GREAT LAKES 

RESTORATION 

INITIATIVE

Further Actions 

Would Result in More 

Useful Assessments 

and Help Address 

Factors That Limit 

Progress

Report to Congressional Requesters

September 2013

GAO-13-797

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-797, a report to 

congressional requesters

September 2013

GREAT LAKES RESTORATION INITIATIVE

Further Actions Would Result in More Useful 

Assessments and Help Address Factors That Limit 

Progress

Why GAO Did This Study

The Great Lakes contain about 84 

percent of North America’s surface 

freshwater and provide economic and 

recreational benefits in the Great 

Lakes Basin. However, the Great 

Lakes face significant stresses—such 

as toxic pollution—that have caused 

ecological and economic damage to 

the region.

Approximately $1.3 billion has been 

appropriated to the GLRI, created in 

fiscal year 2010, which an interagency 

Task Force of 11 federal agencies, 

chaired by the EPA Administrator, 

oversees. In 2010, the Task Force

issued an Action Plan for fiscal years 

2010 to 2014 to develop a 

comprehensive approach to restoring 

the health of the Great Lakes 

ecosystem. GAO was asked to review 

the GLRI. This report examines (1) 

how the GLRI is implemented by the 

Task Force agencies and other

stakeholders, (2) the methods that 

EPA has in place to assess GLRI 

progress, (3) the progress identified by 

the Task Force agencies and 

nonfederal stakeholders, and (4) the 

views of nonfederal stakeholders on 

factors, if any, that may affect or limit 

GLRI progress. GAO analyzed the 

Action Plan, surveyed 205 non-federal 

recipients of GLRI funding, and 

interviewed Task Force agency 

officials and nonfederal stakeholders. 

What GAO Recommends

GAO recommends that EPA help 

ensure more comprehensive and 

useful GLRI progress assessments

and account for factors outside of the 

Action Plan's scope that may affect the 

GLRI’s long-term success. EPA 

generally agreed with GAO’s

recommendations.

What GAO Found

The Task Force agencies use the Action Plan to implement the Great Lakes 

Restoration Initiative (GLRI) and use an interagency process to enter into 

agreements among themselves to identify GLRI projects and with other 

stakeholders to implement GLRI projects. The Action Plan includes guidance for 

implementing the GLRI in five focus areas (such as invasive species and habitat 

and wildlife protection and restoration) that encompass the most significant 

environmental problems in the Great Lakes. Each focus area includes, among 

other things, long-term goals, objectives to be achieved by fiscal year 2014, and 

28 measures of progress that have annual targets for fiscal years 2010 to 2014. 

EPA uses the Action Plan's measures to assess GLRI progress. However, its

methods may not produce comprehensive and useful assessments of GLRI 

progress for several reasons. Among them, some of the goals and objectives do 

not link to any measures and, as a result, it is unclear how EPA will be able to 

assess progress toward them. In addition, some measures track actions that may 

not lead to the desired GLRI goal. For example, one measure tracks the 

reduction in concentrations of polychlorinated biphenyls (PCB) in fish as part of 

the goal to lift all restrictions on consumption of Great Lakes fish. However, 

stakeholders reported that the measure is too narrow and that mercury and other 

contaminants need to be addressed as well. Consequently, reducing PCB 

concentrations in fish is not likely to lead to the desired result of lifting all Great 

Lakes fish consumption restrictions. Without useful measures, EPA may not be 

able to determine that GLRI efforts are producing the desired results.

In spring 2013, the Task Force agencies issued two reports about GLRI progress 

in fiscal years 2010 and 2011, which state whether the targets for the Action

Plan's 28 measures were being met (e.g., 15 of 28 measures met or exceeded in 

fiscal year 2011), but the reports include few specific examples of progress. As a 

result, GAO sought further insights into such progress by surveying nonfederal 

GLRI stakeholders. Overall, 87 percent of respondents cited at least one 

example of how one or more of their projects had, or was expected to, benefit the 

Great Lakes ecosystem. GAO and others have reported that quantifying overall 

Great Lakes restoration progress is difficult, that the environmental conditions of 

each lake are unique, and, according to a 2006 U.N. report, it is often impossible 

to attribute specific environmental changes to specific projects or programs. 

In response to GAO’s survey, among the factors respondents most often cited as 

potentially limiting GLRI progress are several outside the scope of the Action 

Plan, such as inadequate infrastructure for wastewater or stormwater and the 

effects of climate change. These factors could negatively affect GLRI restoration 

efforts. For example, as a result of climate change, warming water temperatures

can lead to increased numbers of aquatic invasive species and a decline in 

native ones, a GLRI focus area. The Action Plan touches on these factors but 

does not state how they will be addressed. In 2012, EPA took steps to 

incorporate climate change considerations into a small number of GLRI projects

but has yet to decide if the GLRI will consider climate change impacts on all 

GLRI projects. Without addressing these factors in the next Action Plan, EPA will 

not be able to more fully account for their impacts on GLRI restoration efforts.

View GAO-13-797. For more information, 

contact J. Alfredo Gómez at (202) 512-3841 or 

gomezj@gao.gov.
Page i GAO-13-797 Great Lakes Restoration Initiative

Letter 1 

Background 6

Task Force Agencies Use the Action Plan and Agreements among 

Themselves and with Nonfederal Stakeholders to Implement the 

GLRI 9

EPA’s Methods to Assess GLRI Progress May Not Produce 

Comprehensive and Useful Assessments or Support Program 

Adjustments 17

Task Force Agencies and Nonfederal Stakeholders Report GLRI 

Progress, but Overall Great Lakes Restoration Progress Is 

Difficult to Quantify 33

Nonfederal Stakeholders Identified Key Factors That May Affect 

and May Limit GLRI Progress 44

Conclusions 52

Recommendations for Executive Action 55

Agency Comments and Our Evaluation 56

Appendix I Objectives, Scope, and Methodology 58

Appendix II Comments from the Environment Protection Agency 66

Appendix III Comments from the Department of the Interior 69

Appendix IV Comments from the Department of Agriculture 70

Appendix V Survey Questions 71

Appendix VI Great Lakes Restoration Initiative Action Plan Long-term 

Goals, Objectives, and Measures of Progress for Each of the 

Five Focus Areas 84

Contents 
Page ii GAO-13-797 Great Lakes Restoration Initiative

Appendix VII GAO Contact and Staff Acknowledgments 96

Tables

Table 1: Descriptions of the Five Great Lakes Restoration Initiative 

Action Plan Focus Areas 10

Table 2: Number of Great Lakes Restoration Initiative Projects 

Funded by Task Force Agencies Reported in the Great 

Lakes Accountability System as of May 2013 12

Table 3: Number of Great Lakes Restoration Initiative Projects by 

Focus Area Reported in the Great Lakes Accountability 

System as of May 2013 13

Table 4: Percentage of Great Lakes Restoration Initiative 

Appropriations Allocated, Obligated, and Outlayed for 

Fiscal Years 2010 through 2012, as of July 2013 16

Figures

Figure 1: Area Comprising the Great Lakes Basin 6

Figure 2: Great Lakes Restoration Initiative Allocations by Agency 

in Fiscal Years 2010 through 2013 as of April 2013 14

Figure 3: Great Lakes Restoration Initiative Allocations by Focus 

Area in Fiscal Years 2010 through 2013 as of April 2013 15

Figure 4: Key Elements of the Adaptive Management Process 30

Figure 5: A Depiction of the Mercury Cycle 37

Figure 6: Survey Respondents Rated Factors Outside the Scope of 

the Great Lakes Restoration Initiative Action Plan That 

Have the Potential to Limit the Restoration of the Health 

of the Great Lakes Ecosystem to a Great or Very Great 

Extent 47
Page iii GAO-13-797 Great Lakes Restoration Initiative

Abbreviations

Action Plan Great Lakes Restoration Initiative Action Plan

EPA Environmental Protection Agency

GLAS Great Lakes Accountability System

GLRI Great Lakes Restoration Initiative

GPRA Government Performance and Results Act of 1993

PCB polychlorinated biphenyls

Task Force Great Lakes Interagency Task Force

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Page 1 GAO-13-797 Great Lakes Restoration Initiative

441 G St. N.W.

Washington, DC 20548

September 27, 2013

The Honorable Bill Shuster

Chairman

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Bob Gibbs

Chairman

Subcommittee on Water Resources and Environment

Committee on Transportation and Infrastructure

House of Representatives

The Great Lakes form the largest system of freshwater on earth. They 

contain about 84 percent of North America’s surface freshwater and are 

shared by eight U.S. states—Illinois, Indiana, Michigan, Minnesota, New 

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

Ontario, and more than 40 tribes. The Great Lakes provide a variety of 

recreational, environmental, and economic benefits, including drinking 

water, fishing, swimming, boating, agriculture, industry, and shipping, for 

the more than 30 million people who reside in the Great Lakes Basin, 

which includes the five Great Lakes and the large land area that extends 

beyond the lakes, including their watersheds, tributaries, and connecting 

channels. In addition, a 2011 Michigan Sea Grant study estimated that 

1.5 million jobs in the United States were directly connected to the Great 

Lakes and generated $62 billion in wages in 2009.

1

However, the Great Lakes face significant environmental and public 

health stresses that continue to threaten their future. For example, 

advisories that warn against the consumption of certain fish species have 

been issued for each of the Great Lakes states due to their levels of 

persistent toxic substances, such as mercury. Decades of industrial 

activity in the region have left a legacy of contamination, such as from 

polychlorinated biphenyls (PCB), that resulted in the United States and 

 

1

Lynn Vaccaro and Jennifer Read, Vital to Our Nation’s Economy: Great Lakes Jobs 2011 

Report (Michigan Sea Grant, 2011). Michigan Sea Grant funds scientific research, 

education, and extension projects designed to foster science-based decisions about the 

use and conservation of Great Lakes resources. Michigan Sea Grant also provides access 

to science-based information about Michigan’s coasts and the Great Lakes.

 
 

Page 2 GAO-13-797 Great Lakes Restoration Initiative

Canada identifying, since 1987, a list of 43 severely degraded locations in 

the Great Lakes Basin as areas of concern; 26 of these areas of concern 

are located wholly in the United States, and 5 are shared between the two 

nations. In addition, more than 180 nonnative or “invasive” aquatic 

species have become established in the Great Lakes. Some invasive 

species have caused extensive ecological and economic damage to the 

Great Lakes. The zebra mussel, for example, outcompetes native species 

for resources by removing live animals and algae that other fish eat from 

water bodies, and it blocks pipes that deliver drinking water to cities and 

cooling water to power plants. The Fish and Wildlife Service has 

estimated a potential economic impact of $5 billion from 2000 to 2010 

within the Great Lakes Basin alone. The discovery of Asian carp near 

waterways connected to the lakes threatens to increase this problem.2

In response to these concerns, President Obama proposed $475 million 

in his fiscal year 2010 budget request for a new interagency initiative to 

accelerate the restoration of the Great Lakes. Specifically, the President 

requested that the U.S. Environmental Protection Agency (EPA) and its 

federal partners coordinate state, tribal, local, and industry actions to 

protect, maintain, and restore the integrity of the Great Lakes. The 

Department of the Interior Appropriations Act for fiscal year 2010 

authorized EPA to transfer up to $475 million appropriated for the Great 

Lakes Initiative to any federal agency to carry out activities in support of 

the Great Lakes Restoration Initiative (GLRI).3 The accompanying 

conference report directed EPA to develop a comprehensive, multiyear 

restoration action plan that includes targets and measurable objectives 

from fiscal years 2010 to 2014 that would lead to the restoration of the 

Great Lakes.4

 

2

The term Asian carp refers collectively to four species of carp—including bighead and 

silver carp—that are native to Asia and were first introduced into the United States in 

1963. Their rapid expansion and population increase can decrease populations of native 

aquatic species, in part by consuming vast areas of aquatic plants that are important as 

food and spawning and nursery habitats. 

The conference report also directed EPA to provide 

detailed, yearly program accomplishments starting in 2011 and to develop 

a process that ensures monitoring and reporting on the progress of the 

3

Pub. L. No. 111-88, 123 Stat. 2904, 2938 (2009). For additional information on the Great 

Lakes Initiative, see GAO, Great Lakes Initiative: EPA Needs to Better Ensure the 

Complete and Consistent Implementation of Water Quality Standards, GAO-05-829 

(Washington, D.C.: July 27, 2005).

4

H. R. Rep. No. 111-316, at 111 (2009). 
 

Page 3 GAO-13-797 Great Lakes Restoration Initiative

GLRI. Nearly $300 million was appropriated in both fiscal years 2011 and 

2012 for the GLRI and, according to EPA, about $284 million in fiscal year 

2013, for a total of approximately $1.3 billion since fiscal year 2010.5

The Great Lakes Interagency Task Force (Task Force)—created in May 

2004 by Executive Order 13340—oversees the GLRI.6 The Task Force is 

chaired by the EPA Administrator, and it includes senior officials from the 

U.S. Departments of Agriculture, Commerce, Defense, Health and 

Human Services, Homeland Security, Housing and Urban Development, 

the Interior, State, and Transportation and the White House Council on 

Environmental Quality. The GLRI is implemented by EPA’s Great Lakes 

National Program Office in conjunction with subagencies within the 11 

Task Force agencies.7 EPA and the other Task Force agencies issued 

the Great Lakes Restoration Initiative Action Plan Fiscal Years 2010-2014

(Action Plan) in February 2010.8

Both our work and that of EPA’s Office of the Inspector General have 

documented concerns about Great Lakes restoration efforts in the past. 

For example, we reported in May 2002 that the pace of cleaning up the 

Great Lakes and restoring areas of concern was slower than anticipated 

In addition, EPA created the Great Lakes 

Accountability System (GLAS) as a mechanism for collecting information 

to monitor GLRI projects and progress.

 

5

The amounts appropriated are approximate because of across the board rescissions and 

other adjustments. 

6

Executive Order 13340, Establishment of Great Lakes Interagency Task Force and 

Promotion of a Regional Collaboration of National Significance for the Great Lakes, 69 

Fed. Reg. 29043 (May 20, 2004).

7

The subagencies within the Task Force agencies that are responsible for implementing 

the GLRI are: the Department of Agriculture’s Animal and Plant Health Inspection Service, 

Forest Service, and Natural Resources Conservation Service; the Department of 

Commerce’s National Oceanic and Atmospheric Administration; the Department of 

Defense’s U.S. Army Corps of Engineers; the Department of Health and Human Services’ 

Agency for Toxic Substances and Disease Registry; the Department of Homeland 

Security’s Coast Guard; the Department of the Interior’s Bureau of Indian Affairs, Fish and 

Wildlife Service, National Park Service, and U.S. Geological Survey; and the Department 

of Transportation’s Federal Highway Administration and Maritime Administration. We refer 

to all 16 Task Force agencies and subagencies collectively as Task Force agencies in this 

report, as is the case on the GLRI website http://greatlakesrestoration.us/priorities.html. 

8

Great Lakes Interagency Task Force, Great Lakes Restoration Initiative Action Plan 

Fiscal Years 2010-2014, 09-P-0231 (Washington, D.C.: Feb. 21, 2010.)
 

Page 4 GAO-13-797 Great Lakes Restoration Initiative

by the United States and Canada.9 In September 2004, we found that 

EPA monitoring efforts did not provide comprehensive information on the 

condition of the Great Lakes and that monitoring by other federal and 

state agencies yielded information that that did not cover all areas related 

to the condition of the Great Lakes or the entire Great Lakes Basin.10 In 

September 2009, EPA’s Office of the Inspector General reported that 

EPA had not developed an effective management framework to clean up 

contaminated sediments in the Great Lakes areas of concern.11

In light of these past issues and the significant federal funds targeted 

toward addressing Great Lakes issues, you asked us to review the GLRI. 

This report examines (1) how the GLRI is implemented by the Task Force 

agencies and other stakeholders; (2) the methods that EPA has in place 

to assess GLRI progress; (3) the progress identified by the Task Force 

agencies and nonfederal stakeholders; and (4) the views of nonfederal 

stakeholders on factors, if any, that may affect or limit GLRI progress.

To examine how Task Force agencies and other stakeholders implement 

the GLRI and identify methods that EPA has in place to assess GLRI 

progress, we analyzed key documents including the Action Plan, EPA’s 

GLRI financial reports, and information about GLRI projects from GLAS. 

In addition, we interviewed federal stakeholders—officials from each Task 

Force agency and relevant subagencies responsible for implementing the 

GLRI—and nonfederal stakeholders; specifically, representatives from 

state and local governments, tribes, nongovernmental organizations—

such as the Nature Conservancy and the Great Lakes Indian Fish and 

Wildlife Commission—and academic institutions that that have received 

GLRI funds to gain an understanding of the GLRI and how it is 

 

9

GAO, Great Lakes: EPA Needs to Define Organizational Responsibilities Better for 

Effective Oversight and Cleanup of Contaminated Areas, GAO-02-563 (Washington, D.C.: 

May 17, 2002). No area of concern had had its designation removed—that is, been 

delisted—by May 17, 2002. EPA has since delisted two areas of concern, one before the 

creation of the GLRI, in 2006, and one after the creation of the GLRI, in 2013.

10GAO, Great Lakes: Organizational Leadership and Restoration Goals Need to Be Better 

Defined for Monitoring Restoration Progress, GAO-04-1024 (Washington, D.C.: Sept. 28, 

2004). 

11EPA Office of the Inspector General, EPA Needs a Cohesive Plan to Clean Up the 

Great Lakes Areas of Concern (Washington, D.C.: Sept. 14, 2009).
 

Page 5 GAO-13-797 Great Lakes Restoration Initiative

implemented.12

To examine the progress identified by the Task Force agencies and 

nonfederal stakeholders and the views of nonfederal stakeholders on 

factors, if any, that may affect or limit GLRI progress, we reviewed key 

documents detailing Great Lakes restoration efforts. We also 

administered a web-based survey to each of the 205 nonfederal 

stakeholders that, as of October 2012, had received GLRI funds from a 

Task Force agency and had a project identified in GLAS. We conducted 

this survey to identify examples of GLRI progress and obtain stakeholder 

views on factors that might limit progress. Of the 205 stakeholders 

contacted, 176 completed the survey, for an overall response rate of 86 

percent. We also asked the 21 subject matter experts we interviewed to 

provide their views about factors that may limit GLRI progress. Appendix I 

presents a more detailed description of our objectives, scope, and 

methodology.

We also interviewed representatives from a prominent 

Great Lakes interest group, the Healing Our Waters – Great Lakes 

Coalition, that has not received GLRI funds. We visited GLRI projects, 

and attended the Eighth Annual Great Lakes Restoration Conference in 

Cleveland in September 2012. In addition, we interviewed a 

nonprobability sample of 21 individuals with expertise in Great Lakes’ 

subject matter to obtain their views about the Action Plan and Great 

Lakes restoration. The 21 subject matter experts who participated in 

these interviews included officials from state agencies, members of 

academia, and nongovernmental organizations. We selected these 

experts in part through recommendations made by nonfederal attendees 

at the Great Lakes Restoration Conference. Because we used a 

nonprobability sample, the information obtained from these interviews is 

not generalizable to other individuals with Great Lakes-related expertise 

but provides illustrative information.

We conducted this performance audit from June 2012 to September 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

 

12We did not include the Department of Housing and Urban Development because 

officials from that agency and EPA told us that it has not been involved with the Task 

Force or the GLRI. 
 

Page 6 GAO-13-797 Great Lakes Restoration Initiative

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The Great Lakes Basin spans more than 750 miles from east to west and, 

as shown in figure 1, encompasses nearly all of Michigan, and parts of 

Illinois, Indiana, Minnesota, New York, Ohio, Pennsylvania, Wisconsin, 

and Ontario, Canada. The U.S. shoreline along the five Great Lakes—

Erie, Huron, Michigan, Ontario, and Superior—is approximately 4,530 

miles long, which is more than 2,000 miles longer than the U.S. coastline 

on the Atlantic Ocean.

