UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C. 20460

OFFICE OF THE ADMINISTRATOR

SCIENCE ADVISORY BOARD

January 24, 2012

EPA-SAB-12-002

The Honorable Lisa P. Jackson

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Subject: Review of Great Lakes Restoration Initiative Action Plan 

Dear Administrator Jackson:

The EPA, with its federal partners, developed the Great Lakes Restoration Initiative Action Plan FY 

2010 - 2014. The Action Plan is a multi-year plan that identifies goals, objectives, ecological targets, and 

specific actions for five major focus areas. Restoration efforts, measures of progress, and principal 

actions have been developed to address toxic substances, Areas of Concern, invasive species, nearshore 

health, nonpoint source pollution, habitat restoration and wildlife protection. The Action Plan identifies 

the need to monitor and evaluate the GLRI’s progress and ensure its accountability. It also addresses the 

need to educate the public, to enhance collaboration among its partners, and to ensure public 

participation. In response to an EPA Region 5 request, the Science Advisory Board formed an ad hoc 

panel, the Great Lakes Restoration Initiative Action Plan Review Panel, to provide advice through the 

chartered SAB. 

The SAB acknowledges the EPA’s thoughtful effort and leadership that guided the development of the

Great Lakes Restoration Initiative Action Plan FY 2010- 2014. The SAB supports the premise that 

enough is known about the issues confronting the Great Lakes, as well as the underlying causes and 

potential remedies, to initiate action, and agrees that the Action Plan identifies most of the important 

actions that should be undertaken. The SAB notes that an integrated, science-based framework that 

provides input and justification for actions is lacking within the GLRI, but finds that the Action Plan is

largely consistent with previous plans and strategies, reflecting a continuation of collaborative planning 

in the region. This continuity is good, but it does not guarantee sufficiency and the SAB has a number of 

comments and recommendations to improve future efforts. 

The SAB supports the primary emphasis on implementing the extensive backlog of restoration projects 

in the Great Lakes region. The SAB also notes that this 5-year Action Plan is well underway and the 

plan itself recognizes that as these projects are completed, an evaluation and reprioritization of efforts 

will be needed using an adaptive management framework. This evaluation will require that a solid,

science-based framework be in place to drive the restoration plan. The SAB recommends that the agency 
2

create this integrated framework to bolster the Action Plan, to organize the current efforts, and to 

identify future directions to develop and implement new restoration technologies, methods and 

approaches. 

Another important organizational tool that is missing is a standing science panel. The SAB recommends

the agency create a well-integrated panel that could influence the program’s evolution by providing 

assessments of progress in key areas. The science panel’s input on design, implementation, monitoring,

and evaluation efforts would provide a scientific basis for setting priorities across disparate actions. In 

addition to natural and physical scientific expertise, the panel should include the social science 

disciplines. Behavioral, social, and decision scientists can provide many kinds of insights and advice

needed for a program as wide ranging as the GLRI. A diverse panel will offer assistance in targeting 

education and outreach efforts, and critical insights into the likely workability of particular institutional 

arrangements

The SAB notes that climate change is not explicitly addressed in the each of the focus areas of the 

Action Plan. Restoration efforts of this magnitude and complexity will likely change in the future as 

alterations in air and lake temperature, amount and patterns of precipitation, ice cover and lake levels 

may significantly impact restoration efforts.

The SAB agrees with the agency’s goal to develop an accountability system and recognizes that the 

current Great Lakes Accountability System is a work in progress. The SAB also notes that a great deal 

of effort will be necessary in order to upgrade the current system from an accounting system to one that 

provides transparency, tracks project outcomes as well as outputs, and provides a solid basis for 

programmatic evaluation needed for an adaptive management framework. In developing such an 

accountability system, the SAB urges the agency to develop metrics of progress that are more in line 

with the underlying science of restoring the Great Lakes rather than only the Government Performance 

Results Act measures that currently comprise the Action Plan. Robust monitoring programs are essential 

and a key element of adaptive management. Therefore, they should be continued and/or developed to 

measure the status and progress of restoration. Monitoring will also be needed to assess impacts on the 

Great Lakes and to assess how global, regional, and subwatershed factors interact. The SAB 

recommends that sufficient funding be allocated to monitoring and the subsequent programmatic 

evaluation to determine the eventual success (or lack thereof) of the Action Plan’s projects.

The Action Plan continues to build on the considerable history and experience studying and controlling 

toxic chemicals in the Great Lakes. This is a sound approach. However, the agency should carefully 

consider whether the current focus on priority “legacy” contaminants addresses the totality of the 

restoration required, or whether the focus should be tailored to account for other contaminants of 

concern. Additionally, as the agency addresses emerging contaminants, it should rely on the strong 

science and protocols developed by scientists in the Great Lakes region to identify which contaminants 

occur at levels of concern and should therefore be priority contaminants for action. The SAB also notes 

that the goal of delisting five areas of concern by 2014 is laudable, but is an extremely aggressive goal 

given historical rates of de-listing, program logistics and system response times. 

There are a number of admirable long-term goals and objectives to eliminate the introduction of invasive 

species in the Action Plan. Several parallel activities are under way to address specific invasive species

(i.e., Asian carp) and vectors (i.e., ballast water controls) in addition to the recommendations on 

surveillance programs the agency requested. The SAB finds these issues important and timely, and

recommends that these parallel efforts be evaluated together to develop a comprehensive invasive 

species program. The SAB endorses developing a basin-wide invasive species surveillance program and 
3

recommends that surveillance and rapid response protocols be coordinated to ensure that the various 

states, provinces, and other participating organizations use the same methodology and protocols to 

provide meaningful information and effective rapid response. 

The Action Plan’s intent to identify, map, and target the highest priority Great Lakes subwatersheds to 

protect nearshore health is the best strategy for producing measurable positive outcomes and provides a 

unique opportunity to form the basis for a long-term restoration vision. In order to sustain that vision, 

strategic planning that includes mechanisms for assuring sound science and measurement of progress

must be performed. Reducing soluble reactive phosphorus loads is one of the more important measures 

of progress as it is a key stressor throughout the Great Lakes ecosystem. However, this and other metrics

must be developed with targets that are statistically significant and scientifically meaningful.

Protecting and restoring habitat and wildlife will require the development and application of a range of 

critical management actions and sound decision-making. The SAB agrees that restoring resiliency is an 

appropriate goal for this focus area. However, the Action Plan does not clearly articulate the concept of 

resiliency in the context of this plan. In addition, adequate information was not presented to judge 

whether the actions associated with habitat and wildlife protection and restoration would be effective at 

attaining enhanced ecosystem resilience in the face of disturbances. A clear, working definition of 

resiliency should be developed along with metrics that can be used to track changes in the resiliency 

over time as restoration measures are implemented. While most of the actions presented in the Action 

Plan are “restoration” actions, the SAB questions whether the noted actions will enable the attainment of 

the objectives under this important focus area.

The SAB agrees that accountability, education, monitoring, evaluation, communication, and 

partnerships are important to the success of the GLRI, but concludes that the monitoring and other 

elements in this focus area may be better addressed in the specific focus areas rather than as a combined 

focus area. Instead, under this capstone focus area; EPA should develop a strategic assessment and 

management plan that implements monitoring, synthesis, and integration across the focus areas to 

bolster the accountability goals of the GLRI. Without a science-based accountability framework, the 

GLRI will do little to advance coordination and collaboration among Great Lakes partners to address 

key scientific issues. There is also a need to enforce the incorporation of educational and outreach 

activities as an overarching theme for all projects in the GLRI. Outreach and education activities provide 

highly respectable goals, but overall the Action Plan lacks a strategic approach to achieve the stated 

objectives.

Finally, the SAB recommends that the EPA and its partners consider explicit peer review criteria, in

parallel with the peer-review process of the National Science Foundation, for all activities (internally 

and externally funded), including those focused on education and outreach. The criteria should advance 

the knowledge and understanding of Great Lakes issues, promote teaching, increase participation of 

underrepresented groups, and broadly disseminate information to enhance the scientific and 

technological understanding of the public.
4

In closing, the SAB encourages EPA to continue efforts under the GLRI and collaborate with its 

interagency partners to develop the best available science to support remediation and restoration efforts 

and develop a sustainable program. We appreciate the opportunity to provide advice on this important 

effort and look forward to your response. 

Sincerely,

/Signed/ /Signed/

Dr. Judith Meyer Dr. James Sanders

Acting Chair Chair

Science Advisory Board SAB Panel on the Great Lakes Restoration 

Initiative Action Plan Review

Enclosure
i

NOTICE

This report has been written as part of the activities of the EPA Science Advisory Board (SAB), a public 

advisory group providing extramural scientific information and advice to the Administrator and other 

officials of the Environmental Protection Agency. The SAB is structured to provide balanced, expert 

assessment of scientific matters related to problems facing the agency. This report has not been reviewed 

for approval by the agency and, hence, the contents of this report do not necessarily represent the views 

and policies of the Environmental Protection Agency, nor of other agencies in the Executive Branch of 

the Federal government, nor does mention of trade names of commercial products constitute a 

recommendation for use. Reports of the SAB are posted on the EPA website at http://www.epa.gov/sab.
ii

U.S. Environmental Protection Agency

Science Advisory Board

Great Lakes Restoration Initiative Action Plan Panel

CHAIR

Dr. James Sanders, Director and Professor, Skidaway Institute of Oceanography, Savannah, GA

PANEL MEMBERS

Dr. Joel Eric Baker, Port of Tacoma Chair in Environmental Science and Professor, The Center for 

Urban Waters, University of Washington - Tacoma, Tacoma, WA

Dr. Robert E. Bilby, Chief Environmental Scientist, Technology Center 1A5, Weyerhaeuser Co., 

Federal Way, WA

Dr. Tracy Collier, Science Advisor, University Corporation for Atmospheric Research, Bainbridge, 

WA

Dr. Robert Diaz, Professor, Department of Biological Sciences, Virginia Institute of Marine Science, 

College of William and Mary, Gloucester Point, VA

Dr. Kirk Havens, Director, Coastal Watersheds Program, Virginia Institute of Marine Science, College 

of William and Mary, Gloucester Point, VA

Dr. Joseph Koonce, Chair, Biology, Case Western Reserve University, Cleveland, OH 

Dr. Thomas Leschine, Director and Professor, School of Marine and Environmental Affairs, College of 

the Environment, University of Washington, Seattle, WA

Dr. James Oris, Professor, Department of Zoology, Miami University, Oxford, OH

Dr. David Sample, Assistant Professor, Biological Systems Engineering, Occoquan Watershed 

Monitoring Laboratory, Virginia Polytechnic Institute and State University, Manassas, VA

Dr. Donald Scavia, Graham Family Professor and Director, Graham Institute, School of Natural 

Resources & Environment, and College of Engineering, University of Michigan, Ann Arbor, MI

Dr Paul Sibley, Professor, School of Environmental Sciences, Ontario Agricultural College, University 

of Guelph, Guelph, Ontario, Canada

Dr. William Taylor, Professor, Biology, University of Waterloo, Waterloo, Canada

Dr. Ron Thom, Technical Leader, Coastal Ecosystem Research Group, Marine Sciences Laboratory, 

