plants which resulted in

plant improvements. 

• Ohio—The Lucas County Health Department has identified private sewage 

systems that are contaminating local beaches. 

• Minnesota—With the establishment of the state’s beach program 

following the BEACH Act, state and local officials in Minnesota formed a 

beach committee that includes representation from the state pollution 

control agency, local and state health departments, local sewage districts 

and utilities, University of Minnesota researchers, and other groups. The 

beach committee has coordinated efforts to identify the sources and 

causes of beach contamination. For example, where beach monitoring 

data has indicated problems at normally clean beaches, the sanitary 

district has investigated these situations and found and repaired broken 

pipes. 

• Wisconsin—Officials in Racine began looking into high numbers of beach 

closures and advisories at one of their beaches in 1999. Using the results of 

water quality monitoring, these officials were able to identify a storm 

water outfall adjacent to the beach that was contributing to the 

contamination and developed an underground treatment system and 

wetland area to filter the discharge. In addition, city officials determined 

that beach grooming procedures and the overall geography of the beach 

were also contributing to the contamination, and they improved their 

beach grooming techniques and regraded the beach to reduce standing 

water. With these corrective actions, the city was able to reduce the 

number of beach health advisory and closure days from 62 in 2000 to 3 in

2006. Figure 10 illustrates the changes to the city’s beach grooming 

processes. 

Page 36 GAO-07-591 Great Lakes Beaches
Figure 10: Changes to Beach Grooming Process at a Racine, Wisconsin, Beach

After: Current grooming practices remove debris from beach sands

while reducing bacterial density.

Before: Past grooming practices leveled and compacted beach sands,

which increased bacterial density. 

Source: Dr. Julie Kinzelman, City of Racine Health Department Laboratory.

In addition to these efforts to identify and address local sources of 

contamination, local officials report an overall increase in awareness of 

how personal actions can impact water quality at beaches, as shown in 

figure 11. For example, not adhering to proper beach practices––such as 

using swim diapers for young children––or not properly disposing of trash 

can lead to increased problems with wildlife such as seagulls and geese. In

addition to actions that the public can take to mitigate contamination, 

there are also actions beach managers can take, such as ensuring the 

availability of sufficient trash cans and functioning restrooms, that can 

also help mitigate beach contamination. Local officials report that they 

have taken some of these actions on a limited basis. 

Page 37 GAO-07-591 Great Lakes Beaches
Figure 11: Estimated Change in Public Awareness of Personal Actions on Water 

Quality at Great Lakes Beaches Since Passage of the BEACH Act 

Source: Responses to GAO’s survey of monitored beaches in the Great Lakes.

Greatly increased

Increased

Not applicable/no basis to judge

Neither increased nor decreased

18%

15%

25%

42%

Nevertheless, EPA officials stated that the primary source of 

contamination at beaches generally is reported by state officials as 

“unknown.” Comprehensive sanitary surveys can help local water program 

managers identify persistent problems; ascertain the sources and 

magnitude of contamination; suggest appropriate actions to control 

contamination and identify priority locations for sampling.21 Although local

officials at Great Lakes beaches reported conducting field observations to 

determine the sources of contamination at 88 percent of the beaches, 

comprehensive sanitary surveys have been conducted at only 48 percent

of the beaches. 

One reason why sanitary surveys have not been more widespread is lack

of funding, but EPA has concluded that BEACH Act grant funds can only 

 21Sanitary surveys are used to identify sources of pollution and provide information on

source controls and identification, persistent problems, and management actions. EPA’s

National Beach Guidance and Required Performance Criteria for Grants states that a 

sanitary survey can be an effective tool for protecting human health at bathing beaches and 

providing information that helps in designing monitoring programs. 

Page 38 GAO-07-591 Great Lakes Beaches
be used for this purpose under certain circumstances.22 In particular, 

sanitary surveys can be done during the development of a monitoring 

program when states are prioritizing their beaches for monitoring or when 

there is a need to reprioritize the beaches. EPA has initiated a pilot 

sanitary survey effort throughout the Great Lakes, working with state and 

county Great Lakes beach managers to design and implement a beach 

sanitary survey project for Great Lakes recreational waters. EPA posted a 

Request for Proposal in August 2006 indicating that $500,000 would be 

available to fund pilot surveys at Great Lakes beaches. Nine state or 

county agencies submitted proposals for conducting sanitary surveys at 

numerous beaches. EPA expects that this work will result in the 

development of a tool for watershed-based sanitary surveys that could be

used by others. EPA made award decisions in December 2006 and 

anticipates grant awards in April 2007. 

Because state and local officials do not have enough information on the 

specific sources of contamination and generally lack funds for 

remediation, most of the sources of contamination at Great Lakes’ beaches 

have not been addressed. Local officials indicated that actions to address 

the sources of contamination had only been taken at an estimated 14

percent of the monitored beaches. While none of the eight Great Lakes 

state officials suggested that the BEACH Act was intended to help 

remediate the sources of contamination, some said that they lack the 

funds needed to mitigate the sources of contamination that increased 

monitoring has helped to identify. However, our review of the BEACH Act 

and EPA’s criteria found that they both specify that BEACH Act grant 

funds should be used only for monitoring and notification purposes. 

