Testimony 

Before the Subcommittee on Water 

Resources and Environment, Committee 

on Transportation and Infrastructure, 

House of Representatives 

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 10:00 a.m. EDT 

Friday, May 21, 2004 GREAT LAKES

A Comprehensive Strategy 

and Monitoring System Are 

Needed to Achieve 

Restoration Goals 

Statement of John B. Stephenson, Director 

Natural Resources and Environment 

GAO-04-782T 
www.gao.gov/cgi-bin/getrpt?GAO-04-782T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact John B. 

Stephenson at (202) 512-3841 or 

stephensonj@gao.gov. 

Highlights of GAO-04-782T, a testimony 

before Subcommittee on Water Resources 

and Environment, Committee on 

Transportation and Infrastructure, House 

of Representatives 

May 21, 2004

GREAT LAKES

A Comprehensive Strategy and 

Monitoring System Are Needed To 

Achieve Restoration Goals 

There are 148 federal and 51 state programs funding environmental 

restoration activities in the Great Lakes Basin. Most of these programs are 

nationwide or statewide programs that do not specifically focus on the Great 

Lakes. However, GAO identified 33 federal Great Lakes specific programs, 

and 17 additional unique Great Lakes specific programs funded by states. 

Although Great Lakes funding is not routinely tracked for many of these 

programs, we identified a total of about $3.6 billion in basin-specific projects 

for fiscal years 1992 through 2001. 

Several disparate Great Lakes environmental strategies are being used at the 

binational, federal, and state levels. Currently, these strategies are not 

coordinated in a way that ensures effective use of limited resources. Without 

such coordination it is difficult to determine the overall progress of 

restoration efforts. The Water Quality Act of 1987 charged EPA’s Great 

Lakes National Program Office with the responsibility for coordinating 

federal actions for improving Great Lakes’ water quality; however, the office 

has not fully exercised this authority to this point. 

With available information, current environmental indicators do not allow a 

comprehensive assessment of restoration progress in the Great Lakes. 

Current indicators rely on limited quantitative data and subjective judgments 

to determine whether conditions are improving, such as whether fish are 

safe to eat. The ultimate success of an ongoing binational effort to develop a 

set of overall indicators for the Great Lakes is uncertain because it relies on 

the resources voluntarily provided by several organizations. Further, no 

date for completing a final list of indicators has been established. 

Great Lakes: Largest Body of Freshwater in the World 

The five Great Lakes, which 

comprise the largest system of 

freshwater in the world, are 

threatened on many environmental 

fronts. To address the extent of 

progress made in restoring the 

Great Lakes Basin, which includes 

the lakes and surrounding area, 

GAO (1) identified the federal and 

state environmental programs 

operating in the basin and funding 

devoted to them, (2) evaluated the 

restoration strategies used and how 

they are coordinated, and (3) 

assessed overall environmental 

progress made in the basin 

restoration effort. 

GAO recommended in its April 

2003 report that the Administrator, 

Environmental Protection Agency 

• ensure that the Great Lakes 

National Program Office fulfills 

its coordination responsibilities 

and develop an overarching 

Great Lakes strategy; and 

• develop environmental 

indicators and a monitoring 

system for the Great Lakes 

Basin that can be used to 

measure overall restoration 

progress. 

EPA generally agreed with GAO’s 

conclusions that better planning, 

coordination, monitoring and the 

development of indicators are 

needed, and stated it would provide 

a formal response to the report 

recommendations at a later date. 

As of May 2004, it has not yet 

provided this response. 
Page 1 GAO-04-782T 

Mr. Chairman and Members of the Subcommittee: 

We are pleased to be here today to discuss our work on environmental 

restoration activities in the Great Lakes Basin. The Great Lakes represent 

the largest system of freshwater in the world and a natural resource that is 

threatened on many environmental fronts. To protect this resource and to 

address common water quality problems, the United States and Canada 

entered into the bilateral Great Lakes Water Quality Agreement (GLWQA) 

in 1972. However, today, more than 3 decades since the original 

agreement, beaches are frequently closed to swimmers due to pollution, 

fish are unsafe to eat for high risk individuals, and raw sewage is still being 

dumped into the lakes. Recently discovered conditions such as the 

reemergence in Lake Erie of a “dead zone”—an area that has no dissolved 

oxygen and therefore cannot support aquatic life—have renewed concerns 

about the overall ecological health of the Great Lakes. 