Pacific Northwest National Laboratory, Sequim, WA

Dr. Judith Weis, Professor, Department of Biological Sciences, Rutgers University, Newark, NJ
iii

SCIENCE ADVISORY BOARD STAFF

Mr. Thomas Carpenter, Designated Federal Officer, U.S. Environmental Protection Agency, Science 

Advisory Board NW, Washington, DC, 
iv

U.S. Environmental Protection Agency

Science Advisory Board

ACTING CHAIR

Dr. Judith L. Meyer, Professor Emeritus, Odum School of Ecology, University of Georgia, Lopez 

Island, WA

MEMBERS

Dr. George Alexeeff, Acting Director, Office of Environmental Health Hazard Assessment, California 

Environmental Protection Agency, Oakland, CA

Dr. David T. Allen, Professor, Department of Chemical Engineering, University of Texas, Austin, TX

Dr. Pedro Alvarez, Department Chair and George R. Brown Professor of Engineering, Department of 

Civil & Environmental Engineering, Rice University, Houston, TX

Dr. Joseph Arvai, Svare Chair in Applied Decision Research, Institute for Sustainable Energy, 

Environment, & Economy, Haskayne School of Business, University of Calgary, Calgary, Alberta, 

Canada

Dr. Claudia Benitez-Nelson, Full Professor and Director of the Marine Science Program, Department 

of Earth and Ocean Sciences, University of South Carolina, Columbia, SC

Dr. Timothy J. Buckley, Professor and Chair, Division of Environmental Health Sciences, College of 

Public Health, The Ohio State University, Columbus, OH

Dr. Patricia Buffler, Professor of Epidemiology and Dean Emerita, Department of Epidemiology, 

School of Public Health, University of California, Berkeley, CA

Dr. Ingrid Burke, Director, Haub School and Ruckelshaus Institute of Environment and Natural 

Resources, University of Wyoming, Laramie, WY

Dr. Thomas Burke, Professor, Department of Health Policy and Management, Johns Hopkins 

Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD

Dr. Terry Daniel, Professor of Psychology and Natural Resources, Department of Psychology, School 

of Natural Resources, University of Arizona, Tucson, AZ

Dr. George Daston, Victor Mills Society Research Fellow, Product Safety and Regulatory Affairs, 

Procter & Gamble, Cincinnati, OH

Dr. Costel Denson, Managing Member, Costech Technologies, LLC, Newark, DE

Dr. Otto C. Doering III, Professor, Department of Agricultural Economics, Purdue University, W. 

Lafayette, IN

Dr. Michael Dourson, President, Toxicology Excellence for Risk Assessment, Cincinnati, OH
v

Dr. David A. Dzombak, Walter J. Blenko, Sr. Professor of Environmental Engineering , Department of 

Civil and Environmental Engineering, College of Engineering, Carnegie Mellon University, Pittsburgh, 

PA

Dr. T. Taylor Eighmy, Vice President for Research, Office of the Vice President for Research, Texas 

Tech University, Lubbock, TX

Dr. Elaine Faustman, Professor and Director, Institute for Risk Analysis and Risk Communication, 

School of Public Health, University of Washington, Seattle, WA

Dr. Jeffrey K. Griffiths, Professor, Department of Public Health and Community Medicine, School of 

Medicine, Tufts University, Boston, MA

Dr. James K. Hammitt, Professor, Center for Risk Analysis, Harvard University, Boston, MA

Dr. Barbara L. Harper, Risk Assessor and Environmental-Public Health Toxicologist, and Division 

Leader, Hanford Projects, and Program Manager, Environmental Health, Department of Science and 

Engineering, Confederated Tribes of the Umatilla Indian Reservation (CTUIR), West Richland, WA

Dr. Kimberly L. Jones, Professor and Chair, Department of Civil Engineering, Howard University, 

Washington, DC

Dr. Bernd Kahn, Professor Emeritus and Associate Director, Environmental Radiation Center, Georgia 

Institute of Technology, Atlanta, GA

Dr. Agnes Kane, Professor and Chair, Department of Pathology and Laboratory Medicine, Brown 

University, Providence, RI

Dr. Madhu Khanna, Professor, Department of Agricultural and Consumer Economics, University of 

Illinois at Urbana-Champaign, Urbana, IL

Dr. Nancy K. Kim, Senior Executive, Health Research, Inc., Troy, NY

Dr. Cecil Lue-Hing, President, Cecil Lue-Hing & Assoc. Inc., Burr Ridge, IL

Dr. Floyd Malveaux, Executive Director, Merck Childhood Asthma Network, Inc., Washington, DC

Dr. James R. Mihelcic, Professor, Civil and Environmental Engineering, University of South Florida, 

Tampa, FL

Dr. Christine Moe, Eugene J. Gangarosa Professor, Hubert Department of Global Health, Rollins 

School of Public Health, Emory University, Atlanta, GA

Dr. Horace Moo-Young, Dean and Professor, College of Engineering, Computer Science, and 

Technology, California State University, Los Angeles, CA

Dr. Eileen Murphy, Director of Research and Grants , Ernest Mario School of Pharmacy, Rutgers 

University, Piscataway, NJ
vi

Dr. James Opaluch, Professor and Chair, Department of Environmental and Natural Resource 

Economics, College of the Environment and Life Sciences, University of Rhode Island, Kingston, RI

Dr. Duncan Patten, Research Professor, Hydroecology Research Program , Department of Land 

Resources and Environmental Sciences, Montana State University, Bozeman, MT

Dr. Stephen Polasky, Fesler-Lampert Professor of Ecological/Environmental Economics, Department 

of Applied Economics, University of Minnesota, St. Paul, MN

Dr. C. Arden Pope, III, Professor, Department of Economics, Brigham Young University, Provo, UT. 

Dr. Stephen M. Roberts, Professor, Department of Physiological Sciences, Director, Center for 

Environmental and Human Toxicology, University of Florida, Gainesville, FL

Dr. Amanda Rodewald, Professor of Wildlife Ecology, School of Environment and Natural Resources, 

The Ohio State University, Columbus, OH

Dr. Jonathan M. Samet, Professor and Flora L. Thornton Chair, Department of Preventive Medicine, 

Keck School of Medicine, University of Southern California, Los Angeles, CA

Dr. James Sanders, Director and Professor, Skidaway Institute of Oceanography, Savannah, GA

Dr. Jerald Schnoor, Allen S. Henry Chair Professor, Department of Civil and Environmental 

Engineering, Co-Director, Center for Global and Regional Environmental Research, University of Iowa, 

Iowa City, IA

Dr. Gina Solomon, Senior Scientist, Health and Environment Program, Natural Resources Defense 

Council, San Francisco, CA

Dr. Daniel O. Stram, Professor, Department of Preventive Medicine, Division of Biostatistics, 

University of Southern California, Los Angeles, CA

Dr. Peter Thorne, Professor and Head, Occupational and Environmental Health, College of Public 

Health, University of Iowa, Iowa City, IA

Dr. Paige Tolbert, Professor and Chair, Department of Environmental Health, Rollins School of Public 

Health, Emory University, Atlanta, GA

Dr. John Vena, Professor and Department Head, Department of Epidemiology and Biostatistics, 

College of Public Health, University of Georgia, Athens, GA

Dr. Robert Watts, Professor of Mechanical Engineering Emeritus, Tulane University, Annapolis, MD

Dr. R. Thomas Zoeller, Professor, Department of Biology, University of Massachusetts, Amherst, MA
vii

SCIENCE ADVISORY BOARD STAFF

Dr. Angela Nugent, Designated Federal Officer, U.S. Environmental Protection Agency, Science 

Advisory Board, Washington, DC, 
viii

Table of Contents

Acronyms and Abbreviations................................................................................................................. ix

1. EXECUTIVE SUMMARY.................................................................................................................. 1

2. INTRODUCTION................................................................................................................................ 9

3. RESPONSE TO CHARGE QUESTIONS....................................................................................... 11

3.1. OVERALL STRUCTURE OF THE GLRI ACTION PLAN................................................................... 11

3.2. TOXIC SUBSTANCES AND AREAS OF CONCERN .......................................................................... 17

3.3. INVASIVE SPECIES...................................................................................................................... 20

3.4. NEARSHORE HEALTH AND NONPOINT SOURCES ........................................................................ 25

3.5. HABITAT AND WILDLIFE PROTECTION AND RESTORATION........................................................ 29

3.6. ACCOUNTABILITY, EDUCATION, MONITORING, EVALUATION, COMMUNICATION, AND 

PARTNERSHIPS....................................................................................................................... 33

REFERENCES........................................................................................................................................ 38

APPENDIX A: CHARGE TO THE SAB........................................................................................... A-1

APPENDIX B: CONSIDERATIONS FOR AN ECOSYSTEM RESTORATION PROGRAM .. B-1
ix

Acronyms and Abbreviations

AOC Areas of Concern

BMP Best Management Practices 

BWMS Ballast Water Management Systems 

DNA Deoxyribonucleic acid 

EPA Environmental Protection Agency 

GPRA Government Performance and Results Act

GLAS Great Lakes Accountability System 

GLRI Great Lakes Restoration Initiative 

IATF Great Lakes Interagency Task Force 

IJC International Joint Commission

LaMP Lake Management Plan 

NGO Non-Governmental Organizations

NIS Non-indigenous invasive species

NSF National Science Foundation

OMB Office of Management and Budget 

PAH Polycyclic aromatic hydrocarbons 

PBT Persistent, bioaccumulative and toxic 

PCB Polychlorinated biphenyls 

SAB Science Advisory Board 

SAV Submerged aquatic vegetation 

SOLEC State of the Great Lakes Ecosystem Conference
1

1. EXECUTIVE SUMMARY

In 2009, President Obama announced and Congress later appropriated $475 million in new funding for 

the Great Lakes Restoration Initiative (GLRI) to “protect and restore the chemical, biological, and 

physical integrity of the Great Lakes.” To guide the efforts of the GLRI, the Environmental Protection 

Agency (EPA) and its Federal partners, through the Great Lakes Interagency Task Force (IATF)1

Overall Structure of the Action Plan

developed a comprehensive multi-year Action Plan that identifies goals, objectives, ecological targets, 

and specific actions for five major focus areas. 

The Great Lakes Restoration Initiative Action Plan FY 2010 - 2014, hereafter referred to as the Action 

Plan, describes the measures of progress and principal actions to address toxic substances, Areas of 

Concern, invasive species, nearshore health, nonpoint source pollution, habitat restoration, and wildlife 

protection and restoration. The Action Plan also provides a fifth focus area to address the GLRI’s effort 

to improve accountability, education, monitoring, evaluation, communication, and partnerships. 