Several state officials believe that it may be more useful to use BEACH Act 

grants to identify and remediate sources of contamination rather than just

continue to monitor water quality. Local officials also reported a need for 

funding to identify and address sources of contamination. Furthermore, at 

EPA’s National Beaches Conference in October 2006, a panel of federal 

and academic researches recommended that EPA provide the states with 

more freedom on how they may spend their BEACH Act funding. 

 22The BEACH Act provides that EPA may award grants to states and localities for 

“monitoring and notification” programs. 33 U.S.C. § 1346(b)(2)(A). According to EPA 

officials, the term “monitoring” encompasses limited investigations to determine sources of

contamination but does not include remediation to address the source of the 

contamination. 

Page 39 GAO-07-591 Great Lakes Beaches
According to state and local officials, as well as other Great Lakes 

stakeholders, an overall improvement in water quality throughout the 

Great Lakes will require a substantial effort directed toward both largescale initiatives and localized actions to address the underlying causes of 

contamination. State officials reported that combined sewer overflows and 

sewage disposal problems throughout the Great Lakes must be addressed. 

Although some communities have taken steps in this direction, others 

continue to discharge partially treated wastewater into the Great Lakes as 

part of their wastewater treatment processes. In addition, more localized

action is also needed to address some sources of contamination at Great 

Lakes beaches. Examples include regrading the beaches to reduce 

standing water and minimizing the use of impervious surface materials to 

construct parking lots adjacent to beaches to reduce storm water runoff. 

EPA has made progress in implementing many of the BEACH Act’s 

requirements but two critical actions, relating to the completion of 

pathogen studies and developing new water quality criteria, have not been

completed as required by the act and may not be completed for several 

more years. Without the completion of these studies and the development 

of new water quality criteria, states will have to continue to use existing 

methods that are already outdated for monitoring water quality at their 

beaches. The use of these methods limits states’ ability to obtain water 

quality test results and make beach closing decisions in a timely manner to

ensure that public health is adequately protected. However, EPA has not 

established a firm time line to guide the completion of the studies and the 

development of the new criteria, so it is unclear when states can expect to

receive updated methods to guide their monitoring efforts. 

Conclusions 

In addition, although EPA developed a formula to distribute BEACH Act 

grants to the states, this formula was based on the assumption that the 

program would receive its fully authorized allocation of $30 million. 

During the last 5 years, the program has not received full funding, and EPA 

has not adjusted the formula to reflect the impacts of reduced levels of 

funding. As a result, the current distribution formula fails to adequately 

take into account the monitoring needs of the states. Instead, it places the 

greatest emphasis on the length of the beach season and not enough 

emphasis on other factors, such as beach use and beach miles, that vary

greatly across states, and which also impact the public health risk and 

significantly influence the level of monitoring that states need to 

undertake. While we recognize that any changes to the distribution 

formula would inevitably result in some states receiving more funds and

Page 40 GAO-07-591 Great Lakes Beaches
some less, unless the program is fully funded as authorized, the current 

distribution formula does not reflect the states’ varied monitoring needs.

Finally, the BEACH Act has had a significant impact in helping the Great

Lakes states increase their level of monitoring, which in turn has increased

their knowledge about the scope of contamination at area beaches. 

However, the variability in how the states are conducting their monitoring

and how they are using their monitoring results to notify the public have 

raised concerns about the adequacy of protection provided among and 

across Great Lakes states. In addition, because it appears that BEACH Act 

funds cannot currently be used to investigate the source of contamination 

or remediate an identified problem, states have been unable to address the 

contamination that they now know exists. While we recognize that funding

for BEACH Act grants has been limited over the last 5 years, we believe 

that additional flexibility for the states to use a portion of their BEACH Act 

grants to help them identify the source of contamination if their 

monitoring has identified a reoccurring problem would be helpful. In this 

regard, we also believe that EPA could provide guidance to ensure that 

states are still conducting the monitoring programs expected by the 

BEACH Act and not diverting all their monitoring funds to investigation 

and mitigation. 

As it considers reauthorization of the BEACH Act, Congress should 

consider providing EPA some flexibility in awarding BEACH Act grants to 

allow states to undertake limited research to identify specific sources of 

contamination at monitored beaches and certain actions to mitigate these 

problems, as specified by EPA. 