Progress has been made on a number of significant fronts, including 

controlling the nonnative sea lamprey, reducing the water’s phosphorus 

content, and improving fish populations, but much more remains to be 

accomplished before the overall goals of the agreement can be met. 

Several recently released reports, including ours, have questioned whether 

the current environmental activities in the Great Lakes being funded by 

numerous organizations and various programs have resulted in significant 

restoration progress in the basin, or even if they are adequate to fulfill the 

U.S. commitments under the Agreement. In 2002, we reported that the 

Environmental Protection Agency (EPA) needed to take action to improve 

its oversight for cleaning up specifically designated contaminated areas.1

My testimony today is based on our April 2003 report2

 prepared at the 

request of 14 members of Congress’ Great Lakes Task Force. Specifically, 

GAO was asked to (1) identify the federal and state environmental 

programs operating in the Great Lakes Basin and the funding being 

devoted to them, (2) evaluate how the restoration strategies are used and 

 1

See U.S. General Accounting Office, Great Lakes: EPA Needs to Define Organizational 

Responsibilities Better for Effective Oversight and Cleanup of Contaminated Areas, 

GAO-02-563 (Washington, D.C.: May 17, 2002). 

2

See U.S. General Accounting Office, Great Lakes: An Overall Strategy and Indicators for 

Measuring Progress Are Needed to Better Achieve Restoration Goals, GAO-03-515

(Washington, D.C.: April 30, 2003). 
Page 2 GAO-04-782T 

coordinated, and (3) assess overall environmental progress made in the 

basin restoration efforts thus far. 

In summary, Mr. Chairman, we found the following: 

• There are 148 federal and 51 state programs funding environmental 

restoration activities in the Great Lakes Basin. Most of these are 

nationwide or statewide programs that do not specifically focus on the 

Great Lakes, but do fund projects that contribute to basin cleanup. We 

could not determine the total Great Lakes-specific funding contributions 

from these programs because funds are not typically tracked for specific 

areas like the basin. However, based on partial information available from 

11 federal agencies and seven of the eight Great Lakes states, we 

determined for these nationwide or statewide programs that at least $1.8 

billion in federal funding, and $461.3 million in state funding went to basinrelated projects in fiscal years 1992 through 2001. The remaining 

programs, 33 federal and 17 state, which focus specifically on 

restoration activities in the Great Lakes Basin, spent about $387 million 

and $956 million, respectively, in fiscal years 1992 through 2001. 

• The numerous restoration programs operating in the Great Lakes Basin 

employ a variety of environmental strategies at the binational, federal, and 

state levels to address specific environmental problems, but there is no 

overarching plan for coordinating these disparate strategies and program 

activities into a coherent approach for attaining overall basin restoration 

goals. Without such a plan for the basin, it is difficult to determine overall 

progress and ensure that limited resources are being effectively utilized. 

Other large-scale ecosystem restoration efforts, such as the ones for the 

Chesapeake Bay and the South Florida ecosystem, have demonstrated the 

importance of having a comprehensive strategic plan with clearly 

articulated goals, objectives, and criteria for measuring success and a 

decision-making body for weighing the merits of, and prioritizing funding 

for, proposed cleanup and restoration projects. 

• The absence of a unified Great Lakes restoration effort stems, in part, from 

the lack of an effective, authoritative organizational entity for planning, 

monitoring, and establishing funding priorities. The Water Quality Act of 

1987 charged EPA’s Great Lakes National Program Office (GLNPO), with 

the responsibility for coordinating federal actions for improving Great 

Lakes’ water quality. However, GLNPO has not fully exercised this 

authority. For example, it has not entered into agreements with other 

agency organizations regarding their restoration responsibilities as 

required by the Clean Water Act. 
Page 3 GAO-04-782T 

• Additionally, the lack of consistent, reliable information and measurement 

indicators makes it impossible to comprehensively assess restoration 

progress in the Great Lakes Basin. While the Great Lakes Water Quality 

Agreement long ago called for the development and implementation of a 

monitoring system, this requirement has not yet been met. Furthermore, 

any effort to develop indicators must rely on limited quantitative data and 

subjective judgments to determine whether conditions are improving. In 

1996, a binational effort was initiated to develop a set of overall indicators 

for the Great Lakes through a series of biennial conferences, but the 

ultimate success of this effort, which relies on the volunteer contributions 

of several organizations, is uncertain. 