In response to the Department of the Interior, Environment, and Related Agencies Appropriations Act of 

2010, EPA as the lead agency for the GLRI requested that the Science Advisory Board (SAB) review

the Action Plan. The SAB formed an ad hoc panel, the Great Lakes Restoration Initiative Action Plan 

Review Panel, to conduct the review and provide advice through the chartered SAB. The SAB 

responded to eleven charge questions in its deliberations. Charge questions were organized to address 

the overall structure of the Action Plan and the five Focus Areas. The SAB recognizes that the five-year 

Action Plan is well underway and is providing advice to guide future decisions for the GLRI. In this 

Summary, an excerpt of the charge questions provides context to the SAB recommendations and advice 

on each of the topics addressed in the Action Plan. 

Are the principal actions proposed in the Action Plan consistent with the actions and/or 

recommendations of the previous collaborative plans and strategies for the Great Lakes 

(e.g. Great Lakes Regional Collaboration Strategy)? Are there other actions that we 

should consider for inclusion in the Action Plan that will better achieve the goals of the 

Action Plan?

The SAB supports the basic premise that enough is known about the issues confronting the Great Lakes, 

as well as the underlying causes and potential remedies, to implement initial remedial activities, and 

agrees that the Action Plan identifies the important actions that should be undertaken. Although a

transparent framework describing the scientific justification for the Action Plan is lacking, the SAB 

notes that the Action Plan is consistent, for the most part, with previous plans and strategies and reflects

a continuation of collaborative planning in the region. This continuity in planning is good, but such 

consistency does not guarantee sufficiency. The SAB provides recommendations for improvement in a 

number of areas. 

The SAB recognizes there is an extensive backlog of restoration projects in the Great Lakes region that 

need to be pursued, and supports the agenda of putting primary emphasis on implementing those 

 1 The Great Lakes Interagency Task Force (IATF) brings together eleven U.S. cabinet and Federal agency heads to coordinate restoration of the Great Lakes. 

Created by Executive Order from President Bush on May 18, 2004, the IATF is to focus on environmental outcomes like cleaner water and sustainable 

fisheries, and target measurable results. The IATF helps coordinate GLRI implementation.

http://www.epa.gov/greatlakes/iatf/index.html
2

projects. The Action Plan recognizes that as these projects are completed, evaluation and reprioritization 

of efforts will need to be accomplished, using an adaptive management framework. Implementation of 

an adaptive management framework will require systematic and continual integration of design, 

management, and monitoring, which would enable EPA and the IATF to make informed adjustments 

and adaptations in the restoration efforts in the Great Lakes. The SAB notes that a solid, science-based 

framework that provides input and justification for actions will be necessary to support restoration 

decisions, track the restoration plan’s progress, and document the GLRI’s success.

The Great Lakes Accountability System (GLAS)2

When developing and implementing a program as large, expansive, and hopefully as sustained as the 

GLRI will be, scientific investment to increase the understanding of critical ecological functions and 

[is] the primary mechanism for 

collecting information to monitor and report on GLRI progress. GLAS is still a work-inprogress at this time and it is not ready for external review. However, given the scope of 

the Action Plan and the nature and types of projects funded under the GLRI, [EPA is]

interested in the SAB’s recommendations on how best to track the progress and 

accountability for a large ecosystem restoration program. What critical environmental 

elements, endpoints, or other measures would you include to those identified in the 

Action Plan?

The SAB agrees with the agency’s goal to develop an accountability system and recognizes the current 

Great Lakes Accountability System (GLAS) is a work in progress. However, much work will need to be 

done to upgrade the current system from an accounting system to one that provides transparency, is able 

to track project outcomes as well as outputs, and provides a solid basis for programmatic evaluation

across the focus areas. In addition, the SAB notes that the ability to integrate outcomes across hundreds 

of projects, essential for evaluation at the theme (e.g., toxics), Lake, or system level and at the overall 

GLRI program level, is lacking. GLAS may not be an appropriate vehicle for this type of integration, as 

it appears designed to function at the project level, and the diversity and granularity of those projects 

would make integration within GLAS difficult. An effective integrative assessment will require 

additional effort, perhaps building from GLAS inputs. Therefore, the SAB recommends a new, focused, 

and perhaps independent, scientific evaluation process.

Please comment on the overall scope and framework of the Action Plan and its ability to 

organize environmental issues in a way that directs restoration actions. Does the SAB 

have any specific recommendations on how to improve or clarify the Action Plan?

While the Action Plan is consistent with previous efforts in the Great Lakes region, there appears to be a 

serious disconnect in that very few of the research, monitoring, and integrative assessment needs 

identified in the earlier documents (e.g., the State of the Great Lakes Ecosystem Conferences,

www.epa.gov/solec/) are carried through to the Action Plan. SAB findings on the adequacy of the 

identified endpoints and measures are addressed in each section below, but overall the measures often 

appear naïve or narrow, and without proper context or benchmarking. Measures should be cognizant of 

historical context and variability. Metrics to identify change or progress toward restoration should be 

developed such that they can be detected statistically. Otherwise, it is not clear if, or when, a metric is 

met. This requires an understanding and explicit documentation of both historical baselines and their 

variability, and the universe within which the metric is couched.

 2 Available online at http://glri.us/projects.html
3

pathways is needed to ensure effective restoration, improve restoration methods, and to monitor, track, 

and evaluate progress. The SAB is concerned that the Action Plan is not placing enough emphasis on 

programmatic evaluation and synthesis across focus areas of the GLRI to successfully employ adaptive 

management. Indeed, evaluations of programs and projects, and their success, should be considered as

important as the other actions. Robust monitoring programs are essential and a key element of adaptive 

management. Therefore, they should be continued and/or developed to measure the status and progress 

of restoration. Monitoring will also be needed to assess impacts on the Great Lakes and to assess how 

global, regional, and subwatershed factors interact. The SAB recommends that sufficient funding be 

allocated to assessing the eventual success (or lack thereof) of the Action Plan.

To achieve success, the SAB notes that an integrated science-based framework that provides input and 

justification for actions taken is necessary to transparently link goals to outputs and outcomes and that 

such a plan is lacking. Creating this framework, herein referred to as a science plan, will not only 

support the current efforts, but also lay out future directions that can support and take advantage of 

development of new restoration technologies, methods, and approaches. The SAB recommends that 

EPA work with natural and social scientists and engineers from government, academia, non-government 

organizations (NGOs) and industry to create this science plan that, when coupled with the Action Plan, 

creates a framework for adaptive management. This science plan also should explicitly consider 

potential impacts of climate change on restoration.

The Action Plan suggests that restoration and protection can be accomplished through natural science 

and engineering processes alone. This is rarely the case in environmental decision-making. Significant 

roadblocks to action can come from social, economic, political, and other human dimensions. 

Investments in behavioral, social and decision science analysis of the science-policy interfaces in the 

region can provide important information to avoid implementation pitfalls and overcome impediments to 

action. Therefore, the SAB recommends that behavioral, social and decision sciences are included in the 

science plan.

One important organizational tool that seems to be missing is a standing science panel, and the SAB 

recommends that one be established. A well-integrated panel could influence the program’s evolution 

providing assessments of progress in key areas. The science panel’s input on design, implementation,

monitoring, and evaluation efforts would provide a scientific basis for setting priorities across disparate 

actions and implementing an adaptive management framework. Members should be independent experts 

drawn from universities and other research institutions, the private sector, and government agencies, but 

selected for their expertise and not to represent their agencies. Such a panel could make substantial 

contributions to the development of both robust monitoring efforts and the adaptive management plan 

that would rely heavily on well-designed monitoring. In addition to natural and physical scientific 

expertise, the panel should include the social science disciplines. Behavioral, social, and decision

scientists can provide many kinds of insights and advice needed for a program as wide ranging as the 

GLRI. A diverse panel will offer assistance in targeting education and outreach efforts, and critical 

insights into the likely workability of particular institutional arrangements

The SAB also recommends the agency explore existing efforts, such as the Puget Sound Institute, the

Scientific and Technology Advisory Committee of the Chesapeake Bay Program and the Delta Science 

Program in the Sacramento-San Joaquin Delta. These efforts serve as potential models for innovative 

ways to engage scientists in developing and implementing the science plan; supporting and managing

scientific assessments and syntheses of critical restoration issues; funding critical gap-filling research;

and integrating scientific efforts across projects, focus areas, and themes. The SAB recommends this 
4

approach so that the EPA and IATF may identify and incorporate elements from other plans to tailor a 

panel and plan that address the needs of the GLRI. 

Toxic Substances and Areas of Concern

Please comment on the Action Plan’s approach for addressing so-called “legacy” 

contaminants through sediment remediation and toxics reduction efforts. Please comment 

on whether the Action Plan addresses the reduction of “legacy” contaminants at all 

geographic scales sufficiently to restore the Great Lakes ecosystem. Are there other 

actions that we should consider?

The Action Plan builds on the considerable history and experience studying and controlling toxic 

chemicals in the Great Lakes, and the Action Plan is clearly directed towards continuing this effort. This

is a sound approach.

A major strategy for addressing so-called “legacy” contaminants is the accelerated clean-up of areas of 

concern (AOCs). Contaminated sediments are often a continuing chronic source of persistent chemicals 

to Great Lakes biota; therefore, a strategy based on cleaning up contaminant “hot spots” has a high 

probability of reducing pollutant levels and effects to biota on a regional basis and may have similar 

success on a basin wide basis. However, as noted in the GLRI, there are a number of other possible 

impacts from a wide range of chemical contaminants, and the SAB cautions the agency to favor an 

approach that balances the need to remediate known problems (e.g., polychlorinated biphenyls (PCBs)

in sediments) while systematically addressing previously under studied “legacy” contaminants. The 

SAB notes that the goal of delisting five AOCs by 2014 is laudable but extremely aggressive given 

historical rates of de-listing, program logistics and system response times. 

Performance management of the AOC restoration program is critical, and needs to go beyond program 

tracking to include scientifically defensible metrics of success that indicate progress of restoration. 

These evaluation mechanisms are lacking from the Action Plan. The SAB notes that such efforts will 

require resources that might otherwise go to additional site cleanup actions, and that these resources may 

be required for many years after the cleanup operations are completed. However, assessing success, 

partial success, or failure of these AOC clean-up programs is essential to the overall Great Lakes 

restoration and making future remediation decisions.

Please comment on [the Action Plan] approach for assessing and managing the risks 

posed by chemicals of emerging concern. Are there other actions or specific chemicals of 

emerging concern that we should consider?

The Action Plan briefly covers emerging contaminants in a single principal action by coordinating 

national chemical programs with progress of AOC cleanups and assessing new toxic threats. The choice 

of which emerging contaminants to focus upon must be led by their potential to affect aquatic species 

and human health at the levels found or anticipated in the Great Lakes. The SAB notes that the Great 

Lakes science community has made significant progress to prioritize emerging contaminants, but that 

further research will be necessary, as few ecotoxicological data exist for these contaminants. Further, 

recommendations made by the International Joint Commission Work Group on Chemicals of Emerging 

Concern should be incorporated into the Action Plan. 
5

Invasive Species

What are the key scientific data needed in an early detection surveillance network to 

provide up-to-date critical information for evaluating rapid response options? Does the 

SAB have any recommendations on demonstrated preventative and control technologies 

that could be applied to invasive species in the Great Lakes? Are there other actions that 

we should consider?