Figure 1: Area Comprising the Great Lakes Basin

Numerous stresses threaten the health of the lakes themselves and the 

adjacent land within the Great Lakes Basin. For example, Asian carp 

threaten commercial and recreational fisheries in the Great Lakes 

because they tend to outcompete native fish for resources and modify 

habitat. In addition, despite progress in reducing the amount of 

Background 
 

Page 7 GAO-13-797 Great Lakes Restoration Initiative

phosphorus in the lakes achieved through mitigation techniques 

implemented in the 1970s, harmful algal blooms are once again 

threatening the Great Lakes Basin.13

The United States has taken several steps to restore the health of the 

Great Lakes ecosystem during the last four decades. Examples are as 

follows:

• In 1972, the United States and Canada signed the first binational 

Great Lakes Water Quality Agreement with the goal of restoring and 

maintaining the chemical, physical, and biological integrity of the 

Great Lakes Basin. The parties signed another Great Lakes Water 

Quality Agreement in 1978 that was amended in 1983, 1987, and in 

2012. The 1987 amendment resulted in the formal identification of 

specific areas of concern, which were defined as geographic areas 

where a change in the chemical, physical, or biological integrity of the 

area is sufficient to cause restrictions on fish and wildlife or drinking 

water consumption, or the loss of fish and wildlife habitat, among 

other conditions, or impair the area’s ability to support aquatic life.14

The 2012 amendment contains provisions for addressing the 

nearshore environment, 15

• In 2002, the Great Lakes Legacy Act authorized EPA to, among other 

things, carry out sediment remediation projects and to conduct 

sediment contamination remediation research in areas of concern in 

the Great Lakes.

aquatic invasive species, habitat 

degradation, and the effects of climate change, among other things.

16

 

13According to EPA, phosphorus is a nutrient that controls the amount of algae that will 

grow suspended in water, and increases in phosphorus can result in increases in algae, 

which can be detrimental to aquatic life by reducing the amount of available oxygen and 

sunlight, among other things. 

14For a complete list of area of concern conditions, click

http://www.ijc.org/rel/boards/annex2/buis.htm.

15The aquatic nearshore can be considered to begin at the shoreline and extend offshore 

to the depth at which the warm surface waters typically reach the bottom in early fall, 

generally 20 to 30 meters deep (i.e., 65 feet 7.4 inches to 98 feet 5.1 inches). Terrestrial 

nearshore areas range from narrow beaches to inland features affected by lake water. 

16Pub. L. No. 107-303, 116 Stat. 2355 (2002). Congress consolidated funding for the 

Great Lakes Legacy Act under the GLRI in 2009. See H. R. Rep. No. 111-316, at 110

(2009).
 

Page 8 GAO-13-797 Great Lakes Restoration Initiative

• In 2004, the Task Force agencies collaborated with Great Lakes 

governors, mayors, tribes, and nongovernmental organizations in an 

effort referred to as the Great Lakes Regional Collaboration, which led 

to the development in 2005 of the Great Lakes Regional Collaboration 

Strategy to Restore and Protect the Great Lakes.

17 More than 1,500 

individuals participated in this effort. A 2007 Brookings Institution 

report estimated that the $26 billion dollar investment necessary to 

implement this strategy would have resulted in $30 to $50 billion in 

short-term benefits to the regional economy and at least $50 billion in 

the long term.18

Even with these actions, the Great Lakes are environmentally vulnerable. 

In 2009, the President requested and Congress appropriated $475 million 

for fiscal year 2010 to create the GLRI. The accompanying conference 

report directed EPA to develop a GLRI Action Plan and to ensure that the 

GLRI funds supplement and expand, not supplant, federal agency Great 

Lakes programs.19 EPA and the Task Force agencies issued the Action 

Plan in February 2010 to guide the implementation of the GLRI. 

According to the Action Plan, the GLRI is intended to build on previous 

restoration strategies to develop a collaborative approach to restoring the 

health of the Great Lakes ecosystem. The conference report also directed 

EPA to engage an independent, scientific panel to review the scientific 

credibility of the plan to optimize the likelihood of successful restoration at 

appropriate scales.20 In response, EPA engaged its Science Advisory 

Board to conduct a review of the Action Plan.21

 

17Great Lakes Regional Collaboration, Great Lakes Regional Collaboration Strategy to 

Restore and Protect the Great Lakes (December 2005).

Among other things, the 

Science Advisory Board recommended that EPA take steps to develop an 

18Austin et al., Healthy Waters, Strong Economy: The Benefits of Restoring the Great 

Lakes Ecosystem (Washington, D.C.: The Brookings Institution, September 2007).

19H. R. Rep. No. 111-316, at 110-11 (2009). 

20H. R. Rep. No. 111-316, at 111 (2009). 

21A 1977 law required EPA to establish a Science Advisory Board to provide scientific 

advice on a variety of matters. The board, which is a federal advisory committee, has 

established several standing committees, including the Ecological Processes and Effects 

Committee. 
 

Page 9 GAO-13-797 Great Lakes Restoration Initiative

adaptive management framework for the GLRI and noted that EPA 

should consider potential impacts of climate change on restoration.22

In March 2013, the Chair of the Council on Environmental Quality 

announced that the administration is committing to another 5-year GLRI 

Action Plan, for fiscal years 2015 to 2019. In May 2013, EPA and the 

Task Force agencies began conducting public meetings and webinars to 

obtain comments on how the Action Plan could be refined to increase the 

effectiveness of GLRI investments during the next phase of the Action 

Plan.

The Task Force agencies use the Action Plan to guide implementation of 

the GLRI. They also use an interagency process to identify and transfer 

funds to GLRI work, and to enter into agreements among themselves and 

with nonfederal stakeholders to identify and implement GLRI projects, or 

they do the work themselves.

The Task Force agencies use the Action Plan to guide implementation of 

the GLRI. The Action Plan is organized into five focus areas that, 

according to the Task Force agencies, encompass the most significant 

environmental problems in the Great Lakes: (1) toxic substances and 

areas of concern; (2) invasive species; (3) nearshore health and nonpoint 

source pollution; (4) habitat and wildlife protection and restoration; and (5) 

accountability, education, monitoring, evaluation, communication, and 

partnerships. Table 1 describes each focus area.

 

22EPA Science Advisory Board, Review of Great Lakes Restoration Initiative Action Plan

(Washington, D.C.: Jan. 24, 2012). 

Task Force Agencies 

Use the Action Plan 

and Agreements 

among Themselves 

and with Nonfederal 

Stakeholders to 

Implement the GLRI

Task Force Agencies Use 

the Action Plan to 

Implement the GLRI
 

Page 10 GAO-13-797 Great Lakes Restoration Initiative

Table 1: Descriptions of the Five Great Lakes Restoration Initiative Action Plan Focus Areas 

Focus area Description 

Toxic substances and areas of concern Includes pollution prevention and cleanup of the most polluted areas in the Great 

Lakes 

Invasive species Includes efforts to institute a “zero tolerance policy” toward new invasions of nonnative species, such as Asian carp 

Nearshore health and nonpoint source pollution Includes targeted geographic focus on high-priority watersheds and reducing 

polluted runoff from urban, suburban, and agricultural sources 

Habitat and wildlife protection and restoration Includes revitalizing wetlands and other habitat, and a comprehensive 

assessment of the entire Great Lakes coastal wetlands for the purpose of 

strategically targeting restoration and protection efforts in a science-based 

manner 

Accountability, education, monitoring, evaluation, 

communication, and partnerships

Includes the implementation of goal- and results-based accountability measures, 

learning initiatives, outreach, and strategic partnerships 

Source: GAO analysis of Great Lakes Restoration Initiative Action Plan.

Each focus area includes a description of its stresses and several longterm goals to address them. For example, one long-term goal in the 

invasive species focus area is to eliminate the introduction of new 

invasive species to the Great Lakes Basin. In addition, each focus area 

includes a number of objectives to be completed within the 5-year period 

covered by the Action Plan. For example, in the habitat and wildlife 

protection and restoration focus area, one objective is to assess 100 

percent of U.S. coastal wetlands in the Great Lakes Basin by 2014.

The focus areas also include measures of progress—28 in total—each of 

which has annual targets for fiscal years 2010 to 2014 that are designed 

to ensure that efforts are on track to meet the long-term goals. Some of 

the measures address environmental conditions. For example, one 

measure for the habitat and wildlife protection and restoration focus area 

addresses the number of fish passage barriers that are to be removed or 

bypassed annually for the period of time covered by the Action Plan. The 

annual targets for the measure are the removal or bypassing of 100 

barriers in 2010, 150 in 2011, 250 in 2012, 350 in 2013, and 450 barriers 

in 2014.

The last part of each focus area is the principal actions, broad statements 

of the most significant activities that EPA and its federal partners 

conclude need to be done in order to achieve the goals, objectives, and 

targets in the Action Plan. For example, a principal action for the invasive 

species focus area is to promote the development and use of new control 

technologies, including biological control methods, that will significantly 
 

Page 11 GAO-13-797 Great Lakes Restoration Initiative

reduce the cost or increase the effectiveness of invasive species control 

measures.

See appendix VI for a complete list of the Action Plan long-term goals, 

objectives, and measures of progress.

The Task Force agencies identify the GLRI projects they plan to 

implement through an interagency process. EPA and the other Task 

Force agencies then enter into interagency agreements that describe the 

scope of the GLRI work that is to be undertaken and the amount of GLRI 

funds EPA will transfer to the Task Force agency doing that work.

The Task Force agencies and nonfederal stakeholders have started more 

than 1,450 GLRI projects since the program began.23 GLRI projects can 

range in size from 0.25 acres for a fish spawning project to 10 million 

acres for a project to update habitat and wetland maps to identify 

sensitive and restorable wetlands across the basin. These projects may 

take place in one location or across multiple states within the Great Lakes 

Basin. GLRI projects have also ranged in cost from $3,000 to protect 

nesting piping plovers to $60.5 million to address contaminated sediment 

in multiple areas of concern.24

 

23For the purpose of this report, we are counting only those projects that were identified in 

GLAS in May 2013. It is the case that some projects identified in GLAS comprise multiple 

efforts that are reported as a greater number of separate projects at the GLRI website, 

Many GLRI projects take several years to 

complete and, as a result, many projects funded in fiscal years 2010 to 

2012 are still under way. For example, approximately 64 percent of the 

fiscal year 2010 to 2012 projects reported in GLAS were at least half 

completed as of May 2013. Tables 2 and 3 show the number of projects 

http://glri.us/projects/index.html. According to an EPA official, some Task Force agencies 

may report these individual efforts on the website to provide more comprehensive 

information on GLRI activities to the public. In May 2013, there were 1,534 GLRI projects 

identified on the website. 

24The piping plover is a small shore bird that uses open sandy beaches for its habitat. The 

piping plover in the Great Lakes watershed was listed as endangered under the 

Endangered Species Act in 1985. 

Task Force Agencies Use 

Interagency Process to 

Identify and Fund GLRI 

Work
 

Page 12 GAO-13-797 Great Lakes Restoration Initiative

funded by Task Force agency and by focus area as of May 2013, 

respectively.25

Table 2: Number of Great Lakes Restoration Initiative Projects Funded by Task Force Agencies Reported in the Great Lakes 

Accountability System as of May 2013

Agency Subagency Number of projects

Environmental Protection Agency 498 

Department of the Interior Fish and Wildlife Service 379 

U.S. Geological Survey 75 

Bureau of Indian Affairs 33 

National Park Service 31 

Department of Defense U.S. Army Corps of Engineers 244 

Department of Commerce National Oceanic and Atmospheric Administration 113

Department of Agriculture Forest Service 37 

Natural Resources Conservation Service 18 

Animal and Plant Health Inspection Service 18 

Department of Homeland Security U.S. Coast Guard 19

Department of Transportation Federal Highway Administration 7 

Maritime Administration 4 

Department of Health and Human Services Agency for Toxic Substances and Disease Registry 5 

Council on Environmental Quality 2 

Total 1,483

Source: GAO analysis of EPA data.

 

25The total number of GLRI projects identified by Task Force agency in table 2, 1,483, is 

less than the number of GLRI projects identified by focus area in table 3, 1,487, because 4 

GLRI projects are funded by two federal subagencies that were not identified as Task 

Force agencies and, therefore, are not included in table 2. These subagencies are the 

Department of Agriculture’s Cooperative State Research, Education, and Extension 

Service and the Department of Health and Human Service’s Federal Occupational Health.
 

Page 13 GAO-13-797 Great Lakes Restoration Initiative

Table 3: Number of Great Lakes Restoration Initiative Projects by Focus Area 

Reported in the Great Lakes Accountability System as of May 2013

Focus area

Number of 

projects

Toxic substances and areas of concern 235

Invasive species 192

Nearshore health and nonpoint source pollution 247

Habitat and wildlife protection and restoration 630

Accountability, education, monitoring, evaluation, communication, 

and partnerships

183

Total 1,487

Source: GAO analysis of EPA data.

Although we did not break down GLRI funding per project in detail, some 

Task Force agency officials told us that they use a small percentage of 

that funding for administrative tasks. For example, officials from one Task 

Force agency told us that they used 5 percent of GLRI funds for one 

agency project for overhead and indirect costs. In this case, the agency 

performs laboratory and monitoring work that the nonfederal stakeholders 

that implement the project do not have the capacity to do. As shown in 

figures 2 and 3, most GLRI funding has been utilized by EPA, the 

Department of the Interior’s Fish and Wildlife Service, and the U.S. Army 

Corps of Engineers, and focus area one—toxic substances and areas of 

concern—has received more GLRI funding than the other focus areas in 

each of the past 4 years.
 

Page 14 GAO-13-797 Great Lakes Restoration Initiative

Figure 2: Great Lakes Restoration Initiative Allocations by Agency in Fiscal Years 2010 through 2013 as of April 2013

Note: In addition to funding Great Lakes Restoration Initiative (GLRI) projects, EPA uses its GLRI 

funds for, among other things, Great Lakes Legacy Act projects and GLRI funding for the Great Lakes 

Fishery Commission and International Joint Commission. The Great Lakes Fishery Commission and 

International Joint Commission are binational efforts supported by the Department of State. The 

Great Lakes Fishery Commission works to sustain productivity of fish stocks of U.S. and Canadian 

concern in the Great Lakes, among other things, and the International Joint Commission assists the 

United States and Canada in the protection of the transboundary environment in part through the 

implementation of the Great Lakes Water Quality Agreement, among other things.
 

Page 15 GAO-13-797 Great Lakes Restoration Initiative

Figure 3: Great Lakes Restoration Initiative Allocations by Focus Area in Fiscal 

Years 2010 through 2013 as of April 2013

EPA and the Task Force agencies have 2 years to obligate GLRI funds, 

which means that the amounts allocated in fiscal years 2010 and 2011 

are not likely to change, but fiscal year 2012 and 2013 amounts may 

change as the period for obligating those funds comes to an end. In 

addition, while nearly all of the GLRI appropriations from fiscal years 2010 

to 2012 have been obligated, not all of those obligations have been 
 

Page 16 GAO-13-797 Great Lakes Restoration Initiative

outlayed because many GLRI projects take several years to complete.26

Table 4: Percentage of Great Lakes Restoration Initiative Appropriations Allocated, 

Obligated, and Outlayed for Fiscal Years 2010 through 2012, as of July 2013

Table 4 shows the extent to which GLRI appropriations for fiscal years 

2010 to 2012 have been obligated and outlayed as of July 2013.

Dollar in millions

Appropriations allocated, 

obligated, and outlayed

Fiscal year 

2010

Fiscal year 

2011

Fiscal year 

2012

Appropriations $475 $300 $300 

Percentage of appropriations 

allocated 100% 99.8% 99.84%

Percentage of appropriations 

obligated 99.74% 99.74% 98.42%

Percentage of appropriations 

outlayed 79.53% 63.12% 28.17%

Source: GAO analysis of EPA information.

Note: Appropriation amounts are approximate and do not reflect across the board rescissions and 

other adjustments. 

After EPA and the Task Force agencies have agreed to the GLRI fund 

transfers to each agency and the work that will be done, each agency 

either does the work itself or implements it through mechanisms such as 

cooperative agreements, contracts, or grants with nonfederal 

stakeholders. In the case of GLRI grants, a Task Force agency 

announces the availability of the grants through a request for application 

process. For example, EPA announced on April 19, 2012, that the agency 

planned to award approximately $20 million for about 100 projects in four 

 

26Appropriations represent budget authority to incur obligations and make payments from 

the U.S. Treasury for specified purposes. For budgeting purposes, an allocation means an 

authorized delegation by one agency of its authority to obligate budget authority and 

outlay funds to another agency, and it is made when one or more agencies share the 

administration of a program for which appropriations are made to only one of the 

agencies. For funds controls purpose, an allocation is a subdivision of an apportionment, 

which divides the amount available for obligation in an appropriation. Obligations are 

definite commitments that create a legal liability of the government for the payment of 

goods and services ordered or received, or a legal duty on the part of the United States 

that could mature into a legal liability by virtue of actions on the part of the other party 

beyond the control of the United States. Outlays are the issuance of checks, disbursement 

of cash, or electronic transfer of funds made to liquidate a federal obligation. See GAO, A 

Glossary of Terms Used in the Federal Budget Process, GAO-05-734SP (Washington, 

D.C.: Sept. 1, 2005).
 

Page 17 GAO-13-797 Great Lakes Restoration Initiative

of the five focus areas, and that the applications were due on May 24, 

2012.27 The request for application document included the amount of 

money and number of grants that would be awarded in each focus area 

and grant eligibility information, among other things. Similar 

announcements were made by other Task Force agencies for their GLRI 

grants, and EPA issued its first request for applications for fiscal year 

2013 projects in July 2013.

Although EPA uses information from GLAS and a variety of other sources

to assess GLRI progress in meeting the annual targets associated with 

each of the 28 measures of progress in the Action Plan to assess GLRI 

progress, this information may not produce sufficiently comprehensive or 

useful assessments or support program adjustments. Specifically, (1) the 

Action Plan measures of progress currently in place may not provide 

sufficiently comprehensive or useful information and (2) EPA and the 

Task Force agencies have not fully established a plan to guide an 

adaptive management process for the GLRI that could allow them to 

assess the effectiveness of GLRI actions and, if needed, adjust their 

efforts.

EPA assesses GLRI progress primarily by evaluating performance toward 

meeting the annual targets for the 28 measures of progress in the Action 

Plan, which EPA officials said are intended as indicators of success for 

each focus area. Of the 28 measures, 15 are also used in the agency’s 

performance plan and performance report, which are required by the 

Government Performance and Results Act of 1993 (GPRA) as 

amended.28

 

27EPA did not request applications for grants in the habitat and wildlife protection and 

restoration focus area in the agency’s April 19, 2012, request for applications, noting that 

the National Oceanic and Atmospheric Administration and Fish and Wildlife Service would 

be requesting grants in that area that year.

According to EPA officials, the agency sought to develop, in 

consultation with the Office of Management and Budget, a limited set of 

measures that could be used to evaluate GLRI progress on an annual 

28Pub. L. No. 103-62 (1993), amended by GPRA Modernization Act of 2010, Pub. L. No. 

111-352 (2011). GPRA sought to improve the effectiveness and accountability of federal 

programs by requiring federal agencies to set goals for program performance, measure 

results, and report on annual performance compared with the goals. GPRA as amended 

requires, among other things, that federal agencies develop strategic plans. 

EPA’s Methods to 

Assess GLRI Progress 

May Not Produce 

Comprehensive and 

Useful Assessments 

or Support Program 

Adjustments 

EPA Uses the Action Plan 

Measures to Assess GLRI 

Progress
 

Page 18 GAO-13-797 Great Lakes Restoration Initiative

basis. EPA officials said that, in developing the set of measures, they 

considered such factors as the availability of relevant data, the suitability 

of the data for measuring year-to-year changes, a focus on environmental 

outcomes, and the existing federal authorities available to address the 

measure. Officials from EPA and another Task Force agency also told us 

that many of the measures were based on existing baseline information 

and were practical because they used existing agency databases for 

information.