To improve coordination and help ensure that funds are effectively spent, 

we recommended that the Administrator, Environmental Protection 

Agency (1) charge GLNPO with the responsibility for developing an 

overarching Great Lakes strategy with specific goals and priorities for 

evaluating and funding alternative projects, (2) submit a proposal to 

Congress for funding the plan, and (3) develop environmental indicators 

and a monitoring system that can be used to measure overall restoration 

progress. EPA generally agreed with our conclusions but stated that it 

would provide a formal response to our recommendations at a later date. 

However, over 1 year has past and EPA has not provided us with its formal 

response. 

The Great Lakes Basin is a large area that extends well beyond the five 

lakes proper to include their watersheds, tributaries, connecting channels, 

and a portion of the St. Lawrence River. The basin encompasses nearly all 

of the state of Michigan and parts of Illinois, Indiana, Minnesota, New 

York, Ohio, Pennsylvania, Wisconsin, and the Canadian province of 

Ontario. The lakes form the largest freshwater system on earth, accounting 

for 20 percent of the world’s fresh surface water and over 95 percent of the 

U.S. fresh surface water supply for the contiguous 48 states. 

Millions of people in the United States and Canada rely on the five Great 

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

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

time, industrial, agricultural, and residential development on lands 

adjacent to the lakes have seriously degraded the lakes’ water quality, 

posing threats to human health and the environment, and forcing 

restrictions on activities, such as swimming and fish consumption. 

Background 
Page 4 GAO-04-782T 

To protect the Great Lakes Basin and to address water quality problems, 

the governments of the United States and Canada entered into the bilateral 

Great Lakes Water Quality Agreement in 1972. In the agreement, the 

United States and Canada agreed to restore and maintain the chemical, 

physical, and biological integrity of the Great Lakes Basin. A new 

agreement with the same name was reached in 1978, and amended in 1983 

and 1987. The agreement prescribes prevention and cleanup measures to 

improve environmental conditions in the Great Lakes. The agreement 

obligates the International Joint Commission (IJC), an international body, 

to assist and to report on the implementation of the agreement. 

The Clean Water Act directs EPA to lead efforts to meet the goals of the 

Great Lakes Water Quality Agreement and establishes GLNPO within EPA, 

charging it with, among other things, cooperating with federal, state, tribal, 

and international agencies to develop action plans to carry out the U.S. 

responsibilities under the agreement. GLNPO is further responsible for 

coordinating the agency’s actions both in headquarters and in the regions 

to improve Great Lakes’ water quality. In addition to GLNPO, numerous 

federal, state, binational, and nonprofit organizations conduct activities 

that focus on improving the overall Great Lakes Basin environment or 

some specific environmental issue within the basin. 

About 200 programs—148 federal and 51 state—fund restoration activities 

within the Great Lakes Basin. Most of these programs, however, involve 

the localized application of national or state environmental initiatives and 

do not specifically focus on basin concerns. Officials from 11 federal 

agencies identified 115 of these broadly scoped federal programs, and 

officials from seven of the eight Great Lakes states identified 34 similar 

state programs. EPA administers the majority of the federal programs that 

provide a broad range of environmental activities involving research, 

cleanup, restoration, and pollution prevention. For example, EPA’s 

nationwide Superfund program funds cleanup activities at contaminated 

areas throughout the basin. While these broadly scoped federal and state 

programs contribute to basin restoration, program officials do not track or 

try to isolate the portion of funding going to specific areas like the basin, 

making it difficult to determine their contribution to total Great Lakes 

spending. However, basin-specific information was available on some of 

these programs. Specifically, basin related expenditures for 53 of the 115 

broadly scoped federal programs totaled about $1.8 billion in fiscal years 

1992 through 2001. Expenditures for 14 broadly scoped state funded 

programs totaled $461.3 million during approximately the same time 

period. 