This section of the Action Plan sets out a number of laudable long-term goals and objectives. On the 

other hand, relatively few specific details are provided to explain what exactly will be done regarding 

surveillance, and especially about the technologies to contain and/or control invasive species. While the 

charge to reviewers notes that there are parallel actions under way to address specific invasive species

(i.e., Asian carp) and vectors (i.e., ballast water controls) and that the Action Plan focuses on other 

methods to control invasive species, the SAB finds these parallel issues important and timely. Therefore,

the SAB cites some examples developed under these efforts that may be important to consider in 

developing an early detection surveillance program.

One of the Action Plan’s objectives is to develop methodology and protocols for a basin-wide invasive 

species surveillance program. The SAB agrees with this action and recommends that surveillance and 

rapid response protocols be coordinated to ensure that the various states, provinces, and other 

participating organizations use the same methodology and protocols to provide meaningful information 

exchange and effective rapid response. However, the Action Plan did not provide information about 

prevention and control technologies for invasive species that are under consideration by the agency. In 

addition, the charge requested the SAB provide technologies that could be applied to invasive species in 

the Great Lakes. This is a difficult task given the paucity of information provided. The SAB discussed 

technologies to control invasive species and provides some general guidance and bibliographic citations. 

The SAB encourages the agency’s consideration. The SAB recommends the EPA develop criteria to 

evaluate these and additional studies to develop preventative and control technologies. The SAB also 

recommends that the agency assess known and probable invasive species and prioritize which species 

present the greatest threats to the Great Lakes. 

Nearshore Health and Nonpoint Sources

Please comment on the adequacy of the principal actions to address the impacts 

associated with nearshore soluble reactive phosphorus, Cladophora biomass, and 

dreissenid biomass. Are there other actions that we should consider? Please comment on 

the Action Plan’s intent to target Great Lakes subwatersheds that show severe signs of 

stress for focused restoration activities as opposed to a broader approach that targets all 

watersheds (stressed and currently unstressed). 

While the Action Plan is a five-year plan, it provides a unique opportunity to form the basis for a longterm restoration vision that could guide subsequent renewals of the Action Plan. In order to sustain that 

long-term vision, strategic planning that includes mechanisms for assuring sound science and 

measurement of progress must be performed in order to meet the goal to restore nearshore health and 

reduce impacts from nonpoint source pollution. How future development and climate change will affect 

the Action Plan targets needs to be considered in more detail. Global climate change needs to be added 

as a major driving force. The Action Plan does not address this in an integrated fashion, and further 

detail acknowledging this important new factor and how restoration may be affected is needed.
6

The Action Plan’s intent to identify, map, and target the Great Lakes subwatersheds that show severe 

signs of stress for focused restoration activities is the best strategy for producing measurable positive 

outcomes. Overall, severely stressed systems usually respond positively and measurably to stressor 

relief. This is particularly true for stresses associated with excess nutrient loadings. While the focus on 

stressed watersheds and subwatersheds is good, the SAB notes that the selection process needs to be 

more understandable and transparent and recommends that, at a minimum, a complete list of stressed 

watersheds by Lake be included.

Reducing soluble reactive phosphorus loads is one of the more important measures of progress as it is a 

key stressor throughout the Great Lakes ecosystem. However, this and other metrics must be developed 

with targets that are statistically significant and scientifically meaningful. Within this focus area, it is not 

clear, how metrics and their target quantities were developed, or if the quantities reflect significant or 

scientifically meaningful or measurable improvement. A critical evaluation of what is a significant target 

to achieve in restoration is needed here, and in other focus areas. The SAB recommends EPA engage in 

strategic planning to develop mechanisms that assure sound science, performance measures and rigorous 

monitoring to provide an understanding of how changing climate, water level variation and nonpoint 

sources of stresses impact the Great Lakes.

As identified in the objectives for this focus area, monitoring programs apparently will be a strong part 

of this part of the Action Plan as restoration progress can best be measured by status and trend analysis. 

The adaptive management approach proposed by the Action Plan also requires adequate and timely

monitoring, to enable subsequent evaluation and justify course corrections for program priorities. 

Monitoring will also be needed to assess global change impacts on the Great Lakes and how global, 

regional, and subwatershed factors interact. The SAB recommends that sufficient funding be allocated to 

monitoring the eventual success (or lack thereof) of the Action Plan’s projects.

Habitat and Wildlife Protection and Restoration

Does the SAB have any recommendations on actions to increase “resiliency”? Are there 

additional ecological elements or measures that should be considered to better improve 

resiliency or buffering capacity and our progress in habitat restoration and ecosystem 

protection projects? What about actions in the other focus areas?

Achieving the five goals of this focus area will require the development and application of a range of 

critical management actions and sound decision-making. The SAB finds that restoring resiliency is an 

appropriate goal for this focus area. However, the Action Plan does not clearly articulate the concept of 

resiliency in the context of the GLRI. In addition, adequate information was not presented to judge 

whether the actions associated with Habitat and Wildlife Protection and Restoration would be effective 

at attaining enhanced ecosystem resilience in the face of disturbances. The SAB recommends that a

clear, working definition of resiliency be developed along with metrics that can be used to track changes 

in the resiliency over time as restoration measures are implemented.

The SAB was asked to identify additional ecological elements and measures to improve resiliency that 

the agency should consider as it evaluates the progress of the Action Plan and plans next steps. The SAB

notes that there are certain ecosystem characteristics that have been shown to contribute to ecosystem 

capacity to resist state changes in the face of disturbances. This capacity is frequently what is meant by 

resilience. Restoration actions that enhance these ecosystem characteristics, therefore, should contribute 
7

to resilience. The SAB urges the agency to consider the recommendations presented in this section of 

the Advisory Report and incorporate them as appropriate.

The Action Plan broadly defines “restoration” to encompass physical, biological, and 

chemical functions and processes. Are the actions listed in the Action Plan “restoration” 

actions?

Most of the actions listed under this focus area are “restoration” actions. The more relevant question for 

the GLRI is whether these actions will enable the attainment of the Action Plan’s objectives. The SAB

finds that the italicized parts of the principal actions may be more appropriate as goals for the protection 

and restoration of habitat and wildlife. Actions that are more specific would further describe the efforts 

to achieve these goals. This change would represent the first step towards addressing the ambiguity in 

the links between vision, long-term goals, objectives, and principal actions in the Action Plan. The SAB 

recommends the formal integration of an adaptive management program with clearly articulated goals 

and explicit statements of what the program seeks to accomplish.

Accountability, Education, Monitoring, Evaluation, Communication, and Partnerships

Does the SAB have any recommendations of critical data gaps for which programs or 

tools should be implemented in the other focus areas? Please comment on the Action 

Plan’s approach for enhancing coordination and collaboration among Great Lakes 

partners to address key scientific issues.

The topics addressed under this diverse and disparate focus area in the Action Plan are important to the 

success of the GLRI. The SAB concurs that overall assessment and a management framework are 

necessary for the GLRI, and provides recommendations on how best to achieve this in Section 3.1. In 

order to develop the information needed to evaluate the GLRI, EPA and the IATF must have sufficient 

information to conduct analyses of the success of individual projects and across the focus areas. The 

SAB concludes that the monitoring and other elements of this focus area may be better addressed in the 

specific focus areas noted above, rather than as a combined focus area. The SAB also recommends that, 

instead, a strategic assessment and adaptive management plan to implement monitoring, synthesis and 

integration across the focus areas be included in the Action Plan in this focus area to bolster the 

accountability goals of the GLRI. The SAB further provides recommendations to achieve greater 

accountability, considerations to increase collaboration among partners, and to enhance educational and 

outreach opportunities. 

Combining the accountability, monitoring and evaluation actions together into a single section may 

come at the cost of them being developed separately from the focus area or in a cursory manner. The 

Action Plan addresses a wide variety of management activities and seeks to coordinate them through an 

adaptive management process. Without an explicit representation of the management layer, however, the 

GLRI faces substantial challenges implementing performance evaluation based on principles of adaptive 

management. Monitoring and evaluation in this focus area should provide for the analyses of focus area 

integration and synthesis of actions to achieve overarching goals and the accountability of the GLRI as a 

whole. These analyses should also address uncertainties or data gaps. Additionally, measures of progress 

need to identify benchmarks for expected outputs and outcomes. The GLRI should consider using an 

overall framework to evaluate the integration, synthesis and coordination of all program elements across

all the focus areas. This type of analysis can be used to identify hotspots, areas of improvement, or 

highlight the success or failure of best management practices (BMP), both in terms of location or scale.
8

Without an accountability framework, the GLRI will do little to advance coordination and collaboration 

among Great Lakes partners to address key scientific issues.

The Action Plan lists the federal department level members of the Interagency Task Force and Regional 

Working Group that developed the Action Plan. It also alludes to approximately 200 organizations at the 

federal, state and sovereign tribal nation levels. While it is clear that a great many stakeholder 

organizations are involved in the program, it is not apparent which are the key parties, or what their 

interests and their roles are within the Action Plan. A functional approach to explicit partnerships needs 

to be described; what they are (e.g., science or outreach), and where they fit within the other focus areas

is needed.

The Action Plan identifies the need to educate future generations to extend restoration

efforts. Please comment on the Action Plan’s approach to incorporate Great Lakes 

stewardship into environmental education curricula.

The SAB agrees that there is a need to enforce the incorporation of educational and outreach activities as 

an overarching theme on all projects. Outreach and education activities provide highly laudable goals, 

but overall the Action Plan lacks a strategic approach to achieve the stated objectives. Measures of 

progress were ambiguous and will be difficult to track. Currently, there are no specific indications in the 

Action Plan of the amount or type of resources allocated to these aspects of the program. The SAB

recommends that EPA and its partners should consider explicit peer review criteria, in parallel with the 

peer-review process of the NSF, for all activities (internally and externally funded) that include 

education and outreach with significant weighting as it implements projects under the GLRI. The criteria 

should advance the knowledge and understanding of Great Lakes issues, promote teaching, increase 

participation of underrepresented groups, and broadly disseminate information to enhance scientific and 

technological understanding of the public.
9

2. INTRODUCTION

In 2009, President Obama proposed the Great Lakes Restoration Initiative (GLRI) to “protect and 

restore the chemical, biological, and physical integrity of the Great Lakes,” and Congress appropriated 

$475 million in new funding for the effort. To guide the GLRI, U.S. Environmental Protection Agency 

(EPA) and its Federal partners, through the Great Lakes Interagency Task Force (IATF), developed a 

comprehensive multi-year Action Plan that describes how the Initiative will be executed from 2010 

through 2014. The GLRI Action Plan identifies goals, objectives, ecological targets, and specific actions 

for five major focus areas: 

• Toxic Substances and Areas of Concern – focus on pollution prevention and cleanup of the 

Areas of Concern (AOCs) and Beneficial Use Impairments (BUIs) in the Great Lakes;

• Invasive Species – develop and implement measures to control invasive species to maintain the 

health of the Great Lakes ecosystem;

• Nearshore Health and Nonpoint Source Pollution – identify priority watersheds for reduction in 

polluted runoff from urban, suburban and agricultural sources;

• Habitat and Wildlife Protection and Restoration – provide an assessment of Great Lakes coastal 

wetlands and strategically target restoration and protection efforts for wetlands and other habitat 

restoration; and 

• Accountability, Education, Monitoring, Evaluation, Communication and Partnerships -

implement goal- and results-based accountability measures, learning initiatives, outreach and 

strategic collaborative partnerships.