To gauge GLRI progress toward meeting the targets for the measures, 

EPA obtains the data needed using information from GLAS, EPA 

programs, other federal agencies, states, and universities. For example, 

for 7 of the 28 measures of progress, GLAS provides progress data 

specific to individual GLRI projects. In addition, states provide information 

on progress at areas of concern, the National Oceanic and Atmospheric 

Administration provides progress information from a database it manages 

on invasive species in the Great Lakes, and the Fish and Wildlife Service 

provides progress information related to habitat and wildlife protection 

and restoration. In March 2013, the Task Force agencies issued the first 

GLRI progress report to Congress, which identified fiscal year 2011 

progress using the measures for each focus area and described the 

accomplishments of some projects.29 The Task Force agencies also 

issued a report on fiscal year 2010 progress in April 2013.30

Assessments of GLRI progress could help GLRI stakeholders, Congress, 

and the public discern the extent to which the health of the Great Lakes 

ecosystem has been restored, as well as what has been achieved by the 

approximately $1.3 billion appropriated to the program since fiscal year 

2010. However, the Action Plan measures of progress may not provide 

sufficiently comprehensive or useful information on GLRI progress 

because (1) some goals and objectives do not link to any measures that 

will allow EPA to assess progress toward achieving them; (2) the 

measures do not capture the results of many of the GLRI projects; (3) 

 

29EPA in partnership with the Great Lakes Interagency Task Force, Great Lakes 

Restoration Initiative Fiscal Year 2011 Report to Congress and the President

(Washington, D.C.: September 2011). 

30EPA in partnership with the Great Lakes Interagency Task Force, Great Lakes 

Restoration Initiative Fiscal Year 2010 Report to Congress and the President

(Washington, D.C.: March 2011). 

Action Plan Measures of 

Progress May Not Provide 

Sufficiently 

Comprehensive or Useful 

Information 
 

Page 19 GAO-13-797 Great Lakes Restoration Initiative

data used to evaluate some measures of progress may not be complete; 

and (4) some Task Force and state agency officials, subject matter 

experts, and EPA’s Science Advisory Board raised concerns about the 

usefulness of some measures or their targets for indicating progress 

toward the GLRI goals and objectives.

The Action Plan does not identify the links between a focus area’s goals, 

objectives, and measures. Specifically, based on our analysis of the GLRI 

Action Plan, some of the goals and objectives in the Action Plan do not 

link to any measures of progress, which EPA uses to assess GLRI 

progress. For example, one of the goals of the habitat and wildlife 

protection and restoration focus area is that development activities are 

planned and implemented in ways that are sensitive to environmental 

considerations and compatible with fish and wildlife and their habitats. 

However, we found that none of the six objectives and nine measures of 

progress in this focus area link to this goal. Similarly, in its 2012 review of 

the GLRI Action Plan, EPA’s Science Advisory Board commented on the 

ambiguity in the links between the elements of the plan, such as between 

the long-term goals and the objectives. The Science Advisory Board also 

recommended that the Action Plan tie the measures more directly to the 

goals, noting that the more clear and transparent the connection between 

the measures and the goals, the easier it will be to document how well the 

actions are working to meet the goals.

EPA officials told us that the Action Plan was not intended to contain 

direct linkages between every goal, objective, and measure but rather 

that the measures were to serve as key indicators of success for each 

focus area. They said that the rationale for that decision was to provide 

some flexibility, recognizing that not all important restoration work may fall 

within the measures of progress and that the Action Plan does not 

represent the entirety of actions necessary for Great Lakes protection and 

restoration. However, based on our review of documents on planning for 

restoration of natural resources, we believe that clear linkages between a 

plan’s goals, objectives, and measures are critical to achieving and 

assessing progress over time. For example, the National Research 

Council recommended such linkages in its checklist for planning and 

Some GLRI Goals and 

Objectives Do Not Link to Any 

Measures 
 

Page 20 GAO-13-797 Great Lakes Restoration Initiative

evaluating aquatic ecosystem restoration.31 Specifically, the National 

Research Council recommended constructing specific performance 

indicators that are directly and appropriately linked to each objective, 

noting that these performance indicators are specific, measureable 

quantities that reveal to what extent the objectives are being achieved.32

In addition, the Department of the Interior’s 2009 technical guidance on 

managing natural resources emphasizes that, to be useful for decision 

making and evaluation, objectives need to be unambiguous, with specific 

metrics and specific target conditions.33

We recognize that it may not always be feasible or appropriate to identify 

measures for every aspect of each goal or objective. Nonetheless, 

although some objectives in the Action Plan describe quantifiable actions, 

the Action Plan contains no measures of progress for them. For example, 

two Action Plan objectives for the nearshore health and nonpoint source 

pollution focus area state that, by 2014, (1) 50 percent of high priority 

Great Lakes beaches will have been assessed using a standardized 

sanitary survey tool to identify sources of contamination and (2) rapid 

testing or predictive modeling methods (i.e., to improve the accuracy of 

decisions on beach postings to better protect public health) will be 

employed at 33 percent of high-priority beaches. However, because the 

Action Plan contains no measures of progress that link to these 

objectives, it is unclear how EPA will be able to assess annual progress 

toward these and other objectives that do not have linked measures. EPA 

officials told us that they recognize the need to report a more 

comprehensive assessment of objectives and are considering options for 

evaluating and reporting on them.

 

31The National Research Council is the operating arm of the National Academy of 

Sciences and National Academy of Engineering. Its mission is to improve government 

decision making and public policy, increase public understanding, and promote the 

acquisition and dissemination of knowledge in matters involving science, engineering, 

technology, and health. For more information about the National Research Council click 

http://www.nationalacademies.org/nrc/index.html. 

32National Research Council of the National Academies, Committee on Restoration of 

Aquatic Ecosystems: Science, Technology, and Public Policy, Restoration of Aquatic 

Ecosystems: Science, Technology, and Public Policy (Washington, D.C.: National 

Academies Press, 1992).

33B. K. Williams, R. C. Szaro, and C. D. Shapiro, Adaptive Management: The U.S. 

Department of the Interior Technical Guide, Adaptive Management Working Group, U.S. 

Department of the Interior (Washington, D.C.: 2009). 
 

Page 21 GAO-13-797 Great Lakes Restoration Initiative

Many of the projects funded by the GLRI do not have an Action Plan 

measure of progress assigned to them, which means that the results of 

those projects are not captured by the measures. Specifically, nearly 60 

percent of the more than 1,450 GLRI projects reported in GLAS as of May 

2013 did not have an associated Action Plan measure of progress. One 

reason for this is that, according to a Task Force agency, some projects 

contribute to the Action Plan measures but are not the type of on-theground restoration projects that are addressed by most of the measures 

of progress. Officials from the U.S. Geological Survey told us that this is 

the case for much of their agency’s GLRI work. For example, the 

agency’s work has included efforts to develop new methods of controlling 

phragmites, an invasive plant.34

According to EPA officials, projects without assigned measures address 

the Action Plan goals, objectives, or principal actions; the reason these 

projects do not have measures assigned to them is that they do not 

directly provide data for any of the Action Plan’s 28 measures. They told 

us that they monitor the results of individual projects through standard 

agency practices, but that they are not currently tracking cumulative 

results that are not addressed by an Action Plan measure of progress. 

According to agency officials, future GLRI progress assessments may 

capture more information. Specifically, they said that the cumulative 

results of some of the projects without assigned measures of progress 

may ultimately be captured by some of the existing measures. We 

recognize that this may be the case for some projects. For example, 

projects to restore native fish habitat that do not have assigned measures 

of progress could help lead to progress over time toward the measure 

that addresses the percentage of native aquatic species populations that 

are self-sustaining in the wild. However, a cumulative approach may not 

allow EPA to capture specific progress information from those projects 

This work contributes toward the Action 

Plan’s objective of developing or refining and pilot testing five 

technologies to contain or control invasive species by 2014. However, 

there is no linked measure of progress for this objective or assigned to 

the project. As a result, EPA’s progress assessments may inaccurately 

capture the extent of progress being made toward containing or 

controlling invasive species.

 

34Phragmites australis, or common reed, is a perennial grass now common in North 

American wetlands. Invasive phragmites create tall, dense stands that degrade wetlands 

and coastal areas by crowding out native plants and animals, blocking shoreline views, 

and reducing access for swimming, fishing, and hunting. 

Measures Do Not Capture the 

Results of Many GLRI Projects
 

Page 22 GAO-13-797 Great Lakes Restoration Initiative

without measures, and EPA uses the measures to assess GLRI progress 

and has been directed to report on that progress annually. As we reported 

in November 2002, one attribute of successful performance assessment 

is that there should be enough measures to ensure that an agency has 

the information it needs about project performance.35

Data used to evaluate some measures of progress may not be complete 

because GLAS users are limited to reporting progress using a single 

measure, and GLRI projects may directly address multiple measures 

across different focus areas. We found that 7 of the 28 measures of 

progress are tracked primarily in GLAS and, as we noted previously, EPA 

uses information from GLAS, as well as other sources, to gauge GLRI 

progress toward meeting the targets for the measures. Officials from five 

Task Force agencies told us that this is a significant limitation that can 

result in underreporting of progress. For example, a National Park Service 

GLRI project has involved managing acres for invasive species, which is 

one measure, as well as outreach to the public on practices that prevent 

the introduction and spread of invasive species, which is another 

measure. However, GLAS requires the agency to choose only one of 

these measures for reporting progress. EPA officials told us that GLAS 

users are restricted to reporting on a single measure due primarily to a 

decision by EPA to simplify the reporting process during the initial stages 

of the GLRI. Agency officials said that this decision was made for several 

reasons, including concerns about double-counting and overreporting, a 

desire to minimize the reporting burden for GLAS users and EPA, and the 

need to ensure appropriate data quality review before making the 

progress information public. They said that the current design of GLAS 

reflects this decision and that system modifications would be necessary to 

allow reporting on multiple measures. However, by limiting users to 

reporting information on only a single measure for each project, GLAS 

prevents EPA from collecting complete progress information on GLRI 

projects—that is, information on each of the measures addressed by 

GLRI projects. As we noted previously, there should be enough measures 

to ensure that an agency has the information it needs to assess project 

performance. Without collecting information about the multiple measures 

Without methods to 

include the results of such projects, EPA cannot ensure that the agency is 

assessing the full extent of progress being made.

 

35For information on attributes of successful performance measures, see GAO, Tax 

Administration: IRS Needs to Further Refine Its Tax Filing Season Performance 

Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002).

Data Used to Evaluate Some 

Measures of Progress May Not 

Be Complete
 

Page 23 GAO-13-797 Great Lakes Restoration Initiative

affected by a project, the data EPA is using for certain measures of 

progress cannot be complete, and EPA is likely underreporting progress 

for these measures.

EPA officials told us that they began to address this issue in fiscal year 

2012 for two complementary measures in the habitat and wildlife 

protection and restoration focus area, the miles of rivers reopened for fish 

passage, and the number of fish passage barriers removed or bypassed. 

Specifically, EPA has begun asking GLRI funding recipients reporting on 

one of these measures to indicate progress, if any, on the complementary 

measure. This effort will help EPA obtain more complete information on 

these two measures, but it does not address the broader reporting 

limitation in GLAS, which EPA officials told us may result in 

underreporting of progress for certain measures. EPA officials told us that 

they will consider addressing this limitation in GLAS, but they did not 

indicate a time frame for doing so.

In addition, although EPA officials told us that they have concerns about 

the quality of GLRI progress information in GLAS, they have not fully 

assessed the quality of that information, such as its completeness, 

accuracy, and consistency. As a result, the agency has not made this 

information available to the public. While practices required under GPRA, 

as amended, are required at the federal department or agency level, we 

have previously reported that these requirements can serve as leading 

practices for planning at lower levels within federal agencies, such as 

individual programs or initiatives.36 Thus, EPA is not required to address 

requirements under GPRA, as amended, for GLAS, but by following 

them, the agency would be implementing leading practices. The GPRA 

Modernization Act of 2010 requires, among other things, that agency 

performance plans and reports describe how the agency ensures the 

reliability of the data used to measure progress toward its performance 

goals, including how it verifies and validates measured values of 

performance and compensates for any limitations to the data to reach the 

required level of accuracy.37

 

36See, for example, GAO, Environmental Justice: EPA Needs to Take Additional Actions 

to Help Ensure Effective Implementation, 

Verification includes the assessment of data 

GAO-12-77 (Washington, D.C.: Oct. 6, 2011). 

37Pub. L. No. 111-352, §§ 3-4 (2011). Prior to this amendment, the Government 

Performance and Results Act of 1993 also required agency performance plans to describe 

the means to be used to verify and validate measured values of performance. Pub. L. No. 

103-62, § 4(b) (1993).
 

Page 24 GAO-13-797 Great Lakes Restoration Initiative

completeness, accuracy, and consistency to ensure that the data will be 

of sufficient quality to document performance and support decision 

making.38

GLRI funding recipients are responsible for entering information about the 

progress of their GLRI projects directly into GLAS, and EPA has methods 

in place to review this information on a project-by-project basis. For 

example, EPA has developed a plan for managing the grants, interagency 

agreements, and contracts the agency awards for GLRI projects. 

According to agency officials, this plan synthesizes existing agency 

standards and policies and itemizes the activities to be undertaken by 

project officers and others to ensure an effective grant oversight process. 

Among other things, this plan specifies that, for interagency agreements, 

EPA officials who are GLRI project officers will review progress reports 

submitted by GLRI funding recipients and that the project officers will 

compare the information in those reports to the information entered in 

GLAS.

 In light of this and EPA’s concerns about the quality of the GLRI 

progress data in GLAS, we also have concerns about the use of these 

data for measuring progress toward the Action Plan goals and objectives.

39

However, EPA officials noted that they believe there are overall 

consistency issues with the progress information grantees enter in GLAS, 

and that there could be underreporting of progress for certain measures 

when they are being achieved by a large number of projects or 

stakeholders. However, the officials told us that they have not yet taken 

steps to identify the progress information in GLAS that may be 

incomplete, incorrect, or inconsistently entered by GLRI funding 

recipients. As a result, EPA’s ability to reliably assess progress toward 

the targets for the seven measures tracked primarily in GLAS is 

questionable. EPA officials told us that they recognize the need to 

improve GLAS and that they are beginning efforts to review the system, 

including assessing their data quality and review procedures and 

According to EPA officials, project officers for grants are also 

expected to compare information in progress reports with information in 

GLAS.

 

38GAO, Performance Plans: Selected Approaches for Verification and Validation of 

Agency Performance Information, GAO-GGD-99-139 (Washington, D.C.: July 30, 1999). 

39GLRI funding recipients are required to submit semiannual progress reports to EPA. 

According to EPA officials, they do not use these project reports to assess GLRI progress. 

This is because the progress reports are for administrative management purposes and not 

for reporting progress made toward the Action Plan measures. 
 

Page 25 GAO-13-797 Great Lakes Restoration Initiative

identifying improvements. The officials noted that they are also 

considering whether GLAS is the right tool for the GLRI. EPA officials had 

not determined a time frame for this work as of June 2013.

Some Task Force and state agency officials, subject matter experts, and 

EPA’s Science Advisory Board, raised concerns that certain measures of 

progress or their targets may not be useful for indicating GLRI progress 

toward the Action Plan’s goals and objectives.

Climatic factors may affect the usefulness of some measures. Five of the 

six measures of progress for the nearshore health and nonpoint source 

pollution focus area may not be useful for indicating GLRI progress over 

the short term toward the Action Plan’s goals and objectives. Specifically, 

EPA officials and others have noted that these measures address 

environmental conditions that are influenced by climatic factors, such as 

precipitation and wind patterns. These factors make it difficult to identify 

whether the restoration efforts are having the desired effects. For 

example, one of the measures of progress in the Action Plan for this 

focus area tracks the square miles of harmful algal blooms in the Great 

Lakes. According to information from EPA officials, such algal blooms are 

influenced by climatic factors such as precipitation patterns, water 

temperature, and wind speed and direction. Officials from another Task 

Force agency also told us that because of factors such as weather that 

cannot be controlled, the extent of algal blooms in any given year is not 

directly related to the management actions being taken in the GLRI and, 

as a result, the measure is not useful for indicating GLRI progress toward 

the Action Plan’s goals and objectives. EPA officials told us that, given 

the short period of time the GLRI has been under way, factors such as 

temperature and the amount and timing of precipitation are currently the 

primary factors affecting the extent of algal bloom. Officials also told us 

that, over the long term, management actions will lead to lower 

phosphorous levels, which will have a minimizing affect on the extent of 

such algal blooms. However, over the short term, this measure may not 

be useful for indicating GLRI progress toward the focus area’s objective 

of significantly reducing the number and severity of incidences of harmful 

algal blooms by 2014. In addition, we have previously reported criteria for 

determining the extent to which an agency’s performance plan provides a 

clear picture of intended performance, including that measures must 

clearly represent or be related to the performance they are trying to 

Some Measures or Their 

Targets May Not Be Indicative 

of Progress 
 

Page 26 GAO-13-797 Great Lakes Restoration Initiative

assess.40

Some measures track actions that may not be sufficient to lead to the 

desired GLRI goals. For example, one of the goals for the toxic 

substances and areas of concern focus area is that environmental levels 

of toxic chemicals are reduced to the point that all restrictions on the 

consumption of Great Lakes fish can be lifted. A measure of progress that 

links to this goal tracks the long-term reduction in average concentrations 

of PCBs in Great Lakes fish. However, officials from two Task Force 

agencies and two state agencies, as well as five subject matter experts, 

reported that the measure’s focus on PCBs is too narrow and that other 

contaminants, particularly mercury, need to be addressed as well. EPA’s 

Science Advisory Board also noted this narrow focus in its 2012 review of 

the Action Plan. Mercury is important because, according to a 2011 

binational study of mercury in the Great Lakes region, it has widely 

contaminated the region and has been responsible for fish consumption 

advisories in the eight Great Lakes states and the Canadian province of 

Ontario.

Therefore, measures that track conditions that are not directly 

related to management actions being taken may not be useful for 

indicating GLRI progress toward the Action Plan’s goals and objectives. 

While we recognize that the Action Plan is not a performance plan, using 

criteria intended for performance plans is appropriate because EPA uses 

the Action Plan’s measures of progress to assess GLRI progress as an 

agency would use the measures in a performance plan.

41

 

40For information on criteria for determining the extent to which an agency’s performance 

plan provides a clear picture of intended performance, see GAO, The Results Act: An 

Evaluator’s Guide to Assessing Agency Performance Plans

The study concluded that mercury, largely due to atmospheric 

emissions from coal-fired power plants, remains a pollutant of major 

concern with an impact on fish in the region that is much greater than 

previously recognized. Consequently, reducing average concentrations of 

PCBs in fish is not likely to lead to lifting all restrictions on the 

consumption of Great Lakes fish. Because this measure does not clearly 

represent all of the contaminants that need to be addressed, it may not be 

useful for indicating GLRI progress toward the Action Plan’s goals and 

objectives.

GAO/GGD-10.1.20 

(Washington, D.C.: April 1998).

41D. C. Evers, J . G. Wiener, C. T. Driscoll, D. A. Gay, N. Basu, B. A. Monson, K. F. 

Lambert, H. A. Morrison, J. T. Morgan, K. A. Williams, and A. G. Soehl, Great Lakes 

Mercury Connections: The Extent and Effects of Mercury Pollution in the Great Lakes 

Region, Biodiversity Research Institute, Report BRI 2011-18 (Gorham, Maine: 2011). 
 