To ensure that EPA complies with the requirements laid out in the BEACH 

Act, we recommend that the Administrator of EPA take the following three 

actions: 

Matter for 

Congressional 

Consideration 

Recommendations for 

Executive Action 

• Establish a definitive time line for completing the studies on pathogens 

and their effects on human health, and for publishing new or revised water 

quality criteria for pathogens and pathogen indicators; 

Page 41 GAO-07-591 Great Lakes Beaches
• If current funding levels remain the same, revise the formula for 

distributing BEACH Act grants to better reflect the states’ varied 

monitoring needs by reevaluating the formula factors to determine if the 

weight of the beach season factor should be reduced and if the weight of 

the other factors, such as beach use and beach miles should be increased;

and 

• To better ensure consistent levels of public health protection, EPA should 

provide states and localities with specific guidance on monitoring 

frequency and methods and public notification. 

In commenting on the draft report, EPA generally agreed with GAO’s 

recommendations and agreed to (1) take actions to establish an action

plan and a definitive time frame to complete studies and publish revised 

water quality standards and (2) revise its guidance to states. With respect

to our recommendation to revise the current funding formula to better 

reflect states’ needs, EPA agreed with this recommendation, but stated 

that the states were reluctant to make any substantial changes to the 

formula and were supportive of EPA’s plan to make only minor changes to

the formula. EPA’s comments are included in appendix IV. 

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

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

report date. At that time, we will send copies to the EPA Administrator 

and other interested parties. We will also make copies available to others

upon request. In addition, the report will be available at no charge on the 

GAO Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841 or mittala@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix V. 

Anu K. Mittal 

Director, Natural Resources 

 and Environment

Agency Comments 

and Our Evaluation 

Page 42 GAO-07-591 Great Lakes Beaches
List of Requesters 

The Honorable Evan Bayh 

United States Senate 

The Honorable Richard Durbin 

United States Senate 

The Honorable Russell D. Feingold

United States Senate 

The Honorable Carl Levin 

United States Senate 

The Honorable Richard Lugar 

United States Senate 

The Honorable Barack Obama 

United States Senate 

The Honorable Debbie Stabenow 

United States Senate 

The Honorable George Voinovich 

United States Senate 

The Honorable John Dingell 

House of Representatives 

The Honorable Rahm Emanuel 

House of Representatives 

The Honorable Luis V. Gutierrez 

House of Representatives 

The Honorable Brian M. Higgins 

House of Representatives 

The Honorable Dale Kildee 

House of Representatives 

Page 43 GAO-07-591 Great Lakes Beaches
The Honorable Carolyn C. Kilpatrick 

House of Representatives 

The Honorable Mark Kirk 

House of Representatives 

The Honorable Dennis Kucinich 

House of Representatives 

The Honorable Sander M. Levin 

House of Representatives 

The Honorable Janice Schakowsky 

House of Representatives 

The Honorable Louise Slaughter 

House of Representatives 

The Honorable Bart Stupak 

House of Representatives 

Page 44 GAO-07-591 Great Lakes Beaches
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

The objectives of this review were to (1) determine the extent to which the

Environmental Protection Agency (EPA) has implemented the Beaches 

Environmental Assessment and Coastal Health (BEACH) Act of 2000 and 

evaluate EPA’s formula for allocating BEACH Act grants, (2) describe and 

evaluate the monitoring and notification programs the eight Great Lakes 

states have developed using BEACH Act grants, and (3) determine the 

effect that the BEACH Act has had on water quality monitoring and 

contamination at Great Lakes beaches. 

We identified and analyzed applicable laws, regulations, policies, and 

procedures to determine what actions EPA has taken to implement the act

and what remains to be addressed. Specifically, we reviewed the act to

identify what actions the agency was required to take. To identify the 

actions EPA has taken to implement the act’s requirements and provisions, 

we reviewed notices and regulations published in the Federal Register and

agency documents, and interviewed agency officials at EPA headquarters, 

EPA’s Great Lakes National Program Office, EPA Region 5 (Chicago), EPA 

Region 2 (New York), and EPA’s National Exposure Research Laboratory. 

To assess the criteria EPA uses to allocate BEACH Act funds to eligible 

states, we interviewed officials that were involved in developing the 

funding formula and conducted a funding formula simulation to 

demonstrate how slight alterations of the BEACH Act grant funding 

formula would shift funding and potentially affect current allocations. 

To determine how the eight Great Lakes states have used BEACH Act 

funds to develop monitoring and notification programs, we used a data 

collection instrument to gather information from state level BEACH Act 

Administrators from each of the Great Lakes states—Illinois, Indiana, 

Ohio, Michigan, Minnesota, New York, Wisconsin, and Pennsylvania. We 

interviewed an official from Erie County, Pennsylvania, where BEACH Act

funds are distributed directly to the county because this is the only county 

in the state with coastal recreational waters. EPA identified these officials 

as the person(s) responsible for coordinating beach monitoring and 

notification programs for each state and collecting and submitting 

information generated by these programs to EPA. 

In addition, we conducted a survey of the 563 Great Lakes beaches EPA 

identified as having monitoring programs in 2005. To gather data 

representative of the Great Lakes beaches, we conducted a random 

sample of 140 beaches which were selected systematically for each state. 