The GLRI, through EPA, conducted two rounds of requests for grant proposals to select restoration 

projects and related activities. As of March 2011, over $418 million in projects to restore the Great 

Lakes was awarded. In addition to federal partners, 286 grantees represent state, local and tribal 

government, nonprofits, and universities. EPA is currently preparing for a third round of proposals based 

on the Action Plan.

In the 2010 Department of the Interior, Environment, and Related Agencies Appropriations Act, 

Congress specified, “conferees expect [EPA] to establish a process that engages an independent, 

scientific panel to review the scientific credibility of the Action Plan to optimize the likelihood of 

successful restoration at appropriate scales." In order to meet this requirement, the EPA Great Lakes 

National Program Office has requested that the Science Advisory Board (SAB) review the Great Lakes 

Restoration Initiative Action Plan FY 2010- 2014 (US EPA 2010), hereafter referred to as the “Action 

Plan.” 

The SAB formed an ad hoc panel, the Great Lake Restoration Initiative Action Plan Review Panel, to 

conduct the review. The Panel met on July 12-13, 2011, to hear EPA technical presentations and public 

comments, and to discuss responses to the Charge to the SAB (Appendix A). The Panel held a follow-up 

public teleconference on September 16, 2011, to discuss an initial draft report. The chartered SAB 

conducted a quality review of the Panel’s report on December 6, 2011. Public comments were received 

and considered throughout the advisory process.

The Charge to the SAB included questions on the overall framework of the Action Plan and specific 

questions on each of the five focus areas. The EPA requested recommendations and advice to further 

develop the Action Plan and increase the collaborations among members of the Great Lakes community
10

to meet GLRI goals as progress was made on focus area projects. The full charge is included as 

Appendix A and relevant charge questions are included within each section of this report. 

The SAB reviewed the charge questions, available information from the GLRI, and projects initiated at 

the time of the review. Projects initiated in the first two rounds of the GLRI were still underway and not 

yet near completion. The agency is developing additional mechanisms and tools to evaluate the progress 

of restoration described in the Action Plan. The SAB recognizes that the GLRI is well underway at this 

point (approximately two years into a five-year plan) and that it is a dynamic program that needs to 

account for a changing physical, social, geographic, and environmental landscape at vast scales. GLRI 

Projects are in different stages of completion simultaneously across the focus areas. Projects completed 

in one focus area may create an opportunity or need for a restoration project in another focus area. The 

size and complexity of the GLRI preclude a program-wide stop, evaluate and restart management 

approach. These considerations necessitate a programmatic ability within the GLRI to reprioritize efforts 

as needed when information becomes available from individual projects without impeding the progress 

of restoration in the Great Lakes.

Based on the status of projects, the project information available, and the charge questions the SAB is 

providing advice to guide future decisions and provide direction for the next steps in the GLRI. The 

SAB responses are geared toward assisting the EPA and IATF to evaluate the results of the restoration 

projects as they are completed and synthesize the data and information across the wide-ranging program. 

The recommendations identify tools, mechanisms, approaches and the types of information needed to 

make decisions on future restoration projects and apply adaptive judgment to change priorities to meet 

the GLRI goals. The SAB encourages the agency to move forward using the best available science to 

restore the Great Lakes and develop the tools and mechanisms needed to guide the program on a 

successful course based on the advances made under the GLRI.
11

3. RESPONSE TO CHARGE QUESTIONS

3.1.

Charge questions 1, 2, and 3 address overarching issues and request that the SAB comment on 

the overall scope of the Action Plan. The SAB provides comments and recommendations on (1) 

the consistency of Action Plan with previous plans and their science, (2) how to identify methods 

to enhance the accountability of the program, and (3) actions the agency could take to improve 

and clarify the GLRI and the Action Plan as it implements further actions. The specific questions 

and SAB responses are detailed below.

Overall Structure of the GLRI Action Plan

3.1.1. Consistency with Other Great Lakes Collaborative Plans and Science 

Question 1

In their current form, it is not possible for the SAB to determine if the Action Plan and Scientific 

Background document provided to the SAB (U.S. EPA 2011) are based on best available science 

or that they are fully consistent with other strategic plans. The Action Plan was written for a 

general audience, and does not contain the breadth or detail that would be required to make such 

a determination. Similarly, the Scientific Background document cites previous collaborative 

plans and strategies but does not provide direct linkage between projects in the Action Plan and 

those citations. SAB expertise and understanding of issues facing the Great Lakes, examination

of past strategic plans, and familiarity with regional workshop reports identified the scientific 

bases and foundations of many of the Action Plan’s principal actions and goals. Therefore, the 

SAB supports the conclusion that enough is known about the issues confronting the Great Lakes, 

as well as the underlying causes and potential remedies, to take initial action and agrees that the 

Action Plan identifies the important first steps to be undertaken. 

On the surface, the Action Plan appears consistent with previous plans and strategies, reflecting a 

continuation of collaborative planning in the region. While continuity in planning is good, such 

consistency does not guarantee sufficiency and, in some cases, it fails to promote the innovation

that comes from strong connections between research and action – a connection that is not

evident in the Action Plan. In addition, while the actions are consistent with many aspects of 

previous efforts, very few of the research, monitoring and integrative assessment needs identified 

in the earlier documents (e.g., SOLEC 2009) are carried through to the Action Plan. Some of the 

more important gaps are addressed in more detail in the following sections.

- As presented in the scientific background document, the goals, objectives, 

measures, and actions of the Action Plan are based on the best available scientific analysis of 

environmental challenges and are consistent with the multitude of strategic plans and governing 

structures for the Great Lakes. Since the Action Plan is an “action driver,” we are most 

interested in the SAB’s recommendations on the identified principal actions to achieve progress. 

Question 1a: Are the principal actions proposed in the Action Plan consistent with the actions 

and/or recommendations of the previous collaborative plans and strategies for the Great Lakes 

(e.g. Great Lakes Regional Collaboration Strategy) as identified in scientific background 

document and other information of which you are aware?

The SAB also concludes that the relationship between the Action Plan and lake-specific goals 

developed through the EPA-facilitated Lake Management Plan (LaMP) processes and the Great 

Lakes Fishery Commission-facilitated Lake Technical Committee processes is unclear. Specific 
12

water-quality, fishery and habitat goals have been established through extensive stakeholder 

processes (i.e., scientific community, policy makers and members of the public) and it is 

important that the Action Plan support achieving those goals. Based on the material provided to 

the SAB, it is not clear whether or how the Action Plan will support these goals.

The SAB recommends that EPA outline explicitly how the Action Plan supports the Lake-wide 

goals and objectives established by the LaMPs and Fishery Technical committees, including 

their research, monitoring, and assessment recommendations.

Question 1b: Are there other actions that we should consider for inclusion in the Action Plan 

that will better achieve the goals of the Action Plan?

While science is only one basis for taking particular action (e.g., others can include availability 

of matching funds, state and local priorities, and partner development), evaluation of the 

effectiveness of actions taken is a scientific process and needs to be included more explicitly 

within the Action Plan. For a program as large, complex, and hopefully sustained as the GLRI, it 

is critical to understand, measure, and track the impacts of initial actions and make adjustments 

as needed within an adaptive management framework. However, the SAB notes that, while 

monitoring appears to exist for some projects, overall there is insufficient monitoring, 

assessment, and evaluation to support adaptive management. Science-based tracking and 

evaluation should be considered as important as direct “restoration actions,” and such efforts 

should be considered integral to the Action Plan. 

Adaptive management is a well-established concept in environmental management. 

Implementation of an adaptive management framework will require systematic and continual 

integration of design, management, and monitoring, which would enable EPA and the IATF to 

make informed adjustments and adaptations in the restoration efforts in the Great Lakes. The 

SAB recommends that EPA reframe the Action Plan using an adaptive management framework 

that includes support for measuring progress and making midcourse corrections, if necessary.

This is discussed further below in the recommendation related to the need for an integrated,

science-based framework that will bolster the Action Plan and a science advisory panel.

The SAB also notes that climate change is not addressed in the Action Plan. Restoration efforts 

at this magnitude and with the attending complexities will play out over time scales where 

changes in air and lake temperature, amount and patterns of precipitation, ice cover and lake 

levels are likely to occur and could significantly alter restoration effectiveness. Further, it is not 

clear if decadal trends of these properties have been taken into account while developing the 

actions. Therefore, the SAB recommends that EPA include efforts to explicitly consider the 

potential impacts of climate change on restoration over the lifetime of the projects in the Action 

Plan.

3.1.2. Tracking GLRI Projects and Accountability

Question 2 – As presented in the scientific background document, we have developed and 

currently operate the Great Lakes Accountability System (GLAS)3

 3 Available online at 

as the primary mechanism for 

collecting information to monitor and report on GLRI progress. GLAS is still a work-in-progress 

at this time and it is not ready for external review. However, given the scope of the Action Plan 

http://glri.us/projects.html
13

and the nature and types of projects funded under the GLRI, we are interested in the SAB’s 

recommendations on how best to track the progress and accountability for a large ecosystem 

restoration program. What critical environmental elements, endpoints, or other measures would 

you include to those identified in the Action Plan?

The SAB recognizes GLAS is a work in progress, but notes that the current system appears to be 

primarily an accounting – as opposed to accountability – system; that is, a system that tracks 

where the funding is going and who will be responsible for those projects. This is important 

information and the SAB appreciates the transparency. However, it should be noted that at the 

time of the review, less than half the agencies had entered information into the system. Some of 

the entries with multiple organizations appear to lack specificity on which organizations are the 

recipients of funding and ultimately responsible for the action. 

There is a potential to track outcomes and outputs for the projects in this system, and if pursued 

carefully GLAS could provide a solid basis for programmatic evaluation across the focus areas. 

However, the SAB finds it is likely not possible to integrate outcomes across hundreds of 

projects, essential for evaluation at the theme (e.g., toxic substances), lake, or system level, and 

for evaluation of the overall GLRI program. GLAS is probably not an appropriate vehicle for this 

type of integration, as it appears designed to function at the project level, and the diversity and 

granularity of those projects would make integration within GLAS difficult. An effective 

integrative assessment will require additional effort, perhaps building upon information reported 

in GLAS. 

Comments on the adequacy of the identified endpoints and measures will be addressed more 

specifically in responses to focus area charge questions below, but overall the measures often 

appear naïve or narrow, and without proper context or benchmarking. Measures should be 

cognizant of historical context and variability. Metrics to identify change or progress toward 

restoration should be developed such that they can be detected statistically, are scientifically 

significant, and attributed to management actions. Otherwise, it will not be clear when or if a 

measure of progress is achieved. This requires an understanding and explicit documentation of 

both historical baselines, the variability in the metric, the universe within which the metric is 

couched and the expected effect of the management action.