Page 27 GAO-13-797 Great Lakes Restoration Initiative

Monitoring practices may affect the usefulness of some measures. For 

example, one goal of the invasive species focus area is to eliminate the 

introduction of new invasive species, with a 2014 objective of reducing 

the yearly average rate of invasive species newly detected in the Great 

Lakes ecosystem by 40 percent, compared with the period from 2000 to 

2009. The linked measure of progress addresses the rate at which 

nonnative species are newly detected in the Great Lakes ecosystem. The 

source of data used to evaluate this measure is a database maintained by 

the National Oceanic and Atmospheric Administration. According to 

information on this database, the identification of new species depends 

on the ability to find, recognize, verify, and document new species, which 

is, in turn, dependent on the ability to adequately sample the Great Lakes 

ecosystem. Officials from a state agency and four subject matter experts 

raised concerns about the usefulness of this measure for assessing 

progress toward the Action Plan objectives, noting that the number of new 

species detected will increase if surveillance for invasive species 

increases or improves. One of these experts noted that meeting the 

targets may not represent progress because monitoring efforts are low, 

and another of these experts told us that the measure needs to be 

combined with a known level of monitoring. Similarly, National Oceanic 

and Atmospheric Administration officials agreed that progress toward the 

targets for this measure will vary depending on the extent of monitoring 

and the ability of surveillance to detect new nonnative species, and they 

told us that, without a known level of monitoring, it may not be possible to 

reliably identify trends in the introduction or detection of new species 

using this measure. As we reported in November 2002, one attribute of 

successful performance measures is that they are likely to produce the 

same results if applied repeatedly to the same situation.42

Targets for some measures may not represent significant ecological 

improvement. EPA’s Science Advisory Board reported in its 2012 review 

of the GLRI Action Plan that it is not clear whether the targets for the 

measures of progress reflect significant or measurable improvement, or 

If efforts to 

identify new species depend on the ability to adequately sample the Great 

Lakes ecosystem and surveillance or levels of monitoring are not 

consistent throughout the program, then this measure may not be useful 

for indicating GLRI progress toward the Action Plan’s goals and 

objectives.

 

42GAO-03-143. 
 

Page 28 GAO-13-797 Great Lakes Restoration Initiative

whether achieving the targets will result in real ecological benefit. It also 

noted that it is not clear how the targets were developed and, that while 

the measures of progress include baselines for the targets, the universe 

is not always defined.43 For example, one measure in the nearshore 

health and nonpoint source pollution focus area addresses the amount of 

land with certain conservation practices implemented to reduce erosion, 

nutrients, and pesticides. The Action Plan reports a baseline of 165,000 

acres with such practices already being implemented and identifies a 

2014 target of 247,500 acres, a 50 percent increase. However, the Action 

Plan does not identify the universe (i.e., the total acreage of land upon 

which such practices could be implemented), which the Science Advisory 

Board reported is more than 38 million acres of agricultural land in the 

United States within the Great Lakes Basin. Consequently, using this 

universe, the 50 percent increase in acreage using such conservation 

measures represents a change from 0.4 percent to 0.6 percent of the total 

U.S. agricultural land in the Great Lakes Basin. According to the Science 

Advisory Board, it is not clear if this change is meaningful and how this 

percentage of improvement will potentially result in the restoration of the 

Great Lakes ecosystem. In November 2002, we reported that clarity is a 

key attribute of successful performance measure.44

A subgroup of the Task Force agencies has been evaluating how well the 

measures of progress and targets are working and has identified some 

that will need revisions. For example, the subgroup found that some 

measures of progress have been difficult to implement or difficult to 

demonstrate scientifically, particularly in the nearshore health and 

nonpoint source pollution focus area. However, as this subgroup has 

acknowledged, there is no defined process for the Task Force agencies 

to revise the Action Plan, such as updating or replacing the measures of 

progress or for updating their targets.

Without some 

clarification, this measure may not be useful for indicating GLRI progress 

toward the Action Plan’s goals and objectives.

 

43According to the Action Plan, the baseline represents the starting point for the measure, 

and the universe represents all that could possibly be, for example, protected, restored, or 

enhanced. For example, one measure in the plan is the amount of contaminated sediment 

remediated in the Great Lakes. The baseline is 5.5 million cubic yards of sediment, and 

the universe is 46 million cubic yards.

44GAO-03-143. 
 

Page 29 GAO-13-797 Great Lakes Restoration Initiative

EPA and the Task Force agencies have not fully established a plan to 

guide an adaptive management process for the GLRI. Although there is 

no requirement that the Task Force establish an adaptive management 

plan for the GLRI, an adaptive management process could allow EPA and 

the Task Force agencies to evaluate whether GLRI projects are leading to 

the Action Plan’s objectives and goals and, if needed, use the results to 

adjust future actions. EPA and several Task Force agencies in 2000 

adopted a unified federal policy on watershed management that defined 

adaptive management as a type of natural resource management in 

which decisions are made as part of an ongoing science-based process 

that involves (1) testing, monitoring, and evaluating applied strategies; (2) 

incorporating new knowledge into management approaches that are 

based on scientific findings and the needs of society; and (3) using results 

to modify management policy, strategies, and practices.45

There is no universal definition for adaptive management or fixed set of 

steps that constitutes an adaptive management process, but key 

elements of this iterative process based on guidance documents from 

several Task Force agencies are summarized in figure 4. In addition, 

according to guidance from the Forest Service, adaptive management 

requires explicit designs that, among other things, specify documentation 

and monitoring protocols; roles, relationships, and responsibilities; and, 

assessment and evaluation processes. This guidance also notes that it is 

important for an adaptive management effort to have clear documentation 

describing details of the adaptive management process, and an absence 

This policy 

stated that the agencies would incorporate adaptive management 

principles into their programs and use adaptive management to improve 

watershed conditions. More recently, in the 2012 amendment to the Great 

Lakes Water Quality Agreement, the United States and Canada agreed to 

be guided by the principles and approaches of adaptive management, 

which is described in the agreement as a systematic process to assess 

the effectiveness of actions and adjust future actions to achieve the 

objectives of the agreement, as outcomes and ecosystem processes 

become better understood.

 

45U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of 

Defense, U.S. Department of Energy, U.S. Department of the Interior, U.S. Environmental 

Protection Agency, Tennessee Valley Authority, and U.S. Army Corps of Engineers, 

Unified Federal Policy for a Watershed Approach to Federal Land and Resource 

Management, notice of final policy, 65 Fed. Reg. 62566 (Oct. 18, 2000).

EPA and the Task Force 

Agencies Have Not Fully 

Established an Adaptive 

Management Plan for the 

GLRI 
 

Page 30 GAO-13-797 Great Lakes Restoration Initiative

of explicit plans can diminish the potential benefits of adaptive 

management.46

Figure 4: Key Elements of the Adaptive Management Process

a

 

46G. H. Stankey, R. N. Clark, and B. T. Bormann, Adaptive management of natural 

resources: theory, concepts, and management institutions, Gen. Tech. Rep. PNW-GTR654: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station 

(Portland, OR: 2005).

B. K. Williams and E. D. Brown, Adaptive Management: The U.S. Department of the Interior 

Applications Guide, Adaptive Management Working Group, U.S. Department of the Interior 

(Washington, D.C.: 2012).
 

Page 31 GAO-13-797 Great Lakes Restoration Initiative

B. K. Williams, R. C. Szaro, and C. D. Shapiro, Adaptive Management: The U.S. Department of the 

Interior Technical Guide, Adaptive Management Working Group, U.S. Department of the Interior 

(Washington, D.C.: 2009).

b

A. J. Atkinson, P. C. Trenham, R. N. Fisher, S. A. Hathaway, B. S. Johnson, S. G. Torres, and Y. C. 

Moore, Designing Monitoring Programs In an Adaptive Management Context For Regional Multiple 

Species Conservation Plans, U.S. Geological Survey Technical Report (U.S. Geological Survey 

Western Ecological Research Center, Sacramento, CA: 2004).

c

RECOVER 2010, Comprehensive Everglades Restoration Plan Adaptive Management Integration 

Guide, Restoration Coordination and Verification (Jacksonville, FL and West Palm Beach, FL: U.S. 

Army Corps of Engineers, Jacksonville District and South Florida Water Management District, 2010).

d

G. H. Stankey, R. N. Clark, and B. T. Bormann, Adaptive Management of Natural Resources: 

Theory, Concepts, and Management Institutions, Gen. Tech. Rep. PNW-GTR-654 (Portland, OR: 

U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station, 2005).

e

In its 2012 review of the Action Plan, EPA’s Science Advisory Board 

found that the GLRI Action Plan did not establish an adaptive 

management framework and recommended that EPA develop a sciencebased plan that, when coupled with the Action Plan, would create an 

adaptive management framework for the GLRI. In response to this 

recommendation, in May 2013, the Task Force agencies released the 

draft GLRI Adaptive Science-Based Framework for Great Lakes 

Restoration, or draft framework, for public comment.

EPA, Watershed Analysis and Management (WAM) Guide for States and Communities: EPA 

Watershed Analysis and Management Project (Washington, D.C.: 2003), and EPA, Handbook for 

Developing Watershed Plans to Restore and Protect Our Waters, EPA 841-B-08-002 (Washington, 

D.C.: 2008).

47

The draft framework recommends use of an “adaptive restoration” 

approach for the GLRI that includes most of the key elements of adaptive 

management. According to the draft framework, adaptive restoration 

involves exploring alternative ways to meet the goals and objectives in 

the Action Plan, predicting the outcomes of alternatives based on the 

current state of knowledge, implementing one or more of these 

alternatives, monitoring to learn about the impacts of restoration actions, 

and incorporating new knowledge into restoration strategies that are 

based on scientific findings and the needs of society. However, the draft 

framework does not provide details on how the elements of adaptive 

management will be implemented. For example, neither the draft 

framework, nor the Action Plan, addresses how the agencies will 

complete the adaptive management loop by incorporating the information 

gained in future decision making and adjusting the GLRI, if needed. The 

 

47Science Subgroup of the Great Lakes Regional Working Group, Great Lakes 

Restoration Initiative Adaptive Science-Based Framework for Great Lakes Restoration

(May 21, 2013).
 

Page 32 GAO-13-797 Great Lakes Restoration Initiative

draft framework indicates that re-assessment of the Action Plan goals, 

objectives, and measures of progress should be considered every 5 

years. However, neither the framework nor the Action Plan outlines a 

process for assessing or incorporating new information or altering the 

Action Plan, such as by refining the measures or their targets, as 

recommended by the adaptive management section of EPA’s 2003 

guidance for states and communities on watershed analysis and 

management.48

In addition, the draft framework does not include two of the key elements 

of adaptive management shown in figure 4: engaging stakeholders, and 

identifying and evaluating uncertainties.

For example, neither the draft framework nor the Action 

Plan identifies decision thresholds or criteria for making changes, which 

the Science Advisory Board’s 2012 report and EPA’s 2003 guidance have 

identified as important.

Engaging stakeholders. According to guidance from several Task Force 

agencies, active and sustained stakeholder involvement is essential for 

effective implementation of adaptive management.49 The draft framework 

does not explicitly include stakeholder engagement as an element of the 

adaptive restoration process. It acknowledges that engaging scientists, 

stakeholders, and the general public should be considered for updating 

the GLRI over time and states that interactive engagement in setting 

goals and objectives is a key element for producing results. Nevertheless, 

it does not address how the Task Force agencies will ensure ongoing 

stakeholder engagement in the GLRI. Without explicit plans in the draft 

framework for engaging stakeholders, it is not clear how the Task Force 

agencies will consider and account for potential changes in stakeholder 

perspectives and priorities. As the Department of the Interior’s guidance 

notes, conflicting priorities among stakeholders can be enough to prevent 

the successful implementation of adaptive management.50

 

48EPA, Watershed Analysis and Management (WAM) Guide for States and Communities. 

This guidance 

also explains that differing stakeholder views about how natural 

processes work and how they respond to management are examples of 

uncertainties that can limit the effectiveness of management efforts.

49For example, see Williams and Brown, Adaptive Management; Stankey et al., Adaptive 

Management of Natural Resources; and RECOVER 2010, Comprehensive Everglades

Restoration Plan Adaptive Management Integration Guide.

50Williams and Brown, Adaptive Management. 
 

Page 33 GAO-13-797 Great Lakes Restoration Initiative

Identifying and evaluating uncertainties. Neither the draft framework, nor 

the Action Plan, identifies, prioritizes, and evaluates critical scientific or 

policy uncertainties. In addition, the draft framework does not include 

such uncertainties in its list of elements of adaptive restoration planning. 

Such uncertainties could include critical assumptions, gaps in knowledge, 

or uncertainties about the relationships between ecological processes 

and stresses, such as the potential effects of climate change on the Great 

Lakes. Identifying and explicitly accounting for critical uncertainties in 

designing the GLRI could increase the likelihood that the GLRI will meet 

its goals and objectives. Several Task Force agencies have emphasized 

the use of models as an important way to evaluate and account for such 

uncertainties by, for example, representing how the ecosystem may 

respond to restoration actions or environmental changes.51 The draft 

framework notes that predictive modeling plays an important role in 

adaptive restoration, and it recommends evaluation of uncertainties in the 

context of reporting on progress.52 However, the framework does not 

identify and account for critical uncertainties.

The Task Force agencies have issued two GLRI progress reports, but the 

reports include few specific examples of progress. To obtain further 

insights about GLRI progress, we surveyed nonfederal GLRI stakeholders 

and interviewed Task Force agency officials. However, quantifying overall 

Great Lakes restoration progress is difficult for several reasons, including 

the unique environmental conditions of each of the Great Lakes.

 

51Williams and Brown, Adaptive Management. Williams et al., Adaptive Management.

Atkinson et al., Designing Monitoring Programs. RECOVER 2010, Comprehensive

Everglades Restoration Plan Adaptive Management Integration Guide. Stankey et al., 

Adaptive Management of Natural Resources. 

52For example, it states that progress reports should (1) attempt to consider the influence 

of potentially confounding developments such as natural environmental variation, along 

with regional and global trends such as climate change, shifts in human population 

numbers, and changing patterns of land use and (2) include relevant evaluations of the 

uncertainty and assumptions associated with particular restoration actions and long-term 

sustainability of ecosystem health.

Task Force Agencies 

and Nonfederal 

Stakeholders Report 

GLRI Progress, but 

Overall Great Lakes 

Restoration Progress 

Is Difficult to Quantify
 

Page 34 GAO-13-797 Great Lakes Restoration Initiative

As we noted previously, the Task Force agencies have issued two GLRI 

progress reports to Congress; one on fiscal year 2011 progress and one 

on progress in fiscal year 2010. EPA officials told us that the report on 

progress in fiscal year 2011 includes more information and was released 

earlier than the fiscal year 2010 report because GLRI funding was 

available late in fiscal year 2010 and not as much was achieved that year. 

Both reports identified whether the targets for the GLRI Action Plan’s 28 

measures of progress had been met or exceeded in the related fiscal 

year, or that data were unavailable for a specific measure. For example, 

the fiscal year 2011 report states that 15 measures were met or 

exceeded, 9 measures were not met, and data were not available to 

determine the status of 4 measures. However, as we noted earlier, the 

measures may not provide sufficiently comprehensive or useful 

information for a number of reasons, including that the measures do not 

capture the results of many of the GLRI projects and that some measures 

or their targets may not be indicative of progress.

The fiscal year 2011 report also includes broad statements about whether 

the GLRI is achieving goals, objectives, and measures of progress that 

are followed by several examples of results and highlights of progress 

made or expected in two projects in each of the five Action Plan focus 

areas.53

In the first years of the GLRI, no new aquatic invasive species populations have been 

detected in the Great Lakes. The GLRI is at the forefront of invasive species prevention, 

control, and rapid response. The GLRI is supporting investments in technologies that 

prevent the introduction of invasive species, including the Department of Transportation’s 

Maritime Administration’s verification of new ballast water treatment technologies, which is 

an important step before conducting ship-scale testing.

For example, in the invasive species focus area, the report states 

that:

However, except for the two projects highlighted in each focus area, the 

fiscal year 2011 report does not identify the GLRI projects that led to the 

progress achieved. In addition, neither of the two reports integrates 

accomplishment and progress information into conclusions about overall 

GLRI progress or contains specific information about the extent of 

progress toward GLRI goals, and neither includes an assessment of 

changes in the health of the Great Lakes ecosystem that could be 

 

53The fiscal year 2010 report includes a list of five to nine projects in each of the Action 

Plan focus areas, some of which include a description of progress made. 

Task Force Agencies 

Report Progress
 

Page 35 GAO-13-797 Great Lakes Restoration Initiative

attributed to the projects. As a result, the information in the GLRI progress 

reports was not sufficient for determining if GLRI projects had led to the 

described progress and how much progress has been made in restoring 

the health of the Great Lakes ecosystem.

In light of the limited information included in the two GLRI progress 

reports, we sought to obtain further insights by surveying nonfederal 

stakeholders and interviewing officials from Task Force agencies. The 

information we gathered in the survey allows us to provide more 

information on how nonfederal stakeholders describe GLRI progress, and 

it is not intended to determine the extent of GLRI progress toward 

restoring the health of the Great Lakes ecosystem. When asked to 

provide examples of how one or more of their organization’s GLRI 

projects had benefitted the Great Lakes ecosystem, 87 percent (153) of 

the 176 respondents provided at least one example of how one or more 

of their GLRI projects had benefited, or was expected to benefit, the 

Great Lakes ecosystem in each of the five focus areas. Specifically:

• 55 percent (96) of respondents provided at least one example of how 

one or more of their GLRI projects had directly benefited the Great 

Lakes ecosystem, such as by restoring habitat or by trapping invasive 

species.

• 27 percent (47) of respondents provided at least one example of how 

one or more of their GLRI projects indirectly benefited the Great 

Lakes ecosystem, such as by improving the understanding of part of 

the ecosystem or identifying future restoration work.54

• 44 percent (77) of respondents reported that they expected at least 

one of their projects to result in a direct or indirect benefit to the 

ecosystem, but that it was too early to report a benefit at this time.

• 13 percent (23) of respondents did not provide an example of how 

one of their projects had, or was expected to, benefit the Great Lakes 

ecosystem.

 

54Because some respondents provided examples of more than one type of benefit, the 

sum of the percent of respondents that provided examples exceeds the 87 percent 

response rate.

Nonfederal Stakeholder 

and Task Force Agency 

Examples of GLRI 

Progress
 

Page 36 GAO-13-797 Great Lakes Restoration Initiative

A majority of the survey respondents and Task Force agency officials we 

interviewed reported progress toward the overall GLRI goal of restoring 

the health of the Great Lakes ecosystem. The following examples 

represent a broad range of GLRI progress in each of the five focus areas 

as reported by survey respondents, through the survey and follow-up 

interviews, and by Task Force agency officials, in interviews, and do not 

represent the only types of GLRI projects being implemented:

• One survey respondent reported that her organization received two 

GLRI grants to help clean up the Presque Isle Bay area of concern in 

Lake Erie, in Pennsylvania; the two grants totaled $664,789. The 

respondent told us that, prior to the GLRI, the organization was 

devoting all of its resources to addressing only one of the specific 

conditions—fish tumors—that were responsible for the bay being 

identified as an area of concern, and that GLRI funding made it 

possible for her organization to do additional work. Specifically, GLRI 

funding enabled the organization to undertake a number of monitoring 

and investigative projects; develop a target for being removed from 

the list of areas of concern; and, develop a long-term monitoring, 

restoration, and protection plan for the bay’s watershed. The 

respondent reported that GLRI funding was also used for specific 

investigations in the watershed that will provide her organization with 

an updated set of data to use in identifying priority areas for 

restoration and protection. According to the respondent, without that 

information, the organization would not have a blueprint to maintain 

and continue protecting the bay. In December 2012, 21 years after the 

bay had been identified as an area of concern, the survey respondent 

told us in an interview that her organization was in the process of 

sending a formal request to remove Presque Isle Bay’s designation as 

an area of concern. EPA announced in February 2013 that the bay 

had been delisted. It is the second U.S. area of concern to be 

removed from the list. The respondent estimated that GLRI funding 

had accelerated the process of removing Presque Isle Bay from the 

list of areas of concern by 10 years.

• Officials we interviewed from the U.S. Geological Survey told us that 

the agency had used GLRI funds to complete three basin-wide 

sampling efforts of the water column, bottom sediments, and two 

other types of samples across the entire Great Lakes Basin as a part 

of its methylmercury sampling and analysis project. Methylmercury—

an organic form of mercury—is a highly toxic substance that can build 

up in predatory fish, including fish that people eat. According to the 

officials, the sampling efforts took place in August 2010, April 2011, 

and August 2011, and data from these efforts have revealed a 

Toxic substances and areas of 

concern 
 

Page 37 GAO-13-797 Great Lakes Restoration Initiative

previously unknown source of methylmercury that likely is the 

dominant source leading to elevated concentrations in fish throughout 

the Great Lakes.