This ensured that the sample selected was proportional to the number of 

Great Lakes beaches in each of the states. Table 7 summarizes sample size 

and disposition by state.

Page 45 GAO-07-591 Great Lakes Beaches
Appendix I: Scope and Methodology 

Table 7: Great Lakes Beaches Reported Monitored by EPA in 2005, GAO Sample, 

and Sample Disposition by State

State 

Total beaches

monitored Sample beaches 

Responding

beaches

Response

rate

Illinois 73 19 15 79%

Indiana 25 6 5 83

Michigan 214 53 49 92

Minnesota 39 10 10 100

New York 38 9 9 100

Ohio 47 12 11 92

Pennsylvania 12 3 3 100

Wisconsin 115 28 28 100

Grand total 563 140 130 93%

Source: GAO.

Information obtained through this survey was used to produce estimates 

of beach monitoring and notification in the 2006 beach season at the Great 

Lakes beaches that conducted monitoring in 2005. Since our beach sample

is only one of a large number of samples that we might have drawn, and 

each sample could have provided different estimates, we express our 

confidence in the precision of our particular sample’s results as a 95 

percent confidence interval. This is the interval that would contain the 

actual population value for 95 percent of the samples we could have 

drawn. All proportion estimates from this sample used in this report have 

95 percent confidence intervals within plus or minus 10 percentage points,

unless otherwise noted. 

Even though we surveyed a random sample of beaches in the Great Lakes,

the practical difficulties of conducting any survey may introduce other 

types of errors, commonly referred to as “nonsampling errors.” For 

example, differences in how a particular question is interpreted or the 

sources of information available to respondents can introduce unwanted 

variability into the survey results. We included steps in both the data 

collection and data analysis stages to minimize these nonsampling errors. 

For example, in the research design and data collection stages, we took 

the following steps: 

• We obtained from EPA a list of contacts for beaches with monitoring 

programs in the Great Lakes. We then attempted to contact all listed local 

officials via telephone and asked them to tell us if they or someone else 

would be the most appropriate contact and to provide their e-mail address. 

Page 46 GAO-07-591 Great Lakes Beaches
Appendix I: Scope and Methodology 

Some officials identified more appropriate survey respondents. In order to 

obtain the appropriate contacts for beaches where we were not able to 

contact the officials using EPA’s list, we asked state BEACH Act officials 

for the most appropriate contact and obtained telephone and/or e-mail 

contacts from them. 

• We reviewed EPA’s National Health Protection Survey of Beaches. 

• We pretested the survey with officials from four beaches between 

November 13, 2006, and November 27, 2006, and used their feedback to

refine the survey. These beaches were selected randomly from the list of 

monitored beaches provided by EPA. For these pretests, we sent officials 

a draft of the survey. We then interviewed the officials to ensure that (1) 

questions were clear and unambiguous, (2) terms were precise, and (3)

data needed to respond to the questions were available to the local 

officials. As a result of our pretests, we refined some of the survey 

questions. A GAO survey specialist also independently reviewed the 

questionnaire. 

• We e-mailed the survey as an attachment on December 5, 2006, to local

officials at 140 beaches. We asked respondents to return the survey by email within 15 working days of receiving our e-mail. We sent e-mail 

reminders and called nonrespondents and accepted responses to the 

surveys through February 2, 2007. 

To minimize nonsampling errors in the data analysis stage, we contacted 

local officials to clarify survey responses, when necessary, and used a 

centralized tracking document to record all changes. Changes made in the 

tracking document were verified against the keypunched data to ensure all 

changes and updates were recorded. When changes took place after a 

survey was keypunched, the updates were made in the computer program 

used to generate survey results. 

As summarized in table 7, we received completed questionnaires for 130 of 

the 140 sample beaches, for an overall response rate of 93 percent. We did

not receive a completed questionnaire from 10 beaches. We do not know if 

the responses for these beaches would have differed materially from those 

for the 130 beaches we did receive. From the questionnaires we received,

we gathered information for each including: (1) the potential sources of 

contamination; (2) water quality standards in place; (3) methods of 

monitoring, including depth and location of samples; (4) frequency of 

monitoring and number of sampling days where water quality standards 

were exceeded; and (5) public notification and remediation efforts. 

Page 47 GAO-07-591 Great Lakes Beaches
Appendix I: Scope and Methodology 

To determine the effect the BEACH Act has had on Great Lakes beach

monitoring and the identification of sources of contamination, we 

analyzed the results of our survey and information obtained from state 

BEACH Act Administrators. In addition, we reviewed EPA data on the 

number of beaches identified in the Great Lakes, the number of identified 

beaches being monitored, and the number of monitored beaches with 

health advisories and beach closures. We interviewed agency officials 

regarding a series of data reliability questions addressing such areas as 

data entry, data access, quality control procedures, and data accuracy and 

completeness. We asked follow-up questions whenever necessary. We 

determined that these data were sufficiently reliable for the purposes of 

this report. 