Most metrics identified in the Action Plan measure outputs as opposed to outcomes. These 

distinctions are important for reporting under the Government Performance and Results Act. 

However, the agencies have an opportunity to be innovative in environmental outcome

evaluation and reporting. The agencies should consider continuing to report the more typical 

project-level outputs through GLAS, but also outline for the Office of Management and Budget 

(OMB) an innovative program for evaluating and reporting environmental outcomes integrated 

across projects at the theme, Lake, and program level. By investing a modest portion of the 

overall budget on an innovative, science-based, integrated outcome evaluation program, there is 

the potential for the GLRI to move toward its restoration goals, and provide a new path toward 

evaluation and reporting restoration goals at more meaningful levels. 

The SAB recommends that EPA implement a new, focused, and perhaps independent scientific 

and integrative outcome evaluation process. This is discussed further below in the 

recommendation related to the need for a science plan, review panel, and a new independent 

entity.
14

3.1.3. Recommendations to Improve or Clarify the Action Plan

Question 3

Bolster the Action Plan with a Science-based Framework

– Please comment on the overall scope and framework of the Action Plan and its 

ability to organize environmental issues in a way that directs restoration actions. Does the SAB 

have any specific recommendations on how to improve or clarify the Action Plan?

The overall scope and framework of the Action Plan addresses many of the important issues and 

problems. However, the SAB is concerned that, while EPA may be able to report on projectspecific outputs and some outcomes, it will not be in a position to effectively measure and report 

on progress toward the overall goal of restoring the Great Lakes. The actions are organized 

primarily around stresses and mostly narrow geographies, as opposed to being organized at 

basin- or lake-scale goals that take into account multiple stresses. This is not to say that the 

specific actions will not add up to larger-scale restoration. Rather, because the GLRI is not 

organized around these larger goals (see above) and because there is not sufficient funding for 

monitoring and scientific evaluation at those scales, the GLRI will not know if those goals are 

being approached effectively. The GLRI lacks a larger-scale framework and a scientific 

evaluation plan to accompany the Action Plan. 

Overall, the GLRI and its Action Plan would be greatly improved by a comprehensive sciencebased framework that provides a foundation of past and current scientific understanding, 

integrates restoration across focus areas, and documents the scientific basis to evaluate GLRI 

actions. Herein, we refer to this framework as a “science plan.” This science plan will identify 

restoration goals, how projects may meet those goals and guide the development of future 

iterations of the Action Plan past 2014. A science plan should also demonstrate and ensure the 

following key elements are addressed:

• Provide the logic supporting how selected projects support the Action Plan;

• The timely availability of monitoring data; and

• Assessment of project outcomes, both positive and negative.

The SAB recommends that EPA work with natural, physical, and social scientists and engineers 

from government, academia, NGOs, and industry to create a forward-looking science plan that, 

when coupled with the Action Plan, creates a conducive framework for adaptive management.

A science plan for the GLRI would outline a plan and funding requirements for (1) integrating 

across stresses and projects; (2) creating opportunities for restoration innovation and increases in 

efficiency and effectiveness; (3) identifying and overcoming key impediments to progress; (4) 

monitoring, assessment, and evaluation at project, Lake, and system levels; and (5) increasing 

transparency of decision making processes. Each element is described briefly below. 

• A Need for Integration – While the symbolic notion of thinking of the Great Lakes as 

one ecosystem is often helpful, from the perspective of understanding, managing, and 

protecting them – the “Great Lakes” is not an ecosystem. As currently constructed, the 

Action Plan is focused around stress issues (e.g., toxic substances) and most of the 

language suggests the Great Lakes can be viewed as a single ecosystem. The individual 

Lakes are as different from each other as the Everglades, Chesapeake Bay, Puget Sound, 

and Georges Bank are from each other, and it would not be logical to think of managing

them as a single ecosystem. Each Lake has unique characteristics, stresses, and likely 
15

restoration goals, and it would be more effective, especially in terms of measuring and 

reporting progress, if the goals and objectives were lake-specific. There already is a basis 

for this approach. Each Lake has a Lake-wide Management Plan (LaMP) or the 

equivalent (Lake Huron is treated differently). LaMPs are developed through stakeholder 

engagement, focused on water quality, and have shown a recent movement toward 

broader ecosystem goals. Each Lake also has a set of fisheries goals, established through 

the Lake Technical Committees facilitated by the international Great Lakes Fishery 

Commission and engaging all appropriate stakeholders. Recent efforts have also moved 

toward habitat and broader ecosystem contexts. A science plan developed for each Lake 

would be helpful in focusing the Action Plan at lake scales.

Organizing a science plan around individual Lakes also may help provide a better overall 

context for actions to restore the Great Lakes. A set of clearly defined objectives should 

be developed to understand and assess the collective impacts of the myriad projects. 

Meeting those objectives would constitute progress in the restoration of the Great Lakes.

The Action Plan currently addresses a series of critical stresses (e.g., toxic substances, 

nonpoint source pollution, and habitat loss) with limited recognition of the potential for 

synergistic or antagonistic actions among the silos potentially created by the focus areas. 

It may also make sense to reshape the Action Plan such that “habitat restoration” 

becomes an overarching goal and strategy, and each of the remaining stress-focus areas is 

redesigned to support habitat restoration. This would be more consistent with the 

ecosystem management paradigm often discussed in Great Lakes management circles and 

cited in the Great Lakes Water Quality Agreement, and would allow for integration 

across the focus areas (IJC 1988 and 2006).

• An Opportunity for Innovation – The SAB recognizes there is an extensive backlog of 

restoration projects in the Great Lakes region that need to be pursued, and supports the 

agenda of putting primary emphasis on implementing those projects. However, the level 

of sustained funding that is in place and anticipated provides the agencies with an 

opportunity to be revolutionary, as opposed to evolutionary, in its implementation. This 

level of funding should not only satisfy the myriad long-standing needs, but also provide 

a new model for how large-scale restoration can be effected – an opportunity for 

innovation. This argues for a place in the science plan for modest investments in 

improving the understanding of the ecosystems that are being restored and developing 

new restoration technologies, methods, and approaches.

• Understanding and Overcoming Impediments – The current plan suggests that restoration 

and protection can be accomplished through natural science and engineering processes 

alone. This is rarely the case in environmental decision-making. Significant roadblocks to 

action can come from social, economic, political, and other human dimensions. 

Investments in behavioral, social and decision science analysis of the science-policy 

interfaces in the region can provide important information on avoiding implementation 

pitfalls and overcoming impediments to action. Therefore, the behavioral, social and 

decision sciences should be included explicitly in the science plan.

• Scientific monitoring, assessment, and evaluation – The science plan should review and 

refine environmental outcome measures for each project. It should outline the 

requirements for and approaches to monitoring, assessing, and evaluating those projects 
16

in the context of the goals developed at large scales. While efforts at the project scale 

should be retained and funded within each project, the science plan also should develop 

an approach for monitoring, assessing, and evaluating efforts across projects, focus areas, 

and perhaps Lakes.

• Increasing Transparency – While GLAS provides a transparent identification of the 

funding allocation and projects selected, it is not clear to the SAB how priorities among 

focus areas or projects were established. A technically sound prioritization process that 

considers the ecological value of potential restoration efforts is essential to program 

success. While it is clear that ecological value is only one metric that needs to be 

considered in assigning priority and that social, economic and political elements also 

must be factored, the lack of a clear description of the process used for generating relative 

ecological values for the GLRI projects underlines the need for the science plan. In 

addition, the EPA should peer review all project proposals using criteria such as those

employed by the National Science Foundation (2011a and 2011b).

Independent Science Advice and Implementation

The SAB recommends that EPA establish a science advice and implementation structure that 

ensures routine expert advice from government, academic, industry, and NGO sectors on the 

science plan, as well as an external entity for implementing key elements of the science plan.

• Independent Science Advisory Panel – This panel would be comprised of senior level 

natural, physical, and social scientists and engineers from government, academia, 

industry, and NGOs without conflicts of interests or stakes in particular projects. This 

advisory panel would be convened every 1-2 years to review the science plan and 

restoration progress, evaluate new scientific findings, and recommend appropriate 

adjustments to the action plan and science plan. Government and other scientists to staff 

the science advisory panel is an additional consideration. Support to develop the science 

plan, manage scientific assessments and syntheses of topics of management and 

restoration concern, fund critical gap-filling research identified in the science plan, and 

coordinate scientific efforts to integrate across projects, focus areas, and themes could 

come from EPA, the IATF, or a support staff could be created outside government.

The SAB is familiar with and supportive of advisory structures and institutes established to 

provide the scientific foundation for restoration efforts. The Puget Sound Institute, the Scientific 

and Technology Advisory Committee of the Chesapeake Bay Program and the Delta Science 

Program in the Sacramento-San Joaquin Delta are some examples. These efforts serve as 

potential models for innovative ways to engage scientists in developing and implementing the 

science plan; supporting and managing scientific assessments and syntheses of critical 

restoration issues; funding critical gap-filling research; and integrating scientific efforts across 

projects, focus areas, and themes. The SAB recommends that EPA consider aspects of these 

models in implementing this approach so that the EPA and IATF may identify and incorporate 

elements from other plans to tailor a panel and plan that addresses the needs of the GLRI. 

In addition, in response to an early draft of this report, EPA requested advice on the level of 

funding that would be appropriate for supporting scientific monitoring, assessment, and 

evaluation. In other major restoration efforts, the percentage of funding dedicated to support 
17

monitoring, assessment, and evaluation of individual projects appears to range between 5 and 50

percent depending on the scope, effort, and parameters monitored. 

While it is difficult a priori to determine the right value for the GLRI, and since at least some 

scientific monitoring, assessment, and evaluation is imbedded in the individual focus areas, the 

SAB recommends that a sufficient percentage of the overall GLRI budget explicitly be allocated 

annually for these tasks. In addition, the SAB urges that funds be made available to implement 

the recommendations for a science plan, science advisory panel and to provide the resources 

needed to support and manage tasks assigned to the science advisory panel. 

3.2.

Focus Area 1 of the Action Plan addresses toxic substances, with emphasis on continuing or 

enhancing long-term declines in legacy pollutants (Question 4) and on managing emerging 

contaminants (Question 5). The Action Plan builds on the considerable history and experience 

studying and controlling toxic chemicals in the Great Lakes, and the Action Plan is clearly 

directed towards continuing this effort. This is a sound approach. However, as discussed above, 

the SAB finds that both the overall GLRI and the toxic substances focus area would benefit

greatly from a strategic science plan that prioritizes actions and assists in choosing remediation 

sites. Actions linked to the goals and objectives within the strategic planning for the toxics focus 

area should be based on a risk characterization that reflects current and anticipated future 

conditions in the Great Lakes.

Toxic Substances and Areas of Concern

3.2.1. Legacy Contaminants

Question 4 – The presence, significance, and trends of many historically-regulated (or “legacy”) 

contaminants in the Great Lakes are well-documented. Through the Action Plan, we are working 

to fully implement and enhance existing programs to eliminate releases of many of these 

contaminants. For example, the GLRI is working to accelerate the rate of sediment remediation 

in Areas of Concern (AOCs) through the Great Lakes Legacy Act4

 4 Funding under the Great Lakes Legacy Act is now part of the GLRI. 

among other programs. 