Many Federal and 

State Programs Fund 

Restoration Activities 

in the Great Lakes 

Basin 
Page 5 GAO-04-782T 

Several federal and state programs were specifically designed to focus on 

environmental conditions across the Great Lakes Basin. Officials from 

seven federal agencies identified 33 Great Lakes-specific programs that 

had expenditures of $387 million in fiscal years 1992 through 2001. Most of 

these programs funded a variety of activities, such as research, cleanup, or 

pollution prevention. An additional $358 million was expended for 

legislatively directed Corps of Engineers projects in the basin, such as a 

$93.8 million project to restore Chicago’s shoreline. Officials from seven 

states reported 17 Great Lakes specific programs that expended about 

$956 million in 1992 through 2001, with Michigan’s programs accounting 

for 96 percent of this amount. State programs focused on unique state 

needs, such as Ohio’s program to control shoreline erosion along Lake 

Erie, and Michigan’s program to provide bond funding for environmental 

activities. 

Besides federal and state government agencies, other organizations, such 

as foundations, fund a variety of restoration activities in the Great Lakes 

Basin by approving grants to nonprofit and other organizations. Other 

governmental and nongovernmental organizations fund restoration 

activities. For example, individual municipalities, township governments, 

counties, and conservation districts are involved in various restoration 

activities. 

Restoration of the Great Lakes Basin is a major endeavor involving many 

environmental programs and organizations. The magnitude of the area 

comprising the basin and the numerous environmental programs operating 

within it require the development of one overarching strategy to address 

and manage the complex undertaking of restoring the basin’s 

environmental health. The Great Lakes region cannot hope to successfully 

receive support as a national priority without a comprehensive, 

overarching plan for restoring the Great Lakes. In lieu of such a plan, 

organizations at the binational, federal, and state levels have developed 

their own strategies for the Great Lakes, which have inadvertently made 

the coordination of various programs operating in the basin more 

challenging. 

The Great Lakes Basin needs a comprehensive strategy or plan similar to 

those developed for other large ecosystem restoration efforts, such as the 

ones for the South Florida ecosystem and the Chesapeake Bay. In South 

Florida, federal, state, local and tribal organizations joined forces to 

participate on a centralized task force formalized in the Water Resource 

Development Act of 1996. The strategic plan developed for the South 

The Lack of a 

Coordinated, 

Overarching Strategic 

Plan Has Impeded 

Restoration Efforts 
Page 6 GAO-04-782T 

Florida ecosystem by the task force made substantial progress in guiding 

the restoration activities. The plan identifies the resources needed to 

achieve restoration and assigns accountability for specific actions for the 

extensive restoration effort estimated to cost $14.8 billion. The 

Chesapeake Bay watershed also has an overarching restoration strategy 

stemming from a 1983 agreement signed by the states of Maryland, 

Virginia, and Pennsylvania; the District of Columbia; the Chesapeake Bay 

Commission; and EPA. This agreement was the basis for a program to 

protect and restore this ecosystem. The implementation of this strategy 

has resulted in improvements in habitat restoration and aquatic life, such 

as increased forested buffer zone and shad population. 

Several organizations have developed strategies for the basin at the 

binational, federal, or state levels that address either the entire basin or 

the specific problems in the Great Lakes. EPA’s Great Lakes Strategy 

2002, developed by a committee of federal and state officials, is the most 

recent of these strategies. While this strategy identified restoration 

objectives and planned actions by various federal and state agencies, it is 

largely a description of existing program activity relating to basin 

restoration. State officials told us that the states had already planned the 

actions described in it, but that these actions were contingent on funding 

for specific environmental programs. The strategy included a statement 

that it should not be construed as a commitment for additional funding or 

resources, and it did not provide a basis for prioritizing activities. In 

addition, we identified other strategies that addressed particular 

contaminants, restoration of individual lakes, or cleanup of contaminated 

areas. Ad hoc coordination takes place among federal agencies, states, and 

other environmental organizations in developing these strategies or when 

programmatic activity calls for coordination. 

Other Great Lakes strategies address unique environmental problems or 

specific geographical areas. For example, a strategy for each lake 

addresses the open lake waters through Lakewide Management Plans 

(LaMP), which EPA is responsible for developing. Toward this end, EPA 

formed working groups for each lake to identify and address restoration 

activities. For example, the LaMP for Lake Michigan, issued in 2002, 

includes a summary of the lake’s ecosystem status and addresses progress 

in achieving the goals described in the previous plan, with examples of 

significant activities completed and other relevant topics. However, EPA 

has not used the LaMPs to assess the overall health of the ecosystem. 