Figure 5: A Depiction of the Mercury Cycle

• One survey respondent reported progress made by a project to 

improve control of sea lampreys, an invasive species in the Great 

Lakes, for which his organization had received $8,203,561 in GLRI 

funding. According to the U.S. Geological Survey, sea lampreys have 

devastated fish communities in the Great Lakes by feeding on the 

bodily fluids of host fish, such as the native lake trout. According to 

the respondent, the project worked to develop a new sea lamprey 

control technique that relies on the sea lamprey’s sense of smell. The 

respondent reported that field trials using this technique increased 

trapping efficiencies by up to 53 percent and that traps used with this 

technique can capture more than twice as many sea lampreys as 

traps that do not use the technique. According to the respondent, this 

Invasive species 
 

Page 38 GAO-13-797 Great Lakes Restoration Initiative

new technique may make it possible not only to capture more sea 

lampreys but also to reduce the amount of pesticides introduced into 

the Great Lakes that are used to kill sea lampreys.

• Officials we interviewed from the U.S. Coast Guard told us that the 

agency’s invasive species-related projects will increase its 

enforcement capability and address some technical problems relating 

to the installation and operation of freshwater ballast treatment 

systems for vessels operating on the Great Lakes. Ballast water is 

water that is taken into or discharged from a ship to accommodate 

changes in weight as a ship loads or unloads cargo. According to the 

U.S. Coast Guard, ballast treatment systems are intended to reduce 

the number of invasive species that can be transported into the Great 

Lakes in ballast water. The U.S. Coast Guard’s Research and 

Development Center worked with the Naval Research Laboratory to 

design, build, test, and verify a system for testing treated ballast water 

under both shoreside and shipboard conditions. According to U.S. 

Coast Guard officials, this project will facilitate rigorous testing of the 

performance of ballast water treatment systems under shipboard 

conditions, ensuring greater protection against the introduction of 

invasive species into the Great Lakes.
 

Page 39 GAO-13-797 Great Lakes Restoration Initiative

• One survey respondent reported that her organization received 

$85,000 in GLRI funding for a project to reduce the amount of bacteria 

in beach sand at a park on Lake Erie, in New York. According to the 

respondent, work completed in 2011 with GLRI funds determined that 

beach sand is acting as a reservoir for Escherichia coli, abbreviated 

as E. coli, which can negatively impact public health.55

• The Natural Resources Conservation Service received $75 million in 

GLRI funding from fiscal years 2010 to 2012 to target conservation 

efforts in selected priority areas. According to an agency official, this 

funding provides an opportunity to implement additional scientifically 

proven conservation practices in the priority watersheds, accelerating 

conservation practice implementation above what other programs 

would have provided. Landowners can take advantage of GLRI funds 

through a Natural Resources Conservation Service cost-share 

assistance program to install conservation practices. The agency 

helps landowners with conservation planning using various 

conservation practices, such as cover crops, conservation crop 

rotations, filter strips, prescribed grazing, and wetlands restoration. 

For example, the practice of cover crops establishes close-growing 

grasses, or other crops, to help improve soil and water quality by 

reducing soil erosion, among other things. A filter strip is a strip of 

herbaceous vegetation that is situated between crop or grazing land 

and a stream, river, or wetland, in order to reduce contaminated 

runoff. An agency official reported that GLRI funded efforts have led to 

the use of cover crops and filter strips on nearly 70,000 acres and 143 

acres of priority watersheds respectively. For example, one landowner 

The 

organization then compared three sand grooming techniques to no 

beach grooming. According to the respondent, the results indicated 

that sand grooming using a specific tractor attachment can reduce the 

amount of bacteria in the sand. In 2012, the organization compared 

water quality when sand was groomed using two different grooming 

techniques. The respondent reported that preliminary results indicate 

that grooming the beach daily with the specific tractor attachment 

significantly reduced the number of beach closures. The respondent 

reported that this fiscal year 2011 to 2012 GLRI project resulted in an 

improvement in water quality.

 

55E. coli are a large and diverse group of bacteria found in the environment, foods, and 

intestines of people and animals. Some strains can cause pneumonia and other illnesses 

in humans who may come into contact with E. coli in rivers and lakes contaminated by 

human or animal feces. 

Nearshore health and nonpoint 

source pollution
 

Page 40 GAO-13-797 Great Lakes Restoration Initiative

used the funds to develop a prescribed grazing system that 

encourages groundwater recharge, improves soil quality and prevents 

sediment and nutrient losses. The landowner is also installing a waste 

collection system to keep contaminated water out of nearby surface 

water and plans to plant 34 acres of cover crop.

• A survey respondent reported that his organization had a project to 

help restore a marsh area that is among the roughly 15 costal marsh 

areas along Lake Michigan’s Lower Peninsula shoreline. The 

organization received $783,823 in GLRI funds for the project. One 

component of the project was to replace seven misaligned culverts. 

According to the respondent, the new culverts will allow unimpeded 

fish passage to more than 12 miles of stream habitat, which improves 

habitat for trout and other aquatic organisms. In addition, the 

respondent reported that the project restored a mile-long section of 

trout stream back to its original watercourse. This was necessary 

because the hydrology of an adjacent 75-acre wetland had been 

significantly degraded when the trout stream had been diverted into a 

straightened channel decades ago. The project also resulted in the 

eradication of types of invasive plants. The survey respondent 

reported that this project will improve fisheries habitat, help restore 

hydrology to a large wetland for waterfowl and many other species of 

wildlife and fish, and improve public recreational opportunities.

• Officials from the Fish and Wildlife Service told us that the agency has 

received $11,590,857 in GLRI funds in fiscal years 2010 to 2012 for a 

project that focuses on restoring habitats for native lake sturgeon, 

brook trout, migratory birds, and threatened and endangered species 

populations within the Great Lakes Basin by removing barriers to fish 

passage, stabilizing stream banks and riparian areas (narrow 

vegetated areas adjoining rivers, streams, and lakes), improving instream habitat and restoring costal, wetland and upland areas. 

According to agency officials, the project has protected, restored, or 

enhanced more than 2,000 acres of wetlands and uplands, removed 

or bypassed more than 30 fish passage barriers, and reopened more 

than 210 stream miles to fish movement. Agency officials said that 

improving aquatic connectivity in the Great Lakes Basin is one of the 

more prominent achievements of the project, and that removing 

barriers to fish passage creates a healthier aquatic habitat and 

improves water quality and sediment management. In addition, 

according to agency officials, free-flowing rivers provide new 

recreational opportunities.

Habitat and wildlife protection 

and restoration
 

Page 41 GAO-13-797 Great Lakes Restoration Initiative

• One survey respondent reported that his organization received GLRI 

funding to map and describe all of the wastewater treatment plants in 

the Great Lakes Basin, both in the United States and Canada, and to 

develop a binational aquatic invasive species response plan. The 

respondent’s organization received $300,000 in GLRI funding for 

these projects. According to the respondent, the project to map and 

describe wastewater treatment plants resulted in the first ever 

binational map of these facilities and will inform management 

decisions about the level and consistency of water treatment and help 

protect human and environmental health. In addition, the respondent 

reported that the aquatic invasive species response plan developed 

by his organization provides a foundation for work on a basinwide 

plan that will be an important backup plan in the event that aquatic 

invasive species prevention efforts fail. According to the respondent, 

the plan his organization developed will directly assist the 

governments of the United States and Canada in meeting their 

obligations under the 2012 amendment to the Great Lakes Water 

Quality Agreement, which requires the two governments to develop 

and implement an early detection and rapid response initiative for 

aquatic invasive species, among other things.

• Officials we interviewed from the National Oceanic and Atmospheric 

Administration told us that the agency’s dissemination of training 

materials for educators and climate curricula for elementary through 

high school students, which is customized for the Great Lakes region, 

is on target to reach more than 3,000 students and 50 teachers by the 

end of fiscal year 2013. As a result, officials said, the number of 

institutions incorporating this information into existing curricula far 

exceeds the GLRI Action Plan targets. Specifically, the Action Plan’s 

2013 target for the measure that addresses the number of educational 

institutions incorporating Great Lakes protection and stewardship 

criteria into their environmental education curricula is 10 institutions. 

This measure corresponds to the Action Plan’s goal to increase 

outreach and education for the Great Lakes so that students 

understand the benefits and ecosystem functions of the Great Lakes 

and are able to make decisions to ensure that restoration investments 

are enhanced over time.

In addition to these examples of progress, respondents to our survey and 

other stakeholders we interviewed reported that the GLRI had allowed 

them to do restoration work that they previously identified as important 

but could not undertake because of limited funds or staff, among other 

reasons. For example, one survey respondent noted that due to GLRI 

funding, progress has been made on problems that had been languishing 

Accountability, education, 

monitoring, evaluation, 

communication, and 

partnerships
 

Page 42 GAO-13-797 Great Lakes Restoration Initiative

for years due to inadequate funding such as high-priority restoration 

projects, aquatic invasive species control, and actions to reduce 

beneficial use impairments. In addition, a state agency official we 

interviewed told us that without GLRI funding his state would not have 

had the capacity to help coordinate restoration efforts for areas of 

concern or conduct necessary monitoring of fish toxicity. Furthermore, in 

commenting on a draft of this report, National Park Service officials noted 

that GLRI funds have proven to be invaluable for helping the Service 

accomplish significant restoration of wetlands and areas affected by 

invasive species, among other things.

We, and other organizations, have documented the difficulties associated 

with efforts to quantify overall progress toward Great Lakes restoration. 

For example, we reported in 2004 that it is difficult to describe restoration 

progress across the basin because of the unique environmental 

conditions of each of the Great Lakes.56 Specifically, the Great Lakes are 

not one contiguous water body but rather distinct lakes with unique 

environmental conditions—such as lake depth—that present challenges 

to setting goals and developing a monitoring system that can be used to 

describe restoration progress across the basin and also capture the 

uniqueness of each lake. In addition, according to a 2006 United Nations 

report, it is usually difficult, and sometimes impossible, to attribute 

changes in the state of a large ecosystem solely to the efforts of a specific 

ecosystem management program. 57

EPA officials told us that it may not be possible to summarize Great 

Lakes restoration progress with one simple statement due to the size and 

complexity of the Great Lakes ecosystem. They said that when the Action 

Plan was created, the Task Force agencies incorporated a measure the 

agency had created as part of its GPRA reporting requirements, the Great 

Lakes 40-point scale (also called the Great Lakes Index), as a measure of 

Furthermore, several Task Force 

agency officials, nonfederal stakeholders, and subject matter experts told 

us that it may take time for some Great Lakes restoration efforts to show 

measurable results.

 

56GAO-04-1024. 

57United Nations Environmental Program and Global Programme of Action for the 

Protection of the Marine Environment from Land-based Activities, Ecosystem-based 

Management: Markers for Assessing Progress (The Hague, Netherlands: 2006).

Overall Great Lakes 

Restoration Progress Is 

Difficult to Quantify
 

Page 43 GAO-13-797 Great Lakes Restoration Initiative

progress intended to represent progress across the focus areas by 

measuring improvement in the overall health of the aquatic ecosystem. 

The index rates eight indicators on a scale from 1 to 5, where 1 is poor, 

and 5 is good, to produce an assessment of overall Great Lakes health 

that is represented by one number.58

However, some stakeholders and subject matter experts we interviewed 

raised concerns about the index and some of its indicators. For example, 

they said that the index is missing key ecosystem indicators, such as 

those related to invasive species and the health of native species. In 

addition, they said that the index is better suited for assessments of longterm, as opposed to annual, changes in the health of the ecosystem. EPA 

officials also questioned how meaningful it was to use just one number to 

convey information about the state of the multiple ecosystems and 

indicators within the Great Lake basin.

EPA officials also explained that the GLRI is a relatively new undertaking 

and that getting visible, lake-wide and basin-wide ecosystem 

improvements from Great Lakes restoration efforts is a slow process. 

According to the officials, benefits, such as improvements in areas of 

concern, are being seen at the local level and by the end of the GLRI’s 

lifespan in 2014, EPA will be able to show progress at a local level as a 

step toward improving the health of the lakes overall.

The Task Force agencies’ draft framework includes direction to report on 

restoration progress and accomplishments, and transfer knowledge and 

lessons learned, among other things. The draft framework also notes that, 

while assembling project specific results can begin to offer a picture of 

cumulative progress and local success, reporting on GLRI at the program 

level can inform whether or not the GLRI is making restoration progress 

at other levels, such as the regional, lake, or ecosystem level.

 

58The eight indicators are coastal wetlands, phosphorus concentrations, area of concern 

sediment contamination, benthic health, fish tissue contamination, beach closures, 

drinking water quality, and air toxics deposition. The ratings for each indicator are added 

together to create the index score. Improvements in the index would indicate that fewer 

toxics are entering the food chain; ecosystem and human health is better protected; fish 

are safer to eat; water is safer to drink; and beaches are safer for swimming.
 

Page 44 GAO-13-797 Great Lakes Restoration Initiative

In response to our survey, respondents reported on what they believed to 

be the key factors that may affect and may limit GLRI progress. They 

cited practical issues related to implementing GLRI projects, such as the 

time it takes to complete quality assurance requirements and obtain 

permits. They also cited broader issues outside the scope of the Action 

Plan, for which realistic solutions may be expensive, pointing in particular 

to inadequate infrastructure for wastewater and stormwater and the 

effects of climate change.

Survey respondents most often reported that their GLRI projects started 

later than planned because of quality assurance requirements and the 

length of time needed to obtain permits. It is important to emphasize that 

quality assurance requirements for environmental programs play a critical 

role in ensuring the success of those programs and that permits for 

environmental activities are required by a number of federal and state 

laws. Moreover, survey respondents did not suggest that either process 

should be eliminated when asked to comment on GLRI’s quality 

assurance requirements. Nonetheless, later start times can slow GLRI 

implementation and, as a result, may affect the pace of progress.

• Quality assurance requirements. Organizations that receive GLRI

funds through federal grants may be required to meet specific quality 

assurance requirements for projects and tasks involving 

environmental data in order to receive the funds.59

 

59According to the EPA, the success of an environmental project depends on the quality of 

the environmental data collected and used in decision making. As part of the process of 

ensuring that projects have quality data, a grantee creates a document that is intended to 

serve as a tool for project managers and planners to document the type and quality of 

data needed for environmental decisions and to describe the methods for collecting and 

assessing those data. There are neither time limits associated with this process for the 

GLRI, nor is there a generally accepted length of time for completing these requirements.

Seventy-seven 

percent (135) of the 176 survey respondents reported that they 

needed to complete quality assurance requirements for at least one of 

their GLRI projects and, that on average, it took nearly 4 months to 

complete those requirements. Of those 135 respondents, 28 percent 

(38) reported that their projects started later than planned because of 

the time it took to complete quality assurance requirements, and 13 

percent (17) reported that they could not start their project until the 

next spring because the ground or water was frozen. EPA officials told 

us that the GLRI quality assurance process was slow at the start of 

Nonfederal 

Stakeholders 

Identified Key Factors 

That May Affect and 

May Limit GLRI 

Progress 

Factors Related to 

Implementing GLRI 

Projects Affected Progress
 

Page 45 GAO-13-797 Great Lakes Restoration Initiative

the program because the agency had not previously assessed quality 

assurance requirements for the kind of work being proposed in some 

of the projects. However, several survey respondents reported that 

the time it takes to complete GLRI quality assurance requirements 

has decreased since the program began in fiscal year 2010.

• Time needed to obtain permits. Organizations implementing GLRI 

projects might need to obtain federal or state permits for certain 

efforts, such as using herbicides to reduce invasive species, 

conducting controlled burning to enrich soil nutrients, or enhancing 

habitat for endangered species and communities. About half (87) of 

the 176 survey respondents reported that they needed a permit for at 

least one of their GLRI projects and that it took an average of 5 

months to obtain the necessary permits. Of those 87 respondents, 31 

reported that their projects started later than planned as a result of the 

time needed to obtain permits, and 13 reported that they could not 

start their project until the next spring because the ground or water 

was frozen. In addition, in the fiscal year 2011 GLRI progress report, 

the Task Force agencies identified permit processing as one of the 

factors for slowed project implementation for the habitat and wildlife 

protection and restoration measure of progress addressing the 

number of acres of coastal, upland, and island habitats protected, 

restored, and enhanced.

Survey respondents also reported that the timing of award notification 

resulted in later-than-planned start times for their GLRI projects (30 

percent, or 52 out of 176, respondents),60 and that weather events limited 

the implementation of their GLRI projects (26 percent, or 45 out of 176, 

respondents). Specifically, 16 percent (29) reported that weather events 

caused their GLRI projects to be completed later than planned, 15 

percent (27) reported weather events caused a suspension of GLRI 

activities, and 6 percent (11) reported that weather events resulted in 

later-than-planned start times for their GLRI projects.61

 

60The timing of award notification is the timing of when an organization received notice 

that its GLRI project would be funded.

Weather events 

may cause GLRI projects to start later than planned because work cannot 

proceed on some projects—such as those that involve planting, doing 

construction, or monitoring stormwater—if there is a drought, too much 

61Because some respondents reported that weather events affected their GLRI projects in 

more than one way, the sum of the percent of respondents that reported specific effects of 

weather events exceeds the 26 percent response rate.
 

Page 46 GAO-13-797 Great Lakes Restoration Initiative

rain, or the ground does not freeze in winter, among other things. For 

example, three survey respondents reported that work on their projects in 

wetlands was delayed because the wetlands involved with their 

organization’s projects did not sufficiently freeze one winter.

Once started, the success of GLRI projects and of the GLRI as a whole 

can depend upon factors outside the scope of the Action Plan—that is, 

factors that are not addressed by the Action Plan’s long-term goals, 

objectives, or measures of progress—that affect the Great Lakes 

ecosystem. One such factor is atmospheric deposition, which is a process 

that transfers pollutants from the air to the earth’s surface and can 

significantly impair water quality in the nation’s rivers, lakes, bays, and 

estuaries, and harm human health and aquatic ecosystems.62

We asked survey respondents to rank nine factors that are not addressed 

in the Action Plan on the basis of their potential to limit the restoration of 

the health of the Great Lakes ecosystem. As indicated in figure 5, survey 

respondents most frequently reported that inadequate infrastructure for 

wastewater or stormwater (72 percent, or 126 of 176, respondents) and 

the effects of climate change (65 percent, or 114 of 176, respondents) 

have the greatest potential to limit the restoration of the health of the 

Great Lakes’ ecosystem in comparison with other factors outside the 

scope of the Action Plan. Survey respondents also reported that factors 

such as the removal of water from the Great Lakes for use outside of the 

region and the effects of population growth in the Great Lakes region 

have the potential to limit the restoration of the health of the Great Lakes’ 

Airborne 

pollutants transferred by atmospheric deposition can fall to the ground in 

precipitation or as a gas or particle and be deposited either directly onto 

the surface of a water body or onto land and then transported into a water 

body through runoff. Atmospheric deposition contributed to the presence 

of toxaphene in the Great Lakes. Toxaphene is an insecticide that was 

once primarily used in southern states from 1947 to 1980, and it was 

banned in the United States for all uses in 1990. It is toxic for many 

aquatic organisms and accumulates in fish and shellfish causing health 

problems in humans who consume them.

 

62For information on atmospheric deposition, see GAO, Water Quality: EPA Faces 

Challenges in Addressing Damage Caused by Airborne Pollutants, GAO-13-39 

(Washington, D.C.: Jan. 24, 2013).

Factors Outside the Scope 

of the Action Plan May 

Limit GLRI Progress
 

Page 47 GAO-13-797 Great Lakes Restoration Initiative

ecosystem to a great or very great extent by 57 percent (101 out of 176 

respondents) and 49 percent (87 out of 176 respondents) respectively.

Figure 6: Survey Respondents Rated Factors Outside the Scope of the Great Lakes 

Restoration Initiative Action Plan That Have the Potential to Limit the Restoration of 

the Health of the Great Lakes Ecosystem to a Great or Very Great Extent

In addition, we asked 21 Great Lakes subject matter experts we 

interviewed to rank these factors, and 13 of the 21 experts identified the 

same top two factors the survey respondents did, noting that both 

inadequate infrastructure for wastewater or stormwater and the effects of 

climate change have the potential to limit the restoration of the health of 

the Great Lakes ecosystem to a great or very great extent.
 