Finally, we conducted interviews with organizations working on Great 

Lakes issues including the National Oceanic and Atmospheric 

Administration (NOAA), the U.S. Geological Survey, the Natural Resources 

Defense Council, the International Joint Commission, the Alliance for the 

Great Lakes, and the Northeast-Midwest Institute Great Lakes and St. 

Lawrence Cities Initiative, among others. 

We conducted our work from June 2006 through March 2007 in

accordance with generally accepted government auditing standards. 

Page 48 GAO-07-591 Great Lakes Beaches
Appendix II: M

with C

ap of 35 States and Territories

oastal Recreational Waters

Page 49 GAO-07-591 

Appendix II: Map of 35 States and Territories 

with Coastal Recreational Waters 

AL

AZ

AR

CA

CO

CT

DE

DC

FL

GA

ID

IL

IN

IA

KS

KY

LA

ME

MD

MA

MI

MN

MS

MO

MT

NE

NV

NH

NJ

NM

NY

NC

ND

OH

OK

OR

PA

RI

SC

SD

TN

TX

UT

VT

VA

WA

WV

WI

WY

AK HI PR VI

Non-BEACH Act states

BEACH Act states

Sources: Map Resources (map) and EPA Office of Water.

Great Lakes Beaches
Appendix III: GAO

Al

Formula 

’s Calculations for an 

ternative BEACH Act Grant Distribution

Page 50 GAO-07-591 

Appendix III: GAO’s Calculations for an 

Alternative BEACH Act Grant Distribution 

Formula 

This appendix describes EPA’s BEACH Act grant distribution formula and 

the results of our calculation using an alternative formula allocation. 

Currently, EPA’s grant formula allocates about 82 percent of the grant 

funds according to beach season and about 9 percent each to beach use 

and beach miles. Our simulation reweighs the factors used in EPA’s 

formula so that beach season receives a weight of about 27 percent, beach

use receives a weight of about 36 percent, and beach miles receive a 

weight of about 36 percent as EPA originally intended. The resulting 

funding amounts are shown for each of the 35 states and territories. 

Finally, we present information on how EPA can alter its formula to 

minimize fluctuations in funding amounts if funding levels increase. 

EPA distributes BEACH Act grants to eligible states and territories 

according to a formula that considers the length of the beach season, 

beach use, and beach miles. EPA intended that the beach season length 

factor would provide the base funding and would be augmented by the 

beach use and beach miles factors. EPA established a series of fixed 

amounts that correspond to states’ varying lengths of beach season to 

cover the general expenses associated with a beach monitoring program. 

For example, EPA estimated that a 3-month beach season would require 

states to fund salaries for two employees, which would cost approximately 

$150,000, while states with beach seasons greater than 6-months would 

require $300,000. The eight Great Lakes states are all classified as having 3 

to 4 months of beach season, as shown in table 8. 

EPA’s BEACH Act Grant 

Distribution Formula 

Table 8: EPA Beach Season Length Factor and States Associated Funding Levels 

State Beach season Base amount 

Alaska <3 monthsa$150,000 

Connecticut, Delaware, Illinois, Indiana, Maine, Maryland, Massachusetts, Michigan, 

Minnesota, New Hampshire, New Jersey, New York, Ohio, Oregon, Pennsylvania, Rhode

Island, Virginia, Washington, Wisconsin 

3–4 months $200,000 

Alabama, Georgia, Louisiana, Mississippi, North Carolina, South Carolina 5–6 months $250,000 

American Samoa, California, Florida, Guam, Hawaii, Northern Mariana, Puerto Rico, Texas, 

U.S. Virgin Islands 

 >6 months $300,000 

Source: EPA. 

a

States and territories with seasons of less than 3 months receive season-based funding only. 

Once the allotments for beach season length are distributed, EPA 

determined that 50 percent of the remaining funds would be distributed to 

states according to beach use, and the other 50 percent would be 

Great Lakes Beaches
Appendix III: GAO’s Calculations for an 

Alternative BEACH Act Grant Distribution

Formula 

distributed according to states’ beach miles. Because consistent data 

across states on beach usage are not available, EPA uses coastal 

population of counties as a surrogate for beach use. Similarly, EPA 

currently does not have beach mileage data in a format that can be used 

for the allocation formula and, therefore, uses shoreline miles as a 

surrogate for beach miles.1

EPA developed this formula with the expectation that BEACH Act grants 

would be allocated funding at their authorized level of $30 million 

annually. Using this authorized amount and EPA’s distribution formula $30 

million and using this distribution formula, each factor would have 

received approximately equal weight, with beach season accounting for 

about 27 percent of each state or territory’s grant, and the remainder 

equally divided between the two other factors—beach use (36 percent) 

and beach miles (36 percent) as shown in table 9.