The Binational Executive Committee for the United States and Canada 

issued its Great Lakes Binational Toxics Strategy in 1997 that established 
Page 7 GAO-04-782T 

a collaborative process by which EPA and Environment Canada, in 

consultation with other federal departments and agencies, states, the 

province of Ontario, and tribes, work toward the goal of the virtual 

elimination of persistent toxic substances in the Great Lakes. The strategy 

was designed to address particular substances that bioaccumulate in fish 

or animals and pose a human health risk. 

Michigan developed a strategy for environmental cleanup called the Clean 

Michigan Initiative. This initiative provides funding for a variety of 

environmental, parks, and redevelopment programs. It includes nine 

components, including Brownfields redevelopment and environmental 

cleanups, nonpoint source pollution control, clean water, cleanup of 

contaminated sediments, and pollution prevention. The initiative is funded 

by a $675 million general obligation bond and as of early 2003; most of the 

funds had not been distributed. 

Although there are many strategies and coordination efforts ongoing, no 

one organization coordinates restoration efforts. We found that extensive 

strategizing, planning, and coordinating have not resulted in significant 

restoration. Thus, the ecosystem remains compromised and contaminated 

sediments in the lakes produce health problems, as reported by the IJC.3

In addition to the absence of a coordinating agency, federal and state 

officials cited a lack of funding commitments as a principal barrier 

impeding restoration progress. Inadequate funding has also contributed to 

the failure to restore and protect the Great Lakes, according to the IJC 

biennial report on Great Lakes water quality issued in July 2000.4

 The IJC 

restated this position in a 2002 report, concluding that any progress to 

restore the Great Lakes would continue at a slow incremental pace 

without increased funding.5

 In its 1993 biennial report, the IJC concluded 

that remediation of contaminated areas could not be accomplished unless 

government officials came to grips with the magnitude of cleanup costs 

and started the process of securing the necessary resources.6

 Despite this 

warning, however, as we reported in 2002, EPA reduced the funding 

available for ensuring the cleanup of contaminated areas under the 

 3

See IJC, Tenth Biennial Report on Great Lakes Water Quality, (June 29, 2000). 

4

See IJC, Tenth Biennial Report on Great Lakes Water Quality, (June 29, 2000). 

5

See IJC, Eleventh Biennial Report on Great Lakes Water Quality, (Sept. 12, 2002). 

6

See IJC, Seventh Biennial Report on Great Lakes Water Quality, (Dec. 15, 1993). 
Page 8 GAO-04-782T 

assumption that the states would fill the funding void. States, however, did 

not increase their funding, and restoration progress slowed or stopped 

altogether.7

 Officials for 24 of 33 federal programs and for 3 of 17 state 

programs reported insufficient funding for federal and state Great Lakes 

specific programs. 

Ultimate responsibility for coordinating Great Lakes restoration programs 

rests with GLNPO; however, GLNPO has not fully exercised this authority. 

Other organizations or committees have formed to assume coordination 

and strategy development roles. The Clean Water Act provides GLNPO 

with the authority to fulfill the U.S. responsibilities under the GLWQA. 

Specifically, the act directs EPA to coordinate the actions of EPA’s 

headquarters and regional offices aimed at improving Great Lakes water 

quality. It also provides GLNPO authority to coordinate EPA’s actions with 

the actions of other federal agencies and state and local authorities for 

obtaining input in developing water quality strategies and obtaining 

support in achieving the objectives of the GLWQA. The act also provides 

that the EPA Administrator shall ensure that GLNPO enters into 

agreements with the various organizational elements of the agency 

engaged in Great Lakes activities and with appropriate state agencies. The 

agreements should specifically delineate the duties and responsibilities, 

time periods for carrying out duties, and resources committed to these 

duties. GLNPO officials stated that they do not enter into formal 

agreements with other EPA offices, but rather fulfill their responsibilities 

under the act by having federal agencies and state officials agree to the 

restoration activities contained in the Great Lakes Strategy 2002. 