Similarly, the Action Plan calls for initiating strategic pollution prevention and toxics reduction 

efforts to minimize releases and emissions of many of these same contaminants. 

Question 4a: Please comment on the Action Plan’s approach for addressing so-called “legacy” 

contaminants through sediment remediation and toxics reduction efforts.

The Action Plan’s stated goal of delisting five AOCs by 2014 is commendable but extremely 

aggressive given historical rates of de-listing, program logistics, and system response times. The 

SAB recommends that this measure of progress in the Action Plan should be clarified – is the 

goal to delist five AOCs by 2014 or is it to complete the management actions thought necessary 

to lead to a delisting? Both are stated in the Action Plan. Some quantitative analysis should be 

included on the implications for other GLRI toxics measures of progress if the goal is not met by 

2014. Stated another way, what is the incremental benefit to the Great Lakes derived from each 

successive AOC delisting, and what extent of AOC clean-up (number of sites, intensity of cleanup at each site) will be required to meet the toxics goals? Further analysis is needed to explore 

how the toxics measures of progress work together – for example how does delisting a given 

AOC contribute to the goal of reducing fish tissue PCB concentrations and therefore the number 

and frequency of fish consumption advisories?
18

Over the past decades, the record of delisting Great Lakes AOCs is poor, with only four AOCs 

cleaned up in approximately 20 years, due in part to the large cost of implementing source 

controls and dredging, disposing, and capping of contaminated sediments. Even with the 

resources available through the GLRI, not all Great Lakes AOCs can be addressed immediately, 

and a rational method to prioritize and rank sites is needed. The Action Plan and supporting 

documents should provide further detail describing how the GLRI prioritizes the order of cleanup activities. Prioritization of AOCs should be clearly linked to the remedial action plans already 

established for each AOC in a manner that integrates the stated objectives in the Action Plan. 

The SAB recognizes that the selection of AOC projects is often driven by factors beyond 

science, and includes the availability of willing local partners and matching funds. However, 

there should be an independent, science-based ranking of AOCs to determine which site cleanups will best assist in meeting the GLRI toxics goals.

Question 4b: Please comment on whether the Action Plan addresses the reduction of “legacy” 

contaminants at all geographic scales sufficiently to restore the Great Lakes ecosystem. 

A major strategy for addressing so-called legacy contaminants is the accelerated clean-up of 

AOCs. Contaminated sediments are often a continuing chronic source of persistent chemicals to 

Great Lakes biota. Therefore, a strategy based on cleaning up contaminant hot spots has a high 

probability of reducing pollutant levels and effects to biota on a regional basis and may have 

similar success on a basin wide basis. However, as noted in the Action Plan there are a number 

of other possible impacts from a wide range of chemical contaminants, and the SAB cautions 

that the agency favor an approach that balances the need to remediate known problems (e.g., 

polychlorinated biphenyls (PCBs) in sediments) while systematically addressing previously 

understudied legacy contaminant issues. Such balance could be achieved by conducting a 

rigorous hazards evaluation within an adaptive management framework.

Question 4c: Are there other actions that we should consider?

The SAB identified several additional actions the agency should consider as it implements the 

Action Plan. Rigorous analysis of the anticipated and realized ecological benefits of proposed 

AOC cleanups should be conducted using established methods in a transparent manner. This 

includes both evaluative models relating the magnitude of benefit to the extent of proposed 

clean-up before the restoration as well as a post-clean up effectiveness assessment. These 

evaluations should include the anticipated and realized benefits to the AOC area itself as well as 

the adjacent Great Lakes open water. Both types of evaluation should include estimations of the

links between reduced sediment concentrations and biological endpoints (e.g., tissue residues or 

biological effects), and the overall impact of the AOC delisting on contaminant body burdens in 

Great Lakes fish (and therefore fish consumption advisories).

Performance management of the AOC restoration program is critical, and needs to go beyond 

program tracking to include scientifically defensible metrics of success. The SAB recognizes that 

this work will require resources that might otherwise go to additional site clean-up actions, and 

that these resources may be required for many years after the clean-up operations are completed. 

Nonetheless, assessing success, partial success, or failure of these AOC cleanup programs is 

essential to improving the Nation’s ability to clean up the Great Lakes.

The Action Plan has few biologically based indicators and the current SOLEC (2009) analysis 

includes external lesions in fish as the sole biologically based effects indicator. Development of 
19

additional, biologically-based effects monitoring is required. Many human health indicators and 

environmental health indicators were not evaluated in the 2009 SOLEC report due to lack of data

and this gap must be addressed by GLRI-supported projects. The toxics measures of progress are 

focused on PCBs and seem to underemphasize the role of mercury despite the greater 

contribution of the latter to fish consumption advisories across the Great Lakes basin (IJC 2004;

U.S. EPA 2003; IJC 2009a). Polycyclic aromatic hydrocarbons (PAHs) also warrant more 

defined actions in the GLRI, given recent findings showing the effects of low levels of these 

compounds on early life stages of a wide variety of fish species (Incardona et al. 2004; Carls et 

al. 2008; Incardona et al. 2009; Hicken et al. 2011; Turcotte et al. 2011). The SAB recognizes 

that focusing on PCBs will likely have a “multiplier effect” for other compounds (e.g., they too 

will be reduced) and that other initiatives exist to address some of the other persistent, 

bioaccumulative and toxic (PBT) compounds in the Great lakes. However, the Action Plan does 

not address the nature of these efforts in any detail.

3.2.2. Chemicals of Emerging Concern

Question 5

The SAB notes that the Great Lakes science community has made significant progress towards 

prioritizing emerging contaminants by using the Muir and Howard (2006) analysis. Further 

details about how this work is influencing basin-wide monitoring and risk assessment programs 

are needed in the Action Plan. GLRI requires a scientifically sound framework to address and 

prioritize emerging contaminants, in order to avoid pursuing an unwieldy number of chemicals. 

The SAB notes that the approach developed by the U.S. EPA Midwest Ecological Research 

Laboratory for personal care products and pharmaceuticals (Ankley et al. 2005) is an example of 

such a framework. The choice of which emerging contaminants to focus upon must be led by the 

contaminants’ effects on aquatic species and human health at the levels found or anticipated in 

the Great Lakes. With a few important exceptions (brominated flame retardants, fluorinated 

surfactants), consumption of Great Lakes fish is not likely to be a major health risk exposure 

– The Action Plan also acknowledges the threats posed to the ecosystem by chemicals 

of emerging concern, such as flame retardants, surfactants, pharmaceuticals and personal care 

product constituents. To devise and implement effective control strategies, EPA and the other 

federal agencies are coordinating efforts to identify significant sources and impacts of new 

toxics to the Great Lakes ecosystem through robust surveillance and screening. 

Question 5a: Please comment on our approach for assessing and managing the risks posed by 

chemicals of emerging concern.

The Action Plan briefly considers emerging contaminants in a single principal action. This action 

links measuring progress of AOC clean ups and assessing new toxic threats. The Action Plan 

states that the program will develop an approach of comprehensive monitoring and assessment to 

identify significant sources and impacts of new toxic substances to the Great Lakes. Based upon 

this surveillance, the agency will “devise and implement effective control strategies” and 

coordinate with efforts to update the Toxic Substances Control Act (page 21). The SAB agrees 

that leveraging multiple statutes and regulatory mechanisms is an appropriate action under which 

to consider emerging contaminants. However, the SAB cannot determine if these actions are 

sufficient given the presentation in the Action Plan and provides additional commentary in its 

response to Question 5b. 

Question 5b: Are there other actions or specific chemicals of emerging concern that we should 

consider?
20

pathway for emerging contaminants. Unfortunately, for many of these chemicals there is little or 

no ecotoxicological information, making a ranking of emerging contaminants difficult. Further 

research with Great Lakes species, coupled with biological effects-monitoring, will be required.

Recommendations made by the International Joint Commission Work Group on Chemicals of 

Emerging Concern (IJC 2009b) should be incorporated into the GLRI Action Plan. These 

include:

• Improved bi-national cooperation and coordination on the underlying principles and 

processes by which emerging chemicals will be prioritized and then on the design and 

implementation of monitoring programs that set common objectives;

• Development of appropriate tools to adequately assess the exposures and impacts of 

emerging chemicals in the Great Lakes;

• Targeted studies to resolve significant gaps in the current state of the science;

• Further emphasis on moving upstream and adopting sustainable solutions to the 

design, production and consumption of chemicals of emerging concern;

• Strengthening pre-manufacturing notification and transparency in chemical 

production and use; and

• Adopting innovative approaches to chemical management in the Great Lakes that go 

beyond one-by-one chemical approaches.

Finally, the Action Plan and associated documents should recognize the interplay between all 

current and emerging stressors, including physical stressors such as increased UV penetration 

and those resulting from climate change (e.g., timing and magnitude of annual water temperature 

cycles, and acidification).

3.3.

Focus Area 2 of the Action Plan sets out a number of laudable long-term goals and objectives

designed to eliminate and control invasive species. However, the Action Plan offers relatively 

few specific details as to what exactly will be done regarding surveillance, and, in particular,

about the technologies that will be developed, refined, and employed to contain and/or control 

invasive species. The Charge to the SAB notes that there are separate, parallel actions under way 

to address specific invasive species (i.e., Asian carp) and vectors (i.e., ballast water controls), 

and seeks recommendations on additional technologies for detection and surveillance of invasive 

species. The SAB finds these parallel issues important, timely, and of value to the Action Plan. 

Therefore, the SAB cites some examples developed under these parallel efforts, as well as others,

that may be important to consider while developing an early detection surveillance program or 

implementing other actions for early detection and species removal.

Invasive Species

Question 6 – Invasive species have dramatically altered the Great Lakes ecosystem. New species 

continue to threaten the Great Lakes. The Action Plan identifies a set of actions intended to 

eliminate new introductions, control the spread, and minimize the risks of invasive species. EPA 

has initiated separate reviews for some of the principal actions in this focus area. Ballast water 

technology is being reviewed by a separate SAB panel. The Asian Carp activities are being 

addressed through the Asian Carp Control Strategy Framework that is being elevated to a 

program unto itself in coordination with GLRI. Therefore, we are asking the SAB’s for advice 

and recommendations on the remaining actions to address invasive species. 
21

3.3.1. Early Detection and Response

Question 6a: What are the key scientific data needed in an early detection surveillance network 

to provide up-to-date critical information for evaluating rapid response options?

One of the Action Plan’s objectives is to develop consistent methodology and protocols for a 

basin-wide invasive species surveillance program. The SAB supports this objective and 

recommends that surveillance and rapid response protocols be coordinated to ensure that the 

various states, provinces, and other participating organizations use the same methodology and 

protocols to provide meaningful information and effective rapid response. This coordination will 

be necessary to make the program effective.