Table 9: EPA’s Formula for Distributing $30 Million in BEACH Act Grants 

Factor Allocation

Beach season length 27% of total annual BEACH Act funds, or $8 million, distributed 

as follows: 

< 3 months: $150,000a

3-4 months: $200,000 

5-6 months: $250,000 

>6 months: $300,000 

Shoreline miles 36% of total annual BEACH Act funds, or $11 million 

Coastal population 36% of total annual BEACH Act funds, or $11 million 

Sources: EPA and GAO. 

a

States and territories with seasons of less than 3 months receive season-based funding only. 

However, since 2002, funding levels for BEACH Act grants have been 

about $10 million each year. Given the lower than anticipated funding 

levels, once the approximately $8 million (which now accounts for 82 

percent of the total grant funding) was allocated in accordance with each

state’s beach season, this left only about $1.85 million or about 18 percent 

of the total funding to be divided equally (about $1 million or 9 percent 

 1

The estimate of shoreline miles are taken from NOAA’s The Coastline of the United States. 

Population estimates are taken from the 2000 Census. 

Page 51 GAO-07-591 Great Lakes Beaches
Appendix III: GAO’s Calculations for an 

Alternative BEACH Act Grant Distribution

Formula 

each) between the beach use and beach miles factors, as shown in table 

10. 

Table 10: EPA’s Formula for Distributing $10 Million in BEACH Act Grants 

Factor Allocation

Beach season length < 3 months: $150,000a

3-4 months: $200,000 

5-6 months: $250,000 

>6 months: $300,000 

Shoreline miles 50% of remaining $1.85 million funds, or $.92 million 

Coastal population 50% of remaining $1.85 million funds, or $.92 million 

Sources: EPA and GAO. 

a

States and territories with seasons of less than 3 months receive season-based funding only. 

Because the beach season factor accounts for a much larger proportion of 

each state’s BEACH Act grant as compared with beach miles or beach use, 

BEACH Act grant amounts may vary little between states that have widely 

varied shorelines or coastal populations, as shown in table 11.

Table 11: Factors Used in BEACH Act Formula Allocations and Resulting 2006 Grants by State and Territory 

State 

Beach

season

length 

Minimum 

allocation

Shoreline 

miles

Shoreline 

ratio

Coastal 

population

(2000) 

Population 

ratio

Grant 

allocation in

2006

Alabama 6 $250,000 607 0.0099 540,258 0.0044 $262,170

Alaska 2 150,000 33,904 0.0000 538,258 0.0000 150,000

American Samoa 12 300,000 126 0.0020 57,291 0.0005 302,140 

California 12 300,000 3,427 0.0557 24,260,099 0.1991 516,960

Connecticut 4 200,000 618 0.0100 2,120,734 0.0174 223,370 

Delaware 4 200,000 381 0.0062 783,600 0.0064 210,750

Florida 12 300,000 8,436 0.1371 15,982,378 0.1311 528,410 

Georgia 6 250,000 2,344 0.0381 538,469 0.0044 286,200 

Guam 12 300,000 110 0.0018 154,805 0.0013 302,600 

Hawaii 12 300,000 1,052 0.0171 1,211,537 0.0099 323,020 

Illinois 4 200,000 63 0.0010 6,021,097 0.0494 242,940

Indiana 4 200,000 45 0.0007 741,468 0.0061 205,800 

Louisiana 6 250,000 7,721 0.1255 2,170,717 0.0178 322,010 

Maine 4 200,000 3,478 0.0565 944,847 0.0078 254,730 

Maryland 4 200,000 3,190 0.0518 3,592,430 0.0295 269,250

Page 52 GAO-07-591 Great Lakes Beaches
Appendix III: GAO’s Calculations for an 

Alternative BEACH Act Grant Distribution

Formula 

State 

Beach

season

length 

Minimum 

allocation

Shoreline 

miles

Shoreline 

ratio

Coastal 

population

(2000) 