However, the strategy does not represent formal agreements to conduct 

specific duties and responsibilities with committed resources. EPA’s 

Office of Inspector General reported the absence of these agreements in 

September 1999.8

 The report stated that GLNPO did not have agreements 

as required by the act and recommended that such agreements be made to 

improve working relationships and coordination. 

To improve coordination of Great Lakes activities and ensure that federal 

dollars are effectively spent, we recommended that the Administrator, 

 7

See U.S. General Accounting Office, Great Lakes: EPA Needs to Define Organizational 

Responsibilities Better for Effective Oversight and Cleanup of Contaminated Areas, 

GAO-02-563 (Washington, D.C.: May 17, 2002). 

8

See U.S. Environmental Protection Agency, EPA’s Great Lakes Program, EPA/OIG Rept. 

99P00212 (Washington, D.C.: Sept. 1, 1999). 
Page 9 GAO-04-782T 

EPA, ensure that GLNPO fulfills its responsibility for coordinating 

programs within the Great Lakes Basin; charge GLNPO with developing, in 

consultation with the governors of the Great Lakes states, federal 

agencies, and other organizations, an overarching strategy that, clearly 

defines the roles and responsibilities for coordinating and prioritizing 

funding for projects; and submit a time-phased funding requirement 

proposal to the Congress necessary to implement the strategy. 

The Great Lakes Water Quality Agreement, as amended in 1987, calls for 

establishing a monitoring system to measure restoration progress and 

assess the degree that the United States and Canada are complying with 

the goals and objectives of the agreement. However, implementation of 

this provision has not progressed to the point that overall restoration 

progress can be measured or determined based on quantitative 

information. Recent assessments of overall progress, which rely on a mix 

of quantitative data and subjective judgments, do not provide an adequate 

basis for making an overall assessment. The current assessment process 

has emerged from a series of biennial State of the Lakes Ecosystem 

Conferences (SOLEC)9

 initiated in 1994 for developing indicators agreed 

upon by conference participants. 

Prior to the 1987 amendments to the GLWQA, the 1978 agreement between 

the two countries also contained a requirement for surveillance and 

monitoring and for the development of a Great Lakes International 

Surveillance Plan. The IJC Water Quality Board was involved in managing 

and developing the program until the 1987 amendments placed this 

responsibility on the United States and Canada. This change resulted in a 

significant reduction in the two countries’ support for surveillance and 

monitoring. In fact, the organizational structure to implement the 

surveillance plan was abandoned in 1990, leaving only one initiative in 

place—the International Atmospheric Deposition Network (IADN), a 

network of 15 air-monitoring stations located throughout the basin. 

With the surveillance and monitoring efforts languishing, IJC established 

the Indicators for Evaluation Task Force in 1993 to identify the 

appropriate framework to evaluate progress in the Great Lakes. In 1996, 

the task force proposed that nine desired measurements and outcomes be 

used to develop indicators for measuring progress in the Great Lakes. 

 9

SOLEC is co-chaired by representatives from the U.S. EPA and Environment Canada. 

The Lack of an 

Effective Monitoring 

System Makes it 

Impossible to Assess 

Overall Restoration 

Progress 
Page 10 GAO-04-782T 

Shortly before the task force began its work, the United States and Canada 

had agreed to hold conferences every 2 years to assess the environmental 

conditions in the Great Lakes in order to develop binational reports on the 

environmental conditions to measure progress under the agreement. 

Besides assessing environmental conditions the conferences were focused 

on achieving three other objectives, including providing a forum for 

communication and networking among stakeholders. Conference 

participants included U.S. and Canadian representatives from federal, 

state, provincial, and tribal agencies, as well as other organizations with 

environmental restoration or pollution prevention interests in the Great 

Lakes Basin. The 1994 SOLEC conference culminated in a “State of the 

Great Lakes 1995” report, which provided an overview of the Great Lakes 

ecosystem at the end of 1994 and concluded that overall the aquatic 

community health was mixed or improving. The same assessment was 

echoed in the 1997 state of the lakes report. Meanwhile the IJC agreed that 

the nine desired outcome areas recommended by the task force would 

help assess overall progress. It recommended that SOLEC, during the 

conference in 2000, establish environmental indicators that would allow 

the IJC to evaluate what had been accomplished and what needed to be 

done for three of the nine indicators—the public’s ability to eat the fish, 

drink the water, and swim in the water without any restrictions. 