Page 48 GAO-13-797 Great Lakes Restoration Initiative

Inadequate infrastructure for wastewater or stormwater refers to the 

deteriorating condition of the nation’s wastewater systems. These 

systems include sewer pipes that convey wastewater from homes and 

businesses to treatment facilities before discharging it into water bodies 

or land. In a 2004 report to Congress, EPA estimated that more than 1.2 

million miles of pipes delivered wastewater into these systems. EPA has 

also reported that the vast majority of the pipes making up the nation’s 

wastewater systems were installed more than 50 years ago and are 

reaching the end of their useful lives. In addition to the age of these 

systems, their conveyance capacity (i.e., the rate at which they can 

transport water) is often exceeded during rainfall or snowmelt, which adds 

to the discharge of wastewater into U.S. surface waters. According to the 

American Society of Civil Engineers, the age and inadequate capacity of 

wastewater infrastructure systems lead to the discharge billion of gallons 

of untreated wastewater into U.S. surface waters each year.63

Inadequate infrastructure can cause conditions that may slow, if not 

negate, restoration efforts, such as to improve water quality or reduce the 

number of days a beach is closed. This is because most wastewater 

systems are designed to discharge flows that exceed conveyance 

capacity directly to rivers, streams, and other surface waters. One Great 

Lakes interest group reported that five U.S. cities alone discharged 41 

billion gallons of untreated sewage and stormwater into the Great Lakes 

from January 2009 to January 2010.64 In its most recent clean water 

needs survey report, EPA stated that $19.7 billion was needed to address 

publicly owned wastewater and stormwater infrastructure needs in the 

Great Lakes Basin.65

Climate change is associated with increasing land and water 

temperatures and rising sea levels. There is uncertainty about the precise 

future effects of climate change on any particular region of the country, 

 

63The American Society of Civil Engineers represents more than 140,000 members of the 

civil engineering profession worldwide. 

64Healing Our Waters – Great Lakes Coalition, Turning the Tide: Investing in Wastewater 

Infrastructure to Create Jobs and Solve the Sewage Crisis in the Great Lakes (Ann Arbor, 

MI: August 2010). According to the report, data for this statement was provided by the five 

cities and EPA.

65EPA, Clean Watershed Needs Survey 2008 Report to Congress, EPA-832-R-10-002 

(Washington, D.C.: 2008).

Infrastructure

Climate Change 
 

Page 49 GAO-13-797 Great Lakes Restoration Initiative

but a strong scientific consensus has emerged in recent years from the 

U.S. Global Change Research Program and the National Research 

Council that the future likely entails greater risks of flooding, drought, and 

changes in the frequency and severity of storms.66 In addition, several 

organizations have predicted specific effects of climate change in the 

Great Lakes, which could negatively affect GLRI restoration efforts, such 

as to remove contaminated sediments from areas of concern or reduce 

the introduction of invasive species. For example, according to a 2000 

report by the U.S. Global Change Research Program, drought could lead 

to certain situations in the Great Lakes that may require additional 

dredging of sediments at an annual cost of from $75 million to $125

million—about $101.6 million to $129.6 million in 2013 dollars—simply to 

maintain shipping lanes.67 In addition, the U.S. Global Change Research 

Program reported in 2009 that warming water temperatures can lead to 

increased numbers of aquatic invasive species, which tend to thrive under 

a wide range of environmental conditions, and a decline in native species, 

which are adapted to a narrower range of conditions.68

One way to reduce the potential effects of climate change is to invest in 

enhancing resilience. As defined by the National Academies, resilience is 

the ability to prepare and plan for, absorb, recover from, and more 

successfully adapt to adverse events.

As we noted 

previously, invasive species such as the zebra mussel have caused 

extensive ecological and economic damage to the Great Lakes.

69

 

66The U.S. Global Change Research Program coordinates and integrates the activities of 

13 federal agencies that conduct research on changes in the global environment and their 

implications for society. For more information about the U.S. Global Change Research 

Program click http://www.globalchange.gov/. 

Enhanced resilience results from 

better planning to reduce losses, rather than waiting for an event to occur 

67U.S. Global Change Research Program, Great Lakes Regional Assessment Group, 

Preparing for Climate Change, The Potential Consequences of Climate Variability and 

Change (Ann Arbor, MI: October 2000). The range of $75 million to $125 million was 

calculated based on average dredging costs at the time of at least $10 to $12 per cubic 

yard—about $14 to $16 per cubic yard in 2013 dollars—in a situation with heightened 

demand for dredging services and 7.5 million cubic yards to 12.5 million cubic removed 

annually.

68U.S. Global Change Research Program, Global Climate Change Impacts in the United 

States (New York, NY: 2009).

69The National Academies, Committee on Increasing National Resilience to Hazards and 

Disasters; Committee on Science, Engineering, and Public Policy; Disaster Resilience: A 

National Imperative (Washington, D.C.: 2012). 
 

Page 50 GAO-13-797 Great Lakes Restoration Initiative

and paying for recovery afterward. Many jurisdictions in the Great Lakes 

region have recognized the threat of climate change and committed 

resources to prepare for its effects, according to a 2012 report focused on 

the region.70 Among these efforts, several Great Lakes states and the city 

of Chicago have each created climate change action plans that identify 

steps being taken to reduce the effects of climate change. For example, 

the city of Chicago identified the use of green roofs as one of many 

climate change mitigation and adaptation actions in its 2008 Chicago 

Climate Action Plan.

71 In its subsequent progress report, Chicago 

reported that more than 4 million square feet of green roofs had been 

planned or completed since 2008.72

In addition, some Great Lakes jurisdictions have recognized that climate 

change can exacerbate other factors that may limit Great Lakes 

restoration. As we reported in April 2013,

A green roof is a vegetative layer 

grown on a rooftop that provides shade and removes heat from the air, 

reducing temperatures of the roof surface and the surrounding air. As a 

result, green roofs act as insulators for buildings and reduce the energy 

needed to provide cooling and heating, which can decrease the 

production of associated air pollution and greenhouse gas emissions that 

contribute to climate change.

73

 

70For information about climate change adaptation efforts in the Great Lakes region, see 

R. M. Gregg, K. M. Feifel, J. M. Kershner, and J. L. Hitt, The State of Climate Change 

Adaptation in the Great Lakes Region (Bainbridge Island, WA: EcoAdapt, 2012), accessed 

June 11, 2013, http://ecoadapt.org/programs/state-of-adaptation/great-lakes-region. 

the Milwaukee Metropolitan 

Sewerage District officials employed what they called “green 

infrastructure” programs to make the district’s sewer system more 

resilient to climate change by capturing and holding or slowing the flow of 

stormwater. This was done as part of broader efforts to meet growing 

demand for sewer capacity, and officials plan to incorporate climate 

change adaptation into infrastructure planning and design where it makes 

sense as their facilities age and are replaced over time.

71City of Chicago, Chicago Climate Action Plan (Chicago, IL: Sept. 19, 2008), accessed 

June 20, 2013, http://www.chicagoclimateaction.org/. 

72City of Chicago, Chicago Climate Change Action Plan Progress Report: the First Two 

Years (Chicago, IL: June 23, 2010), accessed June 20, 2013,

http://www.chicagoclimateaction.org/pages/ccap_progress_report/81.php.

73GAO, Climate Change: Future Federal Adaptation Efforts Could Better Support Local 

Infrastructure Decision Makers, GAO-13-242 (Washington, D.C.: Apr. 12, 2013). 
 

Page 51 GAO-13-797 Great Lakes Restoration Initiative

The Action Plan does not include goals, objectives, or measures of 

progress that show how the GLRI should address inadequate 

infrastructure, the effects of climate change, or other key factors that may 

limit the Action Plan’s success and overall progress concerning the health 

of the Great Lakes ecosystem, with two exceptions.74 In some cases, 

such as with inadequate infrastructure for wastewater or stormwater and 

atmospheric deposition of pollutants from sources outside the Great 

Lakes Basin, the Action Plan notes that some of these issues are 

addressed by other federal programs. For example, the Action Plan 

states that infrastructure needs will be addressed through increased 

funding for EPA’s Clean Water State Revolving Funds, a program that 

provides states and local communities with independent and sustainable 

sources of financial assistance, such as low- or no-interest loans, to fund 

water quality projects identified by the states and localities. EPA reported 

in 2010 that the program has provided more than $74 billion for these 

projects since 1988.75 As we testified in March 2013, however, 

wastewater infrastructure needs are made more daunting by the limited 

resources and budgets facing all levels of government.76

The Action Plan acknowledges that the effects of climate change may 

have implications across all five of the Action Plan’s focus areas, and that 

the needs of communities to adapt to those effects will be assessed and 

addressed by GLRI projects and programs where appropriate. However, 

the Action Plan does not state how these effects will be addressed. To 

date, EPA has made some modest efforts to acknowledge the issue in 

the context of the Great Lakes. In its 2012 request for grant applications, 

for example, EPA included $200,000 for two to five grants for projects to 

increase climate change resiliency in Great Lakes communities. EPA also 

 

74One long-term goal and one objective in the Action Plan address the key factor of 

insufficient coordination between the United States and Canada. The goal is that work 

under the goals and objectives of the Great Lakes Water Quality Agreement is 

coordinated between the United States and Canada through Lakewide Management 

Plans and other binational processes. The objective is that, by 2012, improved 

coordination with Canada will take place for programs under the Great Lakes Water 

Quality Agreement, particularly under the Lakewide Management Plans, which will result 

in the achievement of five to ten priority Lakewide Management Plans goals and actions.

75EPA, Clean Water State Revolving Fund Programs 2009 Annual Report, EPA-832-R-10-

001 (Washington, D.C.: June 2010). 

76GAO, Water Infrastructure: Approaches and Issues for Financing Drinking Water and 

Wastewater Infrastructure, GAO-13-451T (Washington, D.C.: Mar. 13, 2013). 

Action Plan Does Not Clearly 

Account for Key Factors That 

May Limit Its Success and 

Overall Great Lakes 

Restoration Progress 
 

Page 52 GAO-13-797 Great Lakes Restoration Initiative

included an incentive in the request for applications for 2012 for the 

applicants to consider climate change impacts through vulnerability 

assessments or the integration of climate change adaptation measures 

into their project. Specifically, applicants could increase their eligibility for 

a grant by addressing climate change in their proposal.

The GLRI was created to accelerate the protection, maintenance, and 

restoration of the integrity of the Great Lakes. If the Action Plan does not 

state how the GLRI should address key factors—such as inadequate 

infrastructure and the effects of climate change—then the ability of 

restoration efforts guided by the Action Plan to achieve the GLRI’s goal is 

uncertain because these factors may negatively affect restoration efforts. 

EPA has acknowledged that the effects of climate change can be 

detrimental to the Great Lakes and stated in its fiscal year 2013 budget 

justification that it is imperative that consideration of climate change and 

climate adaptation be integrated into GLRI grants and projects to ensure 

the overall success of the GLRI.77

As directed by Congress, EPA and the other Task Force agencies began 

implementing the GLRI in fiscal year 2010 to address the stresses that 

threaten the health of the Great Lakes ecosystem and help restore the 

health of the Great Lakes and issued the GLRI Action Plan to guide 

implementation of the approximately $1.3 billion appropriated to the 

program. A collaborative and comprehensive approach, it is clear that 

both federal and nonfederal GLRI stakeholders believe that the program 

is making strides toward its goals. For example, GLRI efforts enabled 

EPA to remove the Presque Isle Bay area of concern from the list of 

Nonetheless, to date, EPA has made 

few connections between this key issue and the potential effects of 

climate change. At a series of public meetings and webinars beginning in 

May 2013, EPA requested input regarding whether the connection 

between the Action Plan focus areas and the protection of the Great 

Lakes from the effects of climate change should be expressed more 

clearly in the next Action Plan. In commenting on a draft of this report, 

EPA officials told us that they have heard from many stakeholders about 

the need for the fiscal year 2015 to 2019 Action Plan to place additional 

emphasis on climate change, and that there is broad agreement on this 

point among the task force agencies.

 

77EPA, Fiscal Year 2013 Justification of Appropriation Estimates for the Committee on 

Appropriations, EPA-190-R-12-001 (Washington, D.C.: 2012).

Conclusions 
 

Page 53 GAO-13-797 Great Lakes Restoration Initiative

areas of concern identified by the United States and Canada. 

Nonetheless, the threats to the Great Lakes persist, and EPA and the 

other Task Force agencies face significant challenges in ensuring the 

future success of the GLRI due to issues involving their abilities to assess 

and achieve progress. EPA and the Task Force agencies are currently 

obtaining input for the next version of the GLRI Action Plan for fiscal 

years 2015 to 2019.

EPA has assessed GLRI progress primarily by using information from 

various sources to determine whether the GLRI is meeting the annual 

targets for the 28 measures in the Action Plan. Assessments of GLRI 

progress could help GLRI stakeholders, Congress, and the public discern 

the extent to which the health of the Great Lakes ecosystem has been 

restored, as well as what has been achieved by the approximately $1.3 

billion appropriated to the program since fiscal year 2010. Moreover, such 

assessments can be used by EPA and the Task Force agencies to 

assess the effectiveness of GLRI actions and adjust their efforts if 

needed. However, we believe EPA is not well positioned to produce 

comprehensive and useful assessments for several reasons. Specifically:

• Some of the Action Plan’s long-term goals and objectives do not have 

measures of progress that link to them. We believe that clear linkages 

between a plan’s goals, objectives, and measures are critical to 

achieving and assessing progress over time. Without such linkages in 

the current Action Plan, it is unclear how EPA will be able to assess 

progress in meeting the Action Plan’s long-term goals and objectives.

• Similarly, without identifying linkages between long-term goals, 

objectives, and measures in the Action Plan for 2015 to 2019 now 

under development, it is unclear how EPA will be able assess 

progress in meeting the long-term goals and objectives in that plan.

• The measures of progress do not capture the results of many of the 

GLRI projects because more than half of the projects are not 

associated with an Action Plan measure of progress in GLAS, which 

is a mechanism EPA created for collecting information to monitor 

GLRI projects and progress. We recognize that some projects do not 

directly provide data for any of the Action Plan’s 28 measures, and 

that the cumulative results of some of the projects without assigned 

measures may ultimately be captured by some of the existing 

measures. With so many instances in which a project does not have 

an assigned measure, it is unclear if EPA will have the information it 

needs to capture the results of these projects and, therefore, if the 
 

Page 54 GAO-13-797 Great Lakes Restoration Initiative

agency can assess the full extent of progress being made.

• GLRI projects may directly address multiple measures of progress, 

but GLAS limits users to reporting the information for just one 

measure for each project even if more measures are being 

addressed. Without complete progress information on GLRI projects, 

the data EPA is using for certain measures of progress cannot be 

complete, and EPA may be underreporting GLRI progress. EPA 

officials told us that they will consider addressing this limitation in 

GLAS, but they did not specify a time frame for doing so.

• Some Action Plan measures or targets may not be useful because, 

among other things, they track activities that may not be sufficient to 

lead to the desired GLRI goals. Without useful measures, EPA may 

not be able to determine that GLRI efforts are producing the desired 

results.

• EPA and the Task Force agencies have not fully established an 

adaptive management plan. Although there is no requirement that the 

Task Force agencies establish an adaptive management plan for the 

GLRI, EPA and several of the Task Force agencies agreed in a 2000 

to incorporate adaptive management principles into their programs. 

EPA and the Task Force agencies recently issued a plan that includes 

most but not all of the key elements of adaptive management, and it 

does not provide details on how the elements of adaptive 

management will be implemented. Without a fully established 

adaptive management plan, EPA and the other Task Force agencies 

may be limited in their ability to assess the effectiveness of GLRI 

efforts and adjust future actions to achieve the goals and objectives of 

the GLRI as results and ecosystem processes become better 

understood.

We recognize the potentially significant contributions that individual GLRI 

projects can make to resolving specific environmental and public health 

stresses that threaten the Great Lakes. However, we believe that these 

contributions need to be viewed in the context of larger factors affecting 

the Great Lakes, in order to more fully appreciate the long-term future of 

the Great Lakes and to develop optimal strategies to help ensure the best 

possible outcome. Some of these factors can lead to problems that will be 

very expensive to address. Most notably, inadequate infrastructure for 

wastewater and stormwater and the effects of climate change may lead to 

conditions that can negatively affect GLRI restoration efforts. One way to 

reduce the potential impacts of climate change is to invest in planning to 

reduce losses, rather than waiting for an event to occur and paying for 
 

Page 55 GAO-13-797 Great Lakes Restoration Initiative

recovery afterward. The Action Plan touches on these factors, but it does 

not directly address how these factors may affect GLRI efforts to restore 

the health of the Great Lakes ecosystem or provide strategies to address 

them. Without more clearly expressing that connection in the next Action 

Plan, EPA will not be able to help address the effects of these factors, 

including climate change, on GLRI restoration efforts. 

To address challenges the Task Force faces in producing comprehensive 

and useful assessments of progress and addressing factors that may limit 

GLRI progress, we recommend that the EPA Administrator, in 

coordination with the Task Force, as appropriate, take the following seven 

actions:

• ensure progress toward long-term goals or objectives that are 

identified in the Action Plan, but which do not have measures that link 

to them, is assessed;

• ensure that linkages between long-term goals, objectives, and 

measures are identified in the Action Plan for 2015 to 2019;

• ensure that the progress being made by projects that do not have an 

Action Plan measure assigned to them is captured in assessments of 

GLRI progress;

• capture complete information about progress for each of the 

measures that are addressed by a project;

• further evaluate the usefulness of the current measures and targets 

and the need, if any, for the creation of additional measures;

• establish an adaptive management plan that includes all of the key 

elements of adaptive management and provides details on how these 

elements will be implemented; and

• address how factors outside of the scope of the Action Plan that may 

limit progress, such as inadequate infrastructure for wastewater or 

stormwater and the effects of climate change, may affect GLRI efforts 

to restore the Great Lakes.

Recommendations for 

Executive Action
 

Page 56 GAO-13-797 Great Lakes Restoration Initiative

We provided a draft of this report to EPA, the Departments of Agriculture, 

Commerce, Defense, Health and Human Services, Homeland Security, 

the Interior, State, and Transportation, and the Council on Environmental 

Quality for comment. In written comments from the EPA Region 5 

Administrator, which are reproduced in appendix II, EPA generally agreed 

with the conclusions and recommendations in our report. EPA noted in 

particular that our report is well-timed because it comes at the beginning 

of a new 5-year GLRI planning cycle. The agency also noted that we 

rightly acknowledged the complexity of assessing and quantifying overall 

Great Lakes health, the difficulty of attributing specific environmental 

changes to specific projects or programs, and the slow pace of 

ecosystem change. 

In addition, EPA noted that the agency is already taking actions 

consistent with our recommendations, including working to develop more 

appropriate measures of progress in the Action Plan for fiscal years 2015 

to 2019 and finalizing the draft framework. The agency also noted it is 

working with the task force agencies to link all activities described in 

interagency agreements to goals, objectives, and measures of progress 

in the Action Plan to help to track projects where there is not currently an 

associated measure of progress for which data can be reported in GLAS. 

EPA also noted that the agency has heard from many stakeholders about 

the need for the next Action Plan to place additional emphasis on climate 

change, and that there is broad agreement on this point from Task Force 

agencies. Taken together, we believe comprehensive actions along the 

lines stated in the EPA letter would constitute important steps forward, 

and we will look forward to seeing the progress the agency has made in 

taking these actions in the 2015 to 2019 Action Plan. 

In written comments from the Department of the Interior’s Assistant 

Secretary for Policy, Management, and Budget, which are reproduced in 

appendix III, Interior noted that information in our report is accurate and 

relevant, and the agency acknowledged the challenges in quantifying the 

progress toward restoration goals that we identified in our report. The 

Department of Agriculture provided technical comments but did not 

comment on our recommendations. Its letter is reproduced in appendix 

IV.