Population 

ratio

Grant 

allocation in

2006

Massachusetts 4 200,000 1,519 0.0247 4,783,167 0.0392 254,440 

Michigan 4 200,000 3,224 0.0524 4,842,023 0.0397 278,450 

Minnesota 4 200,000 189 0.0031 236,946 0.0019 204,270

Mississippi 6 250,000 359 0.0058 363,988 0.0030 257,510 

New Hampshire 4 200,000 131 0.0021 389,592 0.0032 204,530 

New Jersey 4 200,000 1,792 0.0291 7,575,546 0.0622 277,730 

New York 4 200,000 2,625 0.0427 16,088,089 0.1320 348,740 

North Carolina 6 250,000 3,375 0.0548 826,019 0.0068 302,480 

Northern Mariana 

Islands 12 300,000 206 0.0033 69,221 0.0006 303,330 

Ohio 4 200,000 312 0.0051 2,767,328 0.0227 223,650 

Oregon 4 200,000 1,410 0.0229 1,326,072 0.0109 228,780 

Pennsylvania 4 200,000 140 0.0023 2,946,892 0.0242 222,530 

Puerto Rico 12 300,000 700 0.0114 2,685,883 0.0220 328,450 

Rhode Island 4 200,000 384 0.0062 1,048,319 0.0086 212,640 

South Carolina 6 250,000 2,876 0.0467 981,338 0.0081 296,660 

Texas 12 300,000 3,359 0.0546 5,211,014 0.0428 382,890 

Virgin Islands 12 300,000 175 0.0028 108,612 0.0009 303,180 

Virginia 4 200,000 3,315 0.0539 4,440,709 0.0364 276,900 

Washington 4 200,000 3,026 0.0492 4,070,515 0.0334 270,320 

Wisconsin 4 200,000 820 0.0133 1,992,393 0.0163 225,270 

Total 220 $8,150,000 61,535 1.0000 121,873,396 1.0000 $9,803,100

Sources: EPA and GAO. 

Note: The totals exclude shoreline miles and coastal population for Alaska because Alaska beach 

season is less than 3 months. 

As a result, states and territories with 12-month beach seasons may 

receive larger BEACH Act grants than states with much longer shorelines. 

For example, shoreline miles in the Great Lakes states range from 63 miles 

in Illinois to 3,224 in Michigan; therefore, Michigan may need to monitor 50 

times as many shoreline miles as Illinois. However, because the beach 

miles factor accounts for a much smaller portion of each state’s BEACH 

Act grant than beach season, the BEACH Act grant amount distributed to 

Michigan is only 35 percent more than that for Indiana ($278,450 and 

$205,800, respectively).

Because of the way in which the current formula allocates funding, states

and territories with 12-month beach seasons may also receive larger 

Page 53 GAO-07-591 Great Lakes Beaches
Appendix III: GAO’s Calculations for an 

Alternative BEACH Act Grant Distribution

Formula 

BEACH Act grants than more populous states. For example, in general, 

EPA’s grant distribution formula gives territories an advantage over the

states, because they tend to be in warmer climates with longer beach

seasons. Territories receive an average of $309,000 each year, while states

receive an annual average of $294,000. The Great Lakes states, with their 

comparatively short beach seasons, receive an annual average of $248,000. 

Similarly, states with larger populations are currently at a disadvantage to

the territories that have a longer beach season but significantly smaller 

coastal populations. For example Guam and American Samoa, with 

coastal populations of less than 200,000 each, receive larger grants than 

Maryland and Virginia, with coastal populations of 3.6 and 4.4 million, 

respectively. However, if greater weights were assigned to coastal 

populations, Maryland and Virginia would see an increase in their grant 

allocation. 

Simulations of Alternative 

BEACH Act Distribution 

Formulas 

We calculated the distribution of $10 million in annual BEACH Act grants 

according to an alternative formula that weights each of the factors 

equally (27 percent for beach season, 36 percent for beach use, and 36

percent for beach miles) in accordance with the weights that EPA had 

built into its formula when it anticipated that $30 million would be 

available in annual funding levels. For the purposes of our calculation, we 

reduced the total amount available to be allocated to beach season length

from 82 to 27.2 percent of the current $10 million funding levels. Given this 

simulation, the total amount allocated on the basis of beach season length

falls from $8.15 million to roughly $2.72 million, and the proportion 

allocated to beach use and beach miles increases to $3.65 million (or 36.4 

percent) each. 

Under this alternative formula, Alabama’s total allocation, for example, 

would decrease by 48.6 percent, from $263,225 to $135,399, and its share of 

funding that is based on the length of the beach season would fall from 

$250,000 to $83,333. Table 12 shows how each state and territory’s 

allocations would differ if EPA applied the percentages it built into its 

formula when it anticipated $30 million in funding compared with the 

current $10 million. 

Page 54 GAO-07-591 Great Lakes Beaches
Appendix III: GAO’s Calculations for an 

Alternative BEACH Act Grant Distribution

Formula 

Table 12: Difference in Allocations Using Current and Alternative Formulas 

States and

territories 

BEACH Act 

grant allocation

of $10 million 

Amount based 

on beach

season

27.2% of

amount based 

on beach

season

Estimated 

BEACH Act grant 

under simulated

formula 

Difference 

between actual 

and estimated

allocations (in

dollars)