However, the indicators developed through the SOLEC process and the 

accomplishments reported by federal and state program managers do not 

provide an adequate basis for making an overall assessment for Great 

Lakes restoration progress. The SOLEC process is ongoing and the 

indicators still being developed are not generally supported by sufficient 

underlying data for making progress assessments. The number of 

indicators considered during the SOLEC conferences has been pared 

down from more than 850 indicators in 1998 to 80 indicators in 2000, 

although data were available for only 33 of them. 

After the SOLEC 2000 conference, IJC staff assessed the indicators 

supported by data that measured the desired outcomes of swimmability, 

drinkability, and the edibility of fish in the Great Lakes.10 Overall, the IJC 

commended SOLEC’s quick response that brought together information 

regarding the outcomes and SOLEC’s ongoing efforts. The IJC, however, 

recognized that sufficient data were not being collected throughout the 

Great Lakes Basin and that the methods of collection, the data collection 

 10See IJC, Eleventh Biennial Report on Great Lakes Water Quality, (Sept. 12, 2002). 
Page 11 GAO-04-782T 

time frames, the lack of uniform protocols, and the incompatible nature of 

some data jeopardized their use as indicators. Specifically, for the desired 

outcome of swimmability, the IJC concurred that it was not always safe to 

swim at certain beaches, but noted that progress for this desired outcome 

was limited because beaches were sampled by local jurisdictions without 

uniform sampling or reporting methods. At the 2002 SOLEC conference, 

the number of indicators assessed by conference participants increased 

from 33 to 45. The IJC expressed concern that there are too many 

indicators, insufficient supporting backup data, and a lack of commitment 

and funding from EPA to implement and make operational the agreed 

upon SOLEC baseline data collection and monitoring techniques. The IJC 

recommended in its last biennial report in September 2002 that any new 

indicators should be developed only where resources are sufficient to 

access scientifically valid and reliable information. The information from 

the 2002 SOLEC conference culminated in the “State of the Great Lakes 

2003” report, which concluded that the chemical, physical, and biological 

integrity of the basin is mixed based on assessments of 43 indicators. This 

conclusion was based on five positive signs of recovery, such as persistent 

toxic substances are continuing to decline, and seven negative signs, such 

as phosphorous levels are increasing in Lake Erie. 

The ultimate successful development and assessment of indicators for the 

Great Lakes through the SOLEC process are uncertain because insufficient 

resources have been committed to the process, no plan provides 

completion dates for indicator development and implementation, and no 

entity is coordinating the data collection. Even though the SOLEC process 

has successfully engaged a wide range of binational parties in developing 

indicators, the resources devoted to this process are largely provided on a 

volunteer basis without firm commitments to continue in the future. 

GLNPO officials described the SOLEC process as a professional, 

collaborative process dependent on the voluntary participation of officials 

from federal and state agencies, academic institutions, and other 

organizations attending SOLEC and developing information on specific 

indicators. Because SOLEC is a voluntary process, the indicator data 

resides in a diverse number of sources with limited control by SOLEC 

organizers. GLNPO officials stated that EPA does not have either the 

authority or the responsibility to direct the data collection activities of 

federal, state, and local agencies as they relate to surveillance and 

monitoring of technical data elements that are needed to develop, 

implement, and assess Great Lakes environmental indicators. Efforts are 

underway for the various federal and state agencies to take ownership for 

collecting and reporting data outputs from their respective areas of 

responsibility and for SOLEC to be sustained and implemented; each 
Page 12 GAO-04-782T 

indicator must have a sponsor. However, any breakdown in submission of 

this information would leave a gap in the SOLEC indicator process. 