In addition to these written comments, the Council on Environmental 

Quality submitted an e-mail on September 13, 2013, that further 

emphasized our findings on the need for accountability. Specifically, this 

e-mail stated that GLAS limitations have led to an underreporting of 

progress for certain measures, so that they are not most accurately 

Agency Comments 

and Our Evaluation
 

Page 57 GAO-13-797 Great Lakes Restoration Initiative

reflecting what benefits are accruing under the measures and projects 

implemented. EPA and the Departments of Agriculture, the Interior, and 

Transportation, provided technical comments that we incorporated as 

appropriate. 

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 Administrator of the 

EPA, the appropriate congressional committees, and other interested 

parties. In addition, the report will be available at no charge on the GAO 

website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or gomezj@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 significant contributions 

to this report are listed in appendix VII. 

J. Alfredo Gómez

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 58 GAO-13-797 Great Lakes Restoration Initiative

This appendix provides information on the scope of work and the 

methodology used to examine (1) how the Great Lakes Restoration 

Initiative (GLRI) is implemented by the Task Force agencies and other 

stakeholders; (2) the methods that the Environmental Protection Agency 

(EPA) has in place to assess GLRI progress; (3) the progress identified 

by the Task Force agencies and nonfederal stakeholders; and (4) the 

views of nonfederal stakeholders on factors, if any, that may affect or limit 

GLRI progress.

To examine how the GLRI is implemented by the Great Lakes 

Interagency Task Force (Task Force) agencies and other stakeholders 

we analyzed key documents and interviewed individuals involved with the 

GLRI.1 Specifically, we analyzed the Great Lakes Restoration Initiative 

Action Plan Fiscal Years 2010-2014 (Action Plan) to understand its 

structure and identify the long-term goals, objectives, measures of 

progress and related annual targets, and principal actions in each of the 

Action Plan’s five focus areas; 2 EPA GLRI financial reports and the 

agency’s fiscal year 2014 budget justification to determine the amount of 

GLRI funds that have been allocated for fiscal years 2010 to 2013 to each 

Task Force agency and each focus area; and, information from the Great 

Lakes Accountability System (GLAS) to identify the number of GLRI 

projects in each focus area and to learn more about GLRI projects, such 

as location, size, and funding.3

 

1

The Task Force is chaired by the EPA Administrator, and includes senior officials from 

the U.S. Departments of Agriculture, Commerce, Defense, Health and Human Services, 

Homeland Security, Housing and Urban Development, the Interior, State, and 

Transportation and the White House Council on Environmental Quality. The subagencies 

within the Task Force agencies that are responsible for implementing the GLRI are: the 

Department of Agriculture’s Animal and Plant Health Inspection Service, Forest Service, 

and Natural Resources Conservation Service; the Department of Commerce’s National 

Oceanic and Atmospheric Administration; the Department of Defense’s U.S. Army Corps 

of Engineers; the Department of Health and Human Services’ Agency for Toxic 

Substances and Disease Registry; the Department of Homeland Security’s Coast Guard; 

the Department of the Interior’s Bureau of Indian Affairs, Fish and Wildlife Service, 

National Park Service, and U.S. Geological Survey; and the Department of 

Transportation’s Federal Highway Administration and Maritime Administration. We refer to 

all 16 Task Force agencies and subagencies collectively as Task Force agencies in this 

report, as is the case on the GLRI website http://greatlakesrestoration.us/priorities.html.

We also reviewed interagency 

2

Great Lakes Interagency Task Force, Great Lakes Restoration Initiative Action Plan

Fiscal Years 2010-2014 (Washington, D.C.: Feb. 21, 2010). 

3

GLAS is a mechanism for collecting information to monitor GLRI projects and progress 

and was created by EPA.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 59 GAO-13-797 Great Lakes Restoration Initiative

agreements between EPA and the Task Force agencies that identify the 

amount of GLRI funds EPA will allocate to each agency and the GLRI 

projects the agencies will implement. In addition, we conducted interviews 

with federal stakeholders, officials from EPA headquarters, EPA’s office 

responsible for implementing the GLRI, the Great Lakes National 

Program Office, and the other Task Force agencies. We also interviewed 

representatives from nonfederal GLRI stakeholders—such as the Nature 

Conservancy and the Great Lakes Indian Fish and Wildlife 

Commission4

—and a prominent Great Lakes interest group, Healing Our 

Waters – Great Lakes Coalition, to gain an understanding of the GLRI 

and how it is implemented.5

To examine the methods that EPA has in place to assess GLRI progress, 

we analyzed the Action Plan, documentation about GLAS, information 

from GLAS about GLRI project measures of progress,

Nonfederal stakeholders are state and local 

governments, tribes, nongovernmental organizations, and academic 

institutions that have received GLRI funds. We also attended the Eighth 

Annual Great Lakes Restoration Conference in Cleveland in September 

2012 to learn more about the GLRI and Great Lakes restoration, and 

webinars to learn about the GLRI grant application process and how to 

use GLAS.

6 information 

provided by EPA on the sources of data for each of the plan’s measures 

of progress, the draft GLRI Adaptive Science-Based Framework for Great 

Lakes Restoration (draft Framework), and EPA’s Science Advisory 

Board’s 2012 review of the Action Plan.7

 

4

The Nature Conservancy is a nonprofit conservation organization that works to protect 

ecologically important lands and water for nature and people, and the Great Lakes Indian 

Fish and Wildlife Commission provides natural resource management expertise and 

conservation enforcement, among other things, in support of the 11 Great Lakes tribes it 

represents.

We interviewed EPA officials to 

5

The Healing Our Waters – Great Lakes Coalition consists of more than 120 

environmental, conservation, and outdoor recreation organizations, zoos, aquariums and 

museums, and works to secure a sustainable Great Lakes restoration plan and implement 

it. 

6

We reviewed GLAS, and not the other sources of progress information—such as from 

other federal agencies, states, and universities—because EPA officials told us that it is the 

only new database created by EPA for the purpose of assessing GLRI progress. We did 

not use information in GLAS that was entered by users for the purpose of describing 

progress made by GLRI projects because of concerns raised by EPA about the quality of 

that information.

7

EPA Science Advisory Board, Review of Great Lakes Restoration Initiative Action Plan

(Washington, D.C.: Jan. 24, 2012). 
Appendix I: Objectives, Scope, and 

Methodology

Page 60 GAO-13-797 Great Lakes Restoration Initiative

discuss their methods of assessing GLRI progress. We used the 

interviews with Task Force agency officials described above, and we 

conducted interviews with relevant officials from each of the Great Lakes 

states—Illinois, Indiana, Michigan, Minnesota, New York, Ohio, 

Pennsylvania, and Wisconsin—to discuss the Action Plan. We also 

conducted interviews with subject matter experts, to obtain their views 

about the achievability and usefulness of the Action Plan’s measures of 

progress and related annual targets.

As part of our analysis of the Action Plan, we evaluated the extent to 

which the long-term goals and objectives in the plan have corresponding 

measures of progress. One analyst first compared the objectives for each 

focus area with the goals. The analyst considered whether it appeared 

that an objective would clearly contribute to attaining a goal. For example, 

in the invasive species focus area, the objective of developing and 

refining/piloting technologies that contain or control invasive species 

appears to clearly contribute to attaining the goal of preventing the spread 

of invasive species. The analyst also considered whether there was 

consistent or similar language in any of the goals and objectives that 

helped identify links between them. For example, the analysts examined if 

aspects of a goal in one focus area could be identified in an objective in 

the same focus area, such as in the toxic substances and areas of 

concern focus area, we identified similar language between the objective 

of reducing the concentrations of polychlorinated biphenyls (PCBs) in fish 

through 2014 and the goal of reducing environmental levels of toxic 

chemicals to the point that all restrictions on the consumption of Great 

Lakes fish can be lifted. Objectives could correspond to multiple goals. 

The analyst then compared the measures for each focus area to the 

objectives and looked for consistent or similar language in any of them 

that helped identify links between the objectives and measures. The 

analyst considered whether a measure was closely related to an objective 

and whether it appeared that progress toward at least part of the objective 

could clearly be assessed by a corresponding measure of progress. 

Measures could correspond to multiple objectives. We requested 

additional information from EPA officials on goals, objectives, and 

measures as needed to improve our understanding of them. A second 

analyst examined the conclusions of the first. In cases where there were 

initially disagreements between the two analysts regarding the 

identification of linkages between goals, objectives, and measures, all 

disagreements were resolved through analyst discussions. Ultimately, 

there was 100 percent agreement between the analysts. In addition, we 

evaluated the extent to which EPA and the Task Force agencies had 

established an adaptive management plan for the GLRI by first reviewing 
Appendix I: Objectives, Scope, and 

Methodology

Page 61 GAO-13-797 Great Lakes Restoration Initiative

guidance from several Task Force agencies to identify key elements of 

adaptive management. We then examined the extent to which the GLRI 

Action Plan and draft Framework addressed those elements.

For our interviews with officials from each of the Great Lakes states, we 

developed a set list of open-ended questions for these interviews to 

obtain official’s views about the Action Plan, among other things. We 

identified the state agencies that we would contact by starting with the list 

of state agencies identified at EPA’s Great Lakes website as interested 

parties.8

For the interviews with subject matter experts, we developed a set list of 

questions about the Action Plan’s long-term goals, objectives, and 

measures of progress. The experts we interviewed included state agency 

officials, members of academia, and representatives of nongovernmental 

organizations who had expertise in one or more of the Action Plan’s five 

focus areas. We identified these experts by asking for recommendations 

of at least three experts in each of the focus areas from 24 

representatives of nonfederal Great Lakes stakeholders or Great Lakes 

interest groups organizations: 12 were nonfederal attendees of the Eighth 

Annual Great Lakes Restoration Conference that we selected randomly to 

conduct interviews about the Action Plan and the GLRI, and 12 were 

representatives of nonfederal organizations that we contacted as part of 

We then contacted officials from each interested party to 

determine if their agency was the lead GLRI agency for the state or to 

learn if we should contact a different agency. As a result of this process, 

we identified the following as lead GLRI state agencies: the Illinois 

Department of Natural Resources; the Indiana Department of 

Environmental Management; the Michigan Department of Environmental 

Quality; the Minnesota Pollution Control Agency; the New York 

Department of Environmental Conservation; the Ohio Lake Erie 

Commission; the Pennsylvania Department of Environmental Protection; 

and, the Wisconsin Department of Natural Resources.

 

8

For EPA’s list of Great Lakes interested parties, click

http://www.epa.gov/greatlakes/parties/states.html. 
Appendix I: Objectives, Scope, and 

Methodology

Page 62 GAO-13-797 Great Lakes Restoration Initiative

learning more about the GLRI and the Great Lakes.9 We received 

responses from 17 of the 24 individuals who recommended a total of 187 

subject matter experts.10 We then created a list of the 33 experts who had 

been recommended two or more times and invited 31 of them to 

participate in interviews to obtain their views on the Action Plan goals, 

objectives, and measures of progress, among other things.11

To examine the progress identified by the Task Force agencies and 

nonfederal stakeholders, we took several steps: we reviewed the fiscal 

year 2010 and 2011 GLRI progress reports that EPA and the other Task 

Force agencies issued to Congress in April and March 2013, 

respectively;

Of those 31 

experts, 21 agreed to be interviewed: five experts in focus area one; six 

experts in focus area two; three experts in focus area three; four experts 

in focus area four; and three experts in focus area five. Because we used 

a nonprobability sample, the information obtained from these interviews is 

not generalizable to other individuals with expertise in the Action Plan 

focus areas but provides illustrative information.

12

 

9

We conducted interviews with 19 randomly selected, nonfederal individuals at the 

conference. These individuals were either representatives of nonfederal GLRI 

stakeholders or Great Lakes interest groups. The number of conference attendees we 

were able to interview was determined by the number of attendees who were available at 

the times that we sought out interviewees and were in same location of where we sought 

out interviewees, and the willingness of the attendees we approached to participate in the 

interview. Twelve of these individuals recommended subject matter experts.

we administered a web-based survey to each of the 205 

nonfederal stakeholders that, as of October 2012, had received GLRI 

funds from a Task Force agency and had a project identified in GLAS; we 

used the interviews with officials from each Task Force agency identified 

above; and, we visited several GLRI projects in Illinois. 

10One of the 17 individuals recommended 21 subject matter experts in a focus area. 

11We did not invite two subject matters experts to participate. This is because one expert 

had already provided a lot of information to this report, and we wanted to minimize the 

response burden. In addition, another expert had demonstrated in a previous interview 

that he shared the same opinions as a subject matter expert in the same focus area who 

works for the same organization and who we had already interviewed, and we wanted to 

minimize the likelihood of duplicate responses. In each case, we interviewed four or more 

other experts in the relevant focus areas.

12EPA in partnership with the Great Lakes Interagency Task Force, Great Lakes 

Restoration Initiative Fiscal Year 2010 Report to Congress and the President, 

(Washington, D.C.: March 2011), and EPA in partnership with the Great Lakes 

Interagency Task Force, Great Lakes Restoration Initiative Fiscal Year 2011 Report to 

Congress and the President (Washington, D.C.: September 2011).
Appendix I: Objectives, Scope, and 

Methodology

Page 63 GAO-13-797 Great Lakes Restoration Initiative

We conducted a web-based survey of all of the nonfederal GLRI 

stakeholders that have reported projects in GLAS, as of October 10, 

2012, to identify examples of GLRI progress by obtaining their views on 

how their GLRI projects have benefited the ecosystem, among other 

things. The questionnaire used for this study is in appendix V. EPA 

provided us with contact information for each of those stakeholders, and 

we sent at least one e-mail to a point of contact from each stakeholder to 

identify the best point of contact for our survey. We surveyed the universe 

of the 205 nonfederal stakeholders that have projects in GLAS, as of 

October 10, 2012, and received responses from 176 nonfederal GLRI 

stakeholders for a response rate of 86 percent.

We designed draft questionnaires in close collaboration with a GAO 

social science survey specialist. We conducted pretests with three 

nonfederal GLRI stakeholders to help further refine our questions, 

develop new questions, and clarify any ambiguous portions of the survey. 

We conducted the pretests over the phone, and we selected one GLRI 

nonfederal stakeholder that had received GLRI funds for one grant and 

two GLRI nonfederal stakeholders that had each received GLRI funds for 

multiple grants for the pretest.

We developed and administered the web-based questionnaire accessible 

through a secure server, and we e-mailed unique identification numbers 

and passwords to points of contact at the 205 nonfederal GLRI 

stakeholders February 4, 2013. We sent follow-up e-mail messages 

beginning February 11, 2013. Then we contacted all remaining

nonrespondents by telephone, starting February 26, 2013. The 

questionnaire was available online until March 28, 2013. For questions 

that should have been skipped but were not, we attempted to contact the 

respondents for clarification and edited their responses where warranted.

Because this was not a sample survey, it has no sampling errors. 

However, the practical difficulties of conducting any survey may introduce 

errors, known as nonsampling errors. For example, difficulties in 

interpreting a particular question, sources of information available to 

respondents, or when entering data into a questionnaire or analyzing the 

data can introduce unwanted variability into the survey results. We took 

steps in developing our questionnaire, collecting the data, and analyzing it 

to minimize these errors. In addition, as indicated above, social science 

survey specialists designed the questionnaire in collaboration with GAO 

staff that had subject matter expertise. We then conducted three pretests 

to check that (1) the questions were clear and unambiguous, (2) 

terminology was used correctly, (3) the questionnaire did not place an 
Appendix I: Objectives, Scope, and 

Methodology

Page 64 GAO-13-797 Great Lakes Restoration Initiative

undue burden on respondents, (4) the information could feasibly be 

obtained, and (5) the survey was comprehensive and unbiased. We made 

multiple contact attempts with nonrespondents during the survey by email, and some nonrespondents were also contacted by telephone. When 

we analyzed the data, an independent analyst checked all computer 

programs. Since this was a web-based survey, respondents entered their 

answers directly into the electronic questionnaire, eliminating the need to 

key data into a database, minimizing error.

We conducted a computer-enabled content analysis to analyze 

responses to the question “Please provide examples of how one or more 

of your organization’s GLRI projects have benefitted the Great Lakes 

ecosystem.” Of the 176 respondents, 163 provided information in 

response to this question. We categorized the responses along two 

dimensions: direct and indirect benefits, and observed or expected 

benefits. We defined these categories based on whether respondents 

reported that their organization’s GLRI projects resulted in changes in the 

ecosystem, such as reduced beach closure days, or other types of 

changes, such as improved understanding of the ecosystem, and if 

respondents reported that they had observed the result or expected to 

observe them a later time. One reviewer developed content categories 

based on survey responses and, after obtaining agreement on the 

categories from the second reviewer, assessed and coded each survey 

response into those categories. The second reviewer examined the 

coding. In cases where disagreements among the two reviewers 

regarding the coding of responses into content categories were found, all 

disagreements were resolved through reviewer discussion. Ultimately, 

there was 100 percent agreement between the reviewers. In addition, we 

conducted follow-up interviews by phone and e-mail with those survey 

respondents whose examples we wanted to include in the report to collect 

clarifying information, if necessary.

In addition to the survey, we used the interviews with Task Force agency 

officials identified above to obtain information about GLRI progress. We 

also visited several GLRI projects in Illinois. We traveled to Illinois 

because EPA’s Great Lakes National Program Office is located in 

Chicago. We met with representatives from two nonfederal GLRI 

stakeholders who took us to the sites of their GLRI projects; the two 

nonfederal GLRI stakeholders—the Chicago Park District and Waukegan 

Harbor Citizens Advisory Group—were recommended to us by an official 

from the Illinois Department of Natural Resources.
Appendix I: Objectives, Scope, and 

Methodology

Page 65 GAO-13-797 Great Lakes Restoration Initiative

To examine the views of nonfederal stakeholders on factors, if any, that 

may affect or limit GLRI progress, we used the web-based survey 

described above. Specifically, we used the survey to obtain nonfederal 

GLRI stakeholder views about factors that may have limited their ability to 

carry out GLRI projects and factors that have the potential to affect the 

restoration of Great Lakes health. As part of creating the survey, we 

developed lists of factors that might limit GLRI project implementation 

progress and factors that might limit the restoration of Great Lakes health 

in general through interviews we conducted with 19 randomly selected 

individuals at the Eight Annual Great Lakes Restoration Conference and 

interviews we conducted with representatives from five nonfederal GLRI 

stakeholders and one Great Lakes interest group. We narrowed the list of 

factors that might limit GLRI project implementation progress to four 

factors most often cited by interviewees as hindering their abilities to start 

a project or to successfully carry out a project, and asked survey 

respondents if they had experienced these factors and about the effects 

of each of these factors on their GLRI projects. We narrowed the list of 

factors that might limit the restoration of Great Lakes health in general to 

the nine factors most often cited by grouping similar factors together and 

eliminating those factors that are addressed by the Action Plan either 

through Action Plan long-term goals, objectives, or measures of progress. 

We eliminated those factors addressed by the Action Plan because this 

meant they had already been identified by the GLRI as factors that had 

the potential to limit restoration of Great Lakes health. We asked survey 

respondents to identify the extent to which each of these factors had the 

potential to limit the restoration of the health of the Great Lakes 

ecosystem.

We also used the interviews with subject matter experts mentioned above 

to obtain information about the factors that may limit progress by asking 

them to identify the extent to which each of the same nine factors we 

included in the survey had the potential to limit the restoration of the 

health of the Great Lakes ecosystem.

We conducted this performance audit from June 2012 to September 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Environment 

Protection Agency

Page 66 GAO-13-797 Great Lakes Restoration Initiative

Appendix II: Comments from the 

Environment Protection Agency
Appendix II: Comments from the Environment 

Protection Agency

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Appendix II: Comments from the Environment 

Protection Agency

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Appendix III: Comments from the Department 

of the Interior

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Appendix III: Comments from the 

Department of the Interior
Appendix IV: Comments from the Department 

of Agriculture

Page 70 GAO-13-797 Great Lakes Restoration Initiative

Appendix IV: Comments from the 

Department of Agriculture
Appendix V: Survey Questions

Page 71 GAO-13-797 Great Lakes Restoration Initiative

We conducted a web-based survey of nonfederal GLRI stakeholders that 

have reported projects in the Great Lakes Accountability System, as of 

October 10, 2012, using all of the questions below as stated here.1 Nonfederal stakeholders are state and local governments, tribes, 

nongovernmental organizations, and academic institutions that that have 

received GLRI funds. 