Difference 

between

actual and 

estimated

allocations

Alabama $263,225 $250,000 $83,333 $135,399 -$127,826 -48.6%

Alaska 150,000 150,000 50,000 50,000 -100,000 -66.7

American Samoa 302,329 300,000 100,000 109,169 -193,160 -63.9

California 535,645 300,000 100,000 1,027,721 492,076 91.9

Connecticut 225,386 200,000 66,667 166,609 -58,777 -26.1

Delaware 211,675 200,000 66,667 112,629 -99,046 -46.8

Florida 548,115 300,000 100,000 1,076,811 528,696 96.5

Georgia 289,322 250,000 83,333 238,142 -51,180 -17.7

Guam 302,828 300,000 100,000 111,136 -191,692 -63.3

Hawaii 325,009 300,000 100,000 198,459 -126,550 -38.9

Illinois 246,646 200,000 66,667 250,310 3,664 1.5

Indiana 206,304 200,000 66,667 91,485 -114,819 -55.7

Louisiana 382,538 250,000 83,333 605,128 222,590 58.2

Maine 259,453 200,000 66,667 300,729 41,276 15.9

Maryland 275,218 200,000 66,667 362,797 87,579 31.8

Massachusetts 259,137 200,000 66,667 299,486 40,349 15.6

Michigan 285,214 200,000 66,667 402,148 116,934 41.0

Minnesota 204,639 200,000 66,667 84,932 -119,707 -58.5

Mississippi 258,159 250,000 83,333 115,455 -142,704 -55.3

New Hampshire 204,926 200,000 66,667 86,061 -118,865 -58.0

New Jersey 284,435 200,000 66,667 399,081 114,646 40.3

New York 361,565 200,000 66,667 702,739 341,174 94.4

North Carolina 307,003 250,000 83,333 307,749 746 0.2

Northern Mariana 

Islands 303,622 300,000 100,000 114,260 -189,362 -62.4

Ohio 225,694 200,000 66,667 167,821 -57,873 -25.6

Oregon 231,260 200,000 66,667 189,735 -41,525 -18.0

Pennsylvania 224,471 200,000 66,667 163,007 -61,464 -27.4

Puerto Rico 330,908 300,000 100,000 221,682 -109,226 -33.0

Rhode Island 213,729 200,000 66,667 120,716 -93,013 -43.5

South Carolina 300,681 250,000 83,333 282,859 -17,822 -5.9

Texas 390,044 300,000 100,000 454,496 64,452 16.5

Virgin Islands 303,455 300,000 100,000 113,602 -189,853 -62.6

Page 55 GAO-07-591 Great Lakes Beaches
Appendix III: GAO’s Calculations for an 

Alternative BEACH Act Grant Distribution

Formula 

States and

territories 

BEACH Act 

grant allocation

of $10 million 

Amount based 

on beach

season

27.2% of

amount based 

on beach

season

Estimated 

BEACH Act grant 

under simulated

formula 

Difference 

between actual 

and estimated

allocations (in

dollars)

Difference 

between

actual and 

estimated

allocations

Virginia 283,536 200,000 66,667 $395,541 112,005 39.5

Washington 276,382 200,000 66,667 $367,377 90,995 32.9

Wisconsin 227,448 200,000 66,667 $174,729 -52,719 -23.2

Total $10,000,001 $8,150,000 $2,716,667 $10,000,000 -$1 0.0%

Source: GAO.

Note: Differences noted are due to rounding. 

By simulating the distribution of BEACH Act grants given the more equally

weighted percentages EPA built into its original formula, states with large 

populations, such as Florida, California, and New York would receive 

almost twice as much grant funding as their current allocations. However, 

this increase would come at the expense of states such as Alabama and 

Indiana, and territories such as Puerto Rico, which would receive as little 

as half of their current allocations. California’s allocation, for example, 

would increase by 92 percent, while Indiana’s allocation would decrease 

by 56 percent. It is important to recognize that such large swings in 

allocations could make it difficult for states that have come to depend on 

BEACH Act funding over the last 6 years to continue to monitor their 

beaches. EPA could consider using a hold-harmless provision to minimize 

states’ potential loss of large portions of their BEACH Act grants. The 

hold-harmless provision would ensure that the current grantees would 

maintain, at a minimum, their previous year’s allocation, while any 

additional funding would be allocated to those states with longer 

shorelines and larger populations. 

Page 56 GAO-07-591 Great Lakes Beaches
Appendix IV: Comments from the Appendix IV Environmental Protection Agency : Comments from the 

Environmental Protection Agency 

Page 57 GAO-07-591 Great Lakes Beaches
Appendix IV: Comments from the 

Environmental Protection Agency 

Page 58 GAO-07-591 Great Lakes Beaches
Appendix IV: Comments from the 

Environmental Protection Agency 

Page 59 GAO-07-591 Great Lakes Beaches
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 60 GAO-07-591 

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact Anu K. Mittal, (202) 512-3841, mittala@gao.gov 

In addition to the individual named above, Edward Zadjura, Assistant 

Director; Eric Bachhuber; Joanna Chan; Robert Dinkelmeyer; Greg 

Dybalski; Heather Holsinger; DuEwa Kamara; Matt Michaels; Omari 

Norman; Alison O’Neill; Mark Ramage; and Walter Vance made key 

contributions to this report. Also contributing to the report were Kim 

Raheb, Jena Sinkfield, and John Wanska. 

Great Lakes Beaches

Staff 

Acknowledgments 

(360688) 
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