EPA supports the development of environmental indicators as evidenced 

by the fact that, since 1994, GLNPO has provided about $100,000 annually 

to sponsor the SOLEC conferences. Additionally, GLNPO spends over $4 

million per year to collect surveillance data for its open-lake water quality 

monitoring program, which also provides supporting data for some of the 

indicators addressed by SOLEC. A significant portion of these funds, 

however, supports the operation of GLNPO’s research vessel, the Lake 

Guardian, an offshore supply vessel converted for use as a research 

vessel. GLNPO also supports activities that are linked or otherwise feed 

information into the SOLEC process, including the following: 

• collecting information on plankton and benthic communities in the Great 

Lakes for open water indicator development; 

• sampling various chemicals in the open-lake waters, such as 

phosphorus for the total phosphorus indicator; 

• monitoring fish contaminants in the open waters, directly supporting the 

indicator for contaminants in whole fish and a separate monitoring effort 

for contaminants in popular sport fish species that supports the indicator 

for chemical contaminants in edible fish tissue; and 

• operating 15 air-monitoring stations with Environment Canada 

comprising the IADN that provides information for establishing trends in 

concentrations of certain chemicals and loadings of chemicals into the 

lakes. EPA uses information from the network to take actions to control 

the chemicals and track progress toward environmental goals. 

To better coordinate monitoring activities GLNPO and Environment 

Canada began developing a web-based inventory of monitoring activities 

in the Great Lakes Basin. The first workshop on developing this system 

was held in January 2002. Once development of this system is complete, 

organizations conducting monitoring activities will be requested to 

provide descriptive information about these monitoring activities and 

contact points for obtaining specific monitoring data. We are currently 

conducting a review for 20 members of Congress serving on the Great 

Lakes Task Force that further examines monitoring activities in the Great 

Lakes Basin. In this review we hope to identify some of the major 

challenges to developing a Great Lakes Basin monitoring system. 
Page 13 GAO-04-782T 

Program officials frequently cite output data as measures of success rather 

than actual program accomplishments in improving environmental 

conditions in the basin. As a rule, program output data describe activities, 

such as projects funded, and are of limited value in determining 

environmental progress. For example, in reporting the accomplishments 

for Michigan’s Great Lakes Protection Fund, officials noted that the 

program had funded 125 research projects over an 11-year period and 

publicized its project results at an annual forum and on a Web site. 

Similarly, the Lake Ontario Atlantic Salmon Reintroduction Program 

administered by the Department of Interior’s Fish and Wildlife Service 

listed under its accomplishments the completion of a pilot study and 

technical assistance provided to a Native American tribe. 

Of the 50 federal and state programs created specifically to address 

conditions in the basin, 27 reported accomplishments in terms of outputs, 

such as reports or studies prepared or presentations made to groups. 

Because research and capacity building programs largely support other 

activities, it is particularly difficult to relate reported program 

accomplishments to outcomes. The federal and state environmental 

program officials responding to our evaluation generally provided output 

data or, as reported for 15 programs, reported that the accomplishments 

had not been measured for the programs. 

Only eight of the federal or state Great Lakes-specific programs reported 

outcome information, much of which generally described how effective 

the programs’ activity or action had been in improving environmental 

conditions. For example, EPA’s Region II program for reducing toxic 

chemical inputs into the Niagara River, which connects Lake Erie to Lake 

Ontario, reported reductions in priority toxics from 1986 through 2002 

from ambient water quality monitoring. Other significant outcomes 

reported as accomplishments for the Great Lakes included (1) reducing 

phosphorus loadings by waste treatment plants and limiting phosphorus 

use in household detergents; (2) prohibiting the release of some toxicants 

into the Great Lakes, and reducing to an acceptable level the amount of 

some other toxicants that could be input; (3) effectively reducing the sea 

lamprey population in several invasive species infested watersheds; and 

(4) restocking the fish-depleted populations in some watersheds. 

To fulfill the need for a monitoring system called for in the GLWQA and to 

ensure that the limited funds available are optimally spent, we 

recommended that the Administrator, EPA, in coordination with Canadian 

officials and as part of an overarching Great Lakes strategy, (1) develop 

environmental indicators and a monitoring system for the Great Lakes 
Page 14 GAO-04-782T 

Basin that can be used to measure overall restoration progress and (2) 

require that these indicators be used to evaluate, prioritize, and make 

funding decisions on the merits of alternative restoration projects. 

Mr. Chairman, this completes my prepared statement. I would be happy to 

answer any questions that you or other members of the Subcommittee 

may have at this time. 

For further information, please contact John B. Stephenson at 

(202) 512-3841. Individuals making key contributions to this testimony 

were Willie Bailey, Greg Carroll, Karen Keegan, Jonathan McMurray, and 

John Wanska. 

Contacts and Staff 

Acknowledgements 

(360469) 
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