 

1

The Great Lakes Accountability System is a mechanism for collecting information to 

monitor GLRI projects and progress and was created by EPA. 

Appendix V: Survey Questions
Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix V: Survey Questions

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Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 84 GAO-13-797 Great Lakes Restoration Initiative

The GLRI Action Plan for fiscal years 2010 to 2014 is organized by five 

focus areas that, according to the federal agencies responsible for 

implementing the GLRI, encompass the most significant environmental 

problems in the Great Lakes: (1) toxic substances and areas of concern; 

(2) invasive species; (3) nearshore health and nonpoint source pollution; 

(4) habitat and wildlife protection and restoration; and (5) accountability, 

education, monitoring, evaluation, communication and partnerships. Each 

focus area includes several long-term goals to address these problems, 

as well as objectives to be completed within the 5 years of the plan and 

measures of progress to ensure that efforts are on track to meet the longterm goals.

• Goal 1: Areas of concern are cleaned up, restoring the areas and 

removing the beneficial use impairments.

• Goal 2: The release of toxic substances in toxic amounts is prevented 

and the release of any or all persistent toxic substances to the Great 

Lakes Basin ecosystem is virtually eliminated.

• Goal 3: Exposure to toxic substances from historically contaminated 

sources is significantly reduced through source reduction and other 

exposure reduction methods.

• Goal 4: Environmental levels of toxic chemicals are reduced to the 

point that all restrictions on the consumption of Great Lakes fish can 

be lifted.

• Goal 5: The health and integrity of wildlife populations and habitat are 

protected from adverse chemical and biological effects associated 

with the presence of toxic substances in the Great Lake Basin.

• By 2014, delist five areas of concern.

• By 2014, 46 beneficial use impairments will be removed in areas of 

concern.

Appendix VI: Great Lakes Restoration 

Initiative Action Plan Long-term Goals, 

Objectives, and Measures of Progress for 

Each of the Five Focus Areas

Focus Area One, 

Toxic Substances and 

Areas of Concern

Long-term Goals

Objectives
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 85 GAO-13-797 Great Lakes Restoration Initiative

• By 2011, 15 million pounds of electronic waste and 15 million pills of 

unwanted medicines will be collected or their release will have been 

prevented.

• By 2014, 45 million pounds of e-waste, 45 million pills of unwanted 

medicines, and 4.5 million pounds of household hazardous waste in 

the Great Lakes Basin will have been collected or their release will 

have been prevented.

• By 2014, 9.4 million cubic yards of contaminated sediments will be 

remediated.

• Through 2014, an annual average of up to 5 percent annual decline 

will be maintained or improved for the trend (year 2000 and on) in 

average concentrations of PCBs in whole lake trout and walleye 

samples.

• Number of areas of concern in the Great Lakes where all 

management actions necessary for delisting have been implemented 

(cumulative).

• Area of concern beneficial use impairments removed (cumulative).1

• Beneficial use impairment delisting project starts at areas of concern 

(cumulative).2

• Cubic yards (in millions) of contaminated sediment remediated in the 

Great Lakes (cumulative).3

• Pollution (in pounds) collected through prevention and waste 

minimization projects in the Great Lakes Basin (cumulative).

 

1

This is an existing measure [used in the agency’s performance plan and performance 

report, which are required by the Government Performance Results Act, as amended].

2

These projects represent on-the-ground actions that are being implemented in order to 

remove beneficial use impairments. For example, sediment removals, Superfund 

cleanups, habitat projects and others.

3

This is an existing measure [used in the agency’s performance plan and performance 

report, which are required by the Government Performance Results Act, as amended].

Measures of Progress
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 86 GAO-13-797 Great Lakes Restoration Initiative

• Cumulative percentage decline for the long term trend in average 

concentrations of PCBs in Great Lakes fish.4

• Goal 1: The introduction of new invasive species to the Great Lakes 

Basin ecosystem is eliminated, reflecting a “zero tolerance policy” 

toward invasives.

• Goal 2: The risk of introduction of species, which are imported for 

various uses, in the Great Lakes is minimized.

• Goal 3: The spread of invasive species, by means of recreational 

activities, connecting waterways, and other vectors, beyond their 

current range is prevented.

• Goal 4: A comprehensive program for detection and tracking newly 

identified invasive species in the Great Lakes is developed and 

provides up-to-date critical information needed by decision makers for 

evaluating potential rapid response actions.

• Goal 5: An effective, efficient and environmentally sound program of 

integrated pest management for invasive species is developed and 

implemented, including program functions of containment, eradication, 

control, and mitigation.

• By 2011, eight state aquatic nuisance species management plans will 

be established or revised to include rapid response capabilities. By 

2014, eight state-based, multiagency rapid response plans will be 

implemented and 22 mock exercises to practice responses carried out 

under those plans and/or actual response actions will be completed.

 

4

The annual decline is 5 percent per year. This is based on an existing measure [used in 

the agency’s performance plan and performance report, which are required by the 

Government Performance Results Act, as amended]. In fiscal year 2010, 2008 data are 

compared to 2000 data; in fiscal year 2011, 2009 data are compared to 2000 data; and so 

forth. PCBs are one indicator for a broader suite of persistent toxic substances and one of 

a number being tracked.

Focus Area Two, 

Invasive Species

Long-term Goals

Objectives
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 87 GAO-13-797 Great Lakes Restoration Initiative

• Six technologies that prevent the introduction of invasive species and 

four technologies that either contain or control invasive species will be 

developed or refined and piloted by 2011. Ten technologies that 

prevent the introduction of invasive species and five technologies that 

either contain or control invasive species will be developed or refined 

and piloted by 2014.

• By 2011, methodology and protocols will be piloted for the 

coordinated monitoring methodology and shared protocols for 

basinwide invasive species surveillance. By 2014, a basinwide 

surveillance program with shared sampling protocols and 

methodologies to provide early detection of nonnative species will be 

operational.

• By 2014, a 40 percent reduction in the yearly average rate of invasive 

species newly detected in the Great Lakes ecosystem will be 

achieved, compared with the period 2000-2009.

• By 2014, invasive species populations within the Great Lakes 

ecosystem will have been controlled and reduced, as measured in 

populations controlled to a target level in 6,500 acres of managed 

area and by removing 5,000 pounds of invasive species from the 

Great Lakes ecosystem.

• By 2014, approximately 10 million recreation and resource users will 

be educated on best practices that prevent the introduction and 

spread of invasive species.

• Rate of nonnative species newly detected in the Great Lakes 

ecosystem.

• Acres managed for populations of invasive species controlled to a 

target level (cumulative).

• Number multiagency plans established, mock exercises to practice 

rapid responses carried out under those plans, and/or actual rapid 

response actions (cumulative).

• Number of recreation and resource users contacted on best practices 

that prevent the introduction and spread of invasive species 

(cumulative).

Measures of Progress
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 88 GAO-13-797 Great Lakes Restoration Initiative

• Goal 1: Nearshore aquatic communities consist of healthy, selfsustaining plant and animal populations dominated by native and 

naturalized species.

• Goal 2: Land use, recreation, and economic activities are managed to 

ensure that nearshore aquatic, wetland, and upland habitats will 

sustain the health and function of natural communities.

• Goal 3: The presence of bacteria, viruses, pathogens, nuisance 

growths of plants or animals, objectionable taste or odors, or other 

risks to human health are reduced to levels in which water quality 

standards are met and beneficial uses attained to protect human use 

and enjoyment of the nearshore areas.

• Goal 4: High-quality bathing beach opportunities are maintained by 

eliminating impairments from bacterial, algal, and chemical 

contamination; effective monitoring for pathogens; effective modeling 

of environmental conditions, where appropriate; and timely 

communications to the public about beach health and daily swimming 

conditions.

• Goal 5: A significant reduction in soil erosion and the loading of 

sediments, nutrients, and pollutants into tributaries is achieved 

through greater implementation of practices that conserve soil and 

slow overland flow in agriculture, forestry and urban areas.

• Goal 6: High quality, timely and relevant information about the 

nearshore areas is readily available to assess progress and to inform 

enlightened decision making.

• By 2010, EPA will compile and map the highest priority watersheds for 

implementation of targeted nonpoint source pollution control 

measures.

Focus Area Three, 

Nearshore Health and 

Nonpoint Source 

Pollution

Long-term Goals

Objectives
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 89 GAO-13-797 Great Lakes Restoration Initiative

• By 2014, remediation, restoration and conservation actions in at least 

one targeted watershed in each Great Lake Basin will control erosion, 

reduce nutrient runoff from urban and agricultural sources, and 

improve habitat to protect nearshore aquatic resources.

• By 2014, a baseline will be established for total suspended solids 

loadings from targeted tributaries.

• By 2014, a measurable decrease will be achieved in soluble 

phosphorous loading from 2008 levels in targeted tributaries.

• By 2014, the causes of nutrient-related nearshore biological 

impairments will be better understood and, following local or 

watershed remedial actions, the number and severity of incidences of 

harmful algal blooms, avian botulism, and/or excessive Cladophora

growth will be significantly reduced from 2008 levels.

• By 2014, a comprehensive nearshore monitoring program will have 

been established and implemented, including a publicly accessible 

reporting system, based on a suite of environmental indicators.

• By 2014, 50 percent of high-priority Great Lakes beaches will have 

been assessed using a standardized sanitary survey tool to identify 

sources of contamination.5

• By 2014, 20 percent of high-priority Great Lakes beaches will have 

begun to implement measures to control, manage or remediate 

pollution sources identified through the use of sanitary surveys.

• By 2014, rapid testing or predictive modeling methods (to improve the 

accuracy of decisions on beach postings to better protect public 

health) will be employed at 33 percent of high-priority beaches.

• By 2014, the area of agricultural lands in conservation and/or utilizing 

conservation tillage practices will increase by 50 percent over 2008 

levels.

 

5

Beaches that the states identify as most frequently used and/or that have the highest 

risk. In 2008, there were 356 high-priority beaches out a total of 1,411 total beaches in the 

U.S. Great Lakes.
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 90 GAO-13-797 Great Lakes Restoration Initiative

• Five-year average annual loadings of soluble reactive phosphorous 

from tributaries draining targeted watersheds.6

• Percentage of beaches meeting bacteria standards 95 percent or 

more of beach days.

• Extent (sq. miles) of Great Lakes harmful algal blooms.7

• Annual number of days U.S. Great Lakes beaches are closed or 

posted due to nuisance algae.8

• Annual volume of sediment deposition in defined harbor areas in 

targeted watersheds (cubic yards).9

• Acres in Great Lakes watershed with U.S. Department of Agriculture 

conservation practices implemented to reduce erosion, nutrients 

and/or pesticide loading under Farm Bill programs.10

 

6

[Measured in] metric tons per year. Total phosphorus will also be measured. Targeted 

watersheds will receive focused efforts toward restoration activities, for example, 

agricultural best management practices.

7

Biological responses to nutrients loadings are also dependent on other factors such as 

water temperature, timing and intensity of precipitation, and hydrologic features. Year-toyear variability in these features may mask local improvements in nutrients management. 

Satellite imagery may provide data for days during which harmful algal blooms are 

reported by shoreline observers or boaters.

8

This metric will be added to national surveys for beach managers for 2010. Nuisance 

algae can include Cladophora, harmful algal blooms or other species, all of which are 

believed to be aggravated by elevated levels of phosphorous in the water.

9

U.S. Army Corps of Engineers dredges the federal shipping channel at Toledo Harbor 

each year. This area receives the highest rate of sedimentation in the Great Lakes, 

coming from the Maumee River watershed. Even small improvements in the rate of 

sedimentation here would reflect considerable efforts in the watershed to reduce erosion 

and farm runoff. Alternately, the Corps conducts bathymetric surveys of commercial 

harbors each year, from which the volume of new fluvial sediment can be calculated for 

targeted watersheds. Because the Corps does not dredge every location of every harbor 

each year, the estimated accumulation from a designated area over time will reflect the 

relative amount of sediments deposited from the tributary. This approach is currently in 

development.

10This measure reflects annual (not cumulative) implementation of conservation practices 

(from the Environmental Quality Incentives Program and Conservation Technical 

Assistance program) that will continue to contribute to long term improvements of the 

listed outcomes.

Measures of Progress
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 91 GAO-13-797 Great Lakes Restoration Initiative

• Goal 1: Protection and restoration of Great Lakes aquatic and 

terrestrial habitats, including physical, chemical, and biological 

processes and ecosystem functions, maintain or improve the 

conditions of native fish and wildlife.

• Goal 2: Critical management activities (such as stocking native fish 

and other aquatic species, restoring access of migratory fish species 

at fish passage barriers, and identifying and addressing diseases) 

protect and conserve important fish and wildlife populations.

• Goal 3: Sound decision making is facilitated by accessible, site 

specific and landscape-scale baseline status and trend information 

about fish and wildlife resources and their habitats.

• Goal 4: High-priority actions identified in strategic plans (such as state 

and federal species management, restoration and recovery plans, 

Lakewide Management Plans, Remedial Action Plans, and others) are 

implemented, lead to the achievement of plan goals, and reduce the 

loss of fish and wildlife and their habitats.

• Goal 5: Development activities are planned and implemented in ways 

that are sensitive to environmental considerations and compatible with 

fish and wildlife and their habitats.

• By 2014, 4,500 miles of Great Lakes rivers and tributaries will be 

reopened and 450 barriers to fish passage will be removed or 

bypassed.

• By 2014, 82 percent of recovery actions for federally listed priority 

species will be implemented.

• By 2014, 53 percent of populations of native aquatic non-threatened 

and endangered species are self-sustaining.

• By 2014, 97,500 acres of wetlands, wetland-associated uplands, and 

high-priority coastal, upland, urban, and island habitats will be 

Focus Area Four, 

Habitat and Wildlife 

Protection and 

Restoration 

Long-term Goals

Objectives
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 92 GAO-13-797 Great Lakes Restoration Initiative

protected, restored or enhanced.

• By 2014, 100 percent of U.S. coastal wetlands in the Great Lakes 

Basin will be assessed.

• By 2014, 30 habitat-related beneficial use impairments will be delisted 

across the areas of concern.

• Miles of rivers reopened for fish passage.

• Number of fish passage barriers removed or bypassed.

• Number of species delisted due to recovery.

• Percentage of recovery actions implemented for priority listed species.

• Percentage of populations of native aquatic non-threatened and 

endangered species self-sustaining in the wild.

• Number of acres of wetlands and wetland-associated uplands 

protected, restored and enhanced.

• Number of acres of coastal, upland, and island habitats protected, 

restored and enhanced.

• Percent of U.S. coastal Great Lakes wetlands assessed.

• Number of habitat-related beneficial use impairments removed from 

the 27 U.S. areas of concern so impaired.11

 

11Also captured under the second measure in focus area one.

Measures of Progress
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 93 GAO-13-797 Great Lakes Restoration Initiative

• Goal 1: A cooperative monitoring and observing system provides a 

comprehensive assessment of the Great Lakes ecosystem.

• Goal 2: The necessary technology and programmatic infrastructure 

supports monitoring and reporting, including Great Lakes Restoration 

Initiative project deliverables by all agencies and participating 

stakeholders. Data and information are provided in reports that are 

public friendly, timely and available on the Internet. Reports present 

integrated and scaled data from watersheds to lakes to Great Lakes 

basinwide.

• Goal 3: Increase outreach and education for the Great Lakes, and 

provide ongoing K-12 education for students to understand the 

benefits and ecosystem functions of the Great Lakes so they are able 

to make decisions to ensure that restoration investments are 

enhanced over time.

• Goal 4: Expand the range of opportunities for Great Lakes 

stakeholders and citizens to provide input to the governments and 

participate in Great Lakes issues and concerns.

• Goal 5: Work under the goals and objectives of the Great Lakes 

Water Quality Agreement is coordinated between the United States 

and Canada through Lakewide Management Plans and other 

binational processes.

• By 2011, opportunities for collaboration, planning, data accessibility 

and accountability will be increased through the expanded use of 

Internet-based technology.

Focus Area Five, 

Accountability, 

Education, 

Monitoring, 

Evaluation, 

Communication and 

Partnerships 

Long-term Goals

Objectives
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 94 GAO-13-797 Great Lakes Restoration Initiative

• By 2011, an Accountability System will be developed and 

implemented for the Initiative. The system will integrate and make 

transparent strategic planning, budgeting, and results monitoring.

• By 2011, a satellite remote sensing program will be implemented to 

assess Great Lakes productivity and biological (e.g., algal bloom) 

events.

• By 2011, outreach and education efforts are increased, including 

identifying and revising existing curricula to incorporate sustainable 

education needs for the Great Lakes that meet state and other 

relevant learning standards.

• By 2011, a refined suite of science-based indicators for development 

of a comprehensive assessment of Great Lakes ecosystem health will 

be identified, monitoring programs for those indicators will begin to be 

implemented, and restoration and protection actions tied to those 

assessments and programs assured.

• By 2011, social media access opportunities for basinwide public 

involvement in the Initiative will be in place.

• By 2012, education efforts under existing curricula that meet state and 

other relevant learning standards will be coordinated across states, 

and a system for tracking student and teacher outreach (quantitatively 

and qualitatively) for their use.

• By 2012, improved coordination with Canada will take place for 

programs under the Great Lakes Water Quality Agreement, 

particularly under the Lakewide Management Plans, which will result 

in the achievement of 5-10 priority Lakewide Management Plans 

goals and actions.

• By 2014, a statistically valid and comprehensive assessment, using a 

probability-based design, of Great Lakes water resources, will be 

established. The system will integrate shipboard monitoring, remote 

sensing, automated sampling, and other monitoring or observing 

efforts. By 2016, the system will be in place for all of the Great Lakes 

and it will be capable of providing a scientifically justifiable 

assessment of Great Lakes water resources.

• By 2014, timely data and information will be provided to decision 

makers at multiple scales within a framework of established baselines, 

targets, indicators of progress, and monitoring.
Appendix VI: Great Lakes Restoration Initiative 

Action Plan Long-term Goals, Objectives, and 

Measures of Progress for Each of the Five 

Focus Areas

Page 95 GAO-13-797 Great Lakes Restoration Initiative

• Improvement in the overall aquatic ecosystem health of the Great 

Lakes using the Great Lakes 40-point scale.12

• Number of priority Lakewide Management Plans projects that are 

completed.

• Number of educational institutions incorporating new or existing Great 

Lakes protection and stewardship criteria into their broader 

environment education curricula.13

 

12This is an existing measure [used in the agency’s performance plan and performance 

report, which are required by the Government Performance Results Act, as amended]. 

The Great Lakes Index uses select Great Lakes ecosystem indicators (i.e., coastal 

wetlands, phosphorus concentrations, area of concern sediment contamination, benthic 

health, fish tissue contamination, beach closures, drinking water quality, and air toxics 

deposition) and is based on a 1 to 5 rating system for each indicator, where 1 is poor and 

5 is good. Improvements in the index and measures would indicate that fewer toxics are 

entering the food chain; ecosystem and human health is better protected; fish are safer to 

eat; water is safer to drink; and beaches are safer for swimming.

13Educational institutions include: state departments of education, primary and secondary 

school districts, colleges, universities, zoos, aquaria, museums, and nature/resource 

centers. Curricula will meet relevant official standards.

Measures of Progress
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 96 GAO-13-797 Great Lakes Restoration Initiative

J. Alfredo Gómez, (202) 512-3841 or gomezj@gao.gov

In addition to the individual named above, Steven Elstein, Assistant 

Director; Krista Breen Anderson; Cheryl Arvidson; Mark Braza; Lisa L. 

Fisher; Stuart M. Kaufman; Armetha Liles; Marya Link; Michelle K. 

Treistman; and Wayne Turowski made significant contributions to this 

report.

Appendix VII: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(361404)
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