In order to know which species are potential invaders, information is needed on what has 

occurred recently in the Great Lakes region and similar regions. Literature reviews and risk 

assessments that evaluate potential invaders in the Great Lakes, those that have become invasive 

elsewhere, and the vectors by which they could arrive will be critical sources of information 

(Johnson et al. 2001; Kolar and Lodge 2002; Anderson et al. 2004). The quality and quantity of 

these risk assessments will be the major determinants of the success of prevention and rapid 

response efforts. Data on the transport and sale of live organisms for bait, food, and pets 

(including backyard ponds) also should help inform these risk assessments and further identify 

which species are potential invaders in the Great Lakes. Indeed, as ballast water comes under 

control, other vectors, such as those cited above, may become the most likely sources of new 

invaders.

It is important to recognize that climate change is likely to facilitate invasion by many invasive 

species, including pathogens (Walther et al. 2002; Holzapfel and Vinebrooke 2005). Potential 

impacts of climate change include altered transport of invasive species, climatic constraints on 

invasive species, altered distributions of existing invasive species, impacts of existing invasive 

species, and altered effectiveness of management strategies (Hellman et al. 2008). In freshwater 

ecosystems, climate change is expected to cause warmer temperatures, reduced duration of ice 

cover, and altered stream flow patterns, which can affect pathways by which non-native species 

enter aquatic systems. Climate change will affect the likelihood of new species becoming 

established by eliminating cold temperatures that currently prevent survival. Conversely, some 

invasive coldwater species may not persist under warmer conditions. Ecological impacts of 

invasive species are expected to increase through enhanced competitive and predatory effects on 

native species, and increased virulence of some diseases (Rahel and Olden 2008). 

It is also important to recognize that the adjustment of species' ranges is an important mechanism 

through which ecosystems will adapt to climate change. Many native species will shift their 

geographic distributions northward, moving into areas where they were previously absent. As 

these shifts occur, the distinction between native and invasive species becomes blurred.

Recent and emerging technologies for measuring deoxyribonucleic acid (DNA) have great 

potential for surveillance, but probes must be developed for the different species that are of 

concern. Jerde et al. (2011) located the Asian carp invasion front using a technique called 

environmental DNA or “eDNA.” They analyzed over 1,000 water samples from the Chicago 

Sanitary & Ship Canal and other water bodies in the area. Using genetic tools, they screened the 

samples to find traces of eDNA from species, including Asian carp. In addition to showing that 

the invasive fish were much closer to the Great Lakes than people believed, the research 
22

demonstrated that eDNA is an effective tool for locating and monitoring aquatic species 

invasions. Assessment and, if warranted, adoption of this technology should move forward as 

rapidly as possible.

The availability of taxonomic expertise to identify and recognize many potentially invasive 

species may constrain efforts at early detection, especially for plankton and microscopic 

organisms. The SAB notes that there is currently a scarcity of taxonomic expertise and an aging 

taxonomic workforce that will be available for species identification, especially considering 

surveillance of such diverse ecosystems requires expertise in many different types of organisms. 

This may be an additional consideration for the outreach and education programs discussed 

under Focus Area 5.

Rapid detection and then response to invading organisms are complicated tasks, and must be 

supported by an intensive monitoring program in order to detect nonindigenous invasive species

(NIS) (unless they are large and conspicuous) before they become very abundant. However, such 

a program can also serve other purposes such as ecosystem monitoring, thus providing multiple 

benefits.

A single, rapid response plan should be adopted by all states and provinces that will provide for 

collective effort and will cut through jurisdictional barriers in advance. Otherwise, there will be 

excessive delays in responding and possibly shortfalls in resources, reducing the chance of 

successful eradication when there is still time to do so.

3.3.2. Prevention and Control Technologies

Question 6b: Does the SAB have any recommendations on demonstrated preventative and 

control technologies that could be applied to invasive species in the Great Lakes?

The Action Plan did not provide prevention and control technologies that are under consideration 

by the agency and requested that the SAB provide technologies that could be applied to invasive 

species in the Great Lakes. The SAB discussed some technologies and is providing general 

techniques for the agency to consider, with references and bibliographic citations. The SAB 

encourages the EPA to consider these technologies and recommends the agency develop criteria 

to evaluate these and additional studies to develop preventative and control technologies. 

• Selective Piscicides -- It is vital that selective poisons are truly selective for the invasive 

species under consideration. It is difficult to find a chemical that is toxic to certain fishes 

and not to others. Conover et al. (2007) provide information on selective poisons for 

Asian carp. Another important consideration is some of the fishes most sensitive to 

piscicides are among the most endangered fish species (e.g., sturgeons and native 

lampreys) in the Great Lakes basin (Boogard et al. 2003; McLaughlin et al. 2003).

Therefore, while such an approach may have merit, care must be taken to guard against

unwanted consequences.

• Pheromones --Pheromones to attract or scatter the Asian carp appear to be more 

promising in terms of not harming non-target species. Improvements to lamprey control,

such as more effective traps using pheromone attractants (Sorensen and Hoye 2007; Li et 

al. 2007), are being developed, as are repellants (Wagner et al. 2011). These are an 

improvement over existing chemical control, since lampricides are not entirely selective 

(Boogaard et al. 2003). 
23

• Ballast Water Technologies– There are plans to test the performance of the many

technologies that have already been developed to treat ballast water. This lab work 

should lead to bench and pilot-scale testing providing additional information. Genomic 

techniques could be used for monitoring the ballast water to see if it needs treatment. The 

report, Efficacy of Ballast Water Treatment Systems: a Report by the EPA Science 

Advisory Board, provides advice on technologies and systems to minimize the impacts of 

invasive species in vessel ballast water discharge (SAB 2011). The SAB notes the 

following as germane to the Action Plan, and recommends careful consideration of the 

report:

[The SAB’s] overarching recommendation is that the EPA adopt a 

risk-based approach to minimize the impacts of invasive species in 

vessel ballast water discharge rather than relying solely on numeric 

standards for discharges from shipboard [ballast water management 

systems (BWMS)]. The [SAB] found that insufficient attention has 

been given to integrated sets of practices and technologies that 

could be used to systematically advance ballast water management. 

These practices include managing ballast uptake to reduce the 

presence of invasive species, reducing invasion risk through 

operational adjustments and changes in ship design to reduce or 

eliminate the need for ballast water, development of voyage-based 

risk and/or hazard assessments, and treatment of ballast water in 

onshore reception facilities. The [SAB] recommended that a 

comprehensive analysis be done to compare biological 

effectiveness, cost, logistics, operations and safety associated with 

shipboard BWMS and onshore reception facilities. These practices 

include managing ballast uptake to reduce the presence of invasive 

species, reducing invasion risk through operational adjustments and 

changes in ship design to reduce or eliminate the need for ballast 

water, development of voyage-based risk and/or hazard assessments, 

and treatment of ballast water in onshore reception facilities. The 

[SAB] recommended that a comprehensive analysis be done to 

compare biological effectiveness, cost, logistics, operations and safety 

associated with shipboard BWMS and onshore reception facilities.

• Management of NIS Flora – Management activities for Phragmites australis provide an 

example of how management of plant species may need to consider a wider array of 

factors and biological or chemical control options. For wetland plants (and other species), 

one should evaluate the actual damage that they do, as well as the possible positive

ecosystem services the species may provide before starting wide-scale eradication 

(Hershner and Havens 2008). The capacity of invasive species to provide valued 

ecosystem services should be considered in the management of NIS flora. For example, 

contributions to food webs (Wainwright et al. 2000; Weis et al. 2002), improved habitat 

(Weis and Weis 2001; Yuhas et al. 2005), and sequestration of pollutants (Windham et al. 

2001, 2003; Windham and Meyerson 2003,) have been associated with Phragmites in 

tidal marshes. In addition, it is critical that a biological control agent be well-studied and

highly specific to the desired invasive species, and not attack other plants (Tewksbury et 

al. 2002). Other control methods for invasive plants involve the use of large amounts of 

herbicides, which, like piscicides, tend to be harmful to other species beyond the target 
24

species. One commonly used herbicide, glyphosate (Roundup®), is toxic to a wide 

variety of plants, to various aquatic animals (Tsui and Chu 2003), and to soil microbes 

that perform important ecosystem services (Busse et al. 2001).

• Physical Separation Technologies – The separation study for the Mississippi River and 

Great Lakes system provides considerations for the agency. Fences are being used to 

provide physical separation between the river and Lake Michigan in order to keep Asian 

carp out of the lake (Rasmussen et al. 2011). However, during spring high water, fish 

may be able to go through wetland areas to access lakes Erie and Michigan (Hochanadel 

2010; U.S. ACOE 2010). In general, erecting barriers could impair any migrations of 

native species as well, although this is not a concern for the manmade connection 

between the Mississippi River and Great Lakes.

• Education and Outreach programs – Well-considered education programs (not just 

“contact”) for the general public about releasing pets, and anglers releasing bait fish, are 

crucial. In addition, surveillance for juvenile carp and other invasive fishes among bait 

fish is needed. Target groups for intensive training should include field technicians, 

commercial fishermen, naturalists, subsistence fishers, and others already involved in 

observing, sampling, and handling of Great Lakes fauna and flora. People involved with 

GLRI should work together with the Sea Grant Extension staff in all Great Lakes states 

on these education programs in order to avoid duplication of efforts.

Finally, the SAB also recommends that the agency assess potential and current invasive species 

and prioritize which species present the greatest problem(s) for the Great Lakes. The SAB

concludes it would be wise to spend most of the effort and money on the most problematical 

species, and avoid reactions to all non-native species (Davis et al. 2011; Schlaepfer et al. 2011).

3.3.3. Other Possible Actions

Question 6c: Are there other actions that we should consider?

In general, a better understanding of which ecosystem characteristics increase susceptibility or 

resistance to invasions is needed (Milbau and Nijs 2004; Kuhn and Klotz 2007; Bulleri et al. 

2008). This understanding should be applied to manage the Great Lakes. Focus Area 4, Habitat 

and Wildlife Protection and Restoration, has a goal that includes restoring access of migratory 

fish species at fish passage barriers. While generally a positive goal, this may exacerbate 

problems with movement of problematic non-native species from the Great Lakes into their 

drainage basins. Therefore, the positive and negative impacts of barrier removal should be 

considered in each instance.

As noted generally above (Section 3.1), more meaningful and measurable metrics of ecological 

improvement are needed. Some of the metrics in the Action Plan are not practical. For example,

how can one measure if an average of 1.4 or 1.3 new species arrive? While the SAB recognizes 

that averages can be calculated over the longer term, such a measure is of little value in assessing 

whether the threat from invasions has been reduced. In addition, some measures need further 

specificity. For example, removing “5,000 lbs.” of invasive species is not a helpful measure, 

when one could be addressing either microbes, water fleas or Asian carp.
25

The positive and negative impacts of developing a fishery for Asian carp in the Mississippi 

should be evaluated. Once a species has proliferated and prevention is no longer possible, other 

management options must be considered, and for carp, this may include commercial and 

recreational fishing. While it is not likely that a fishing effort will eliminate the Asian carp, it 

could keep them at a lower population density in the rivers and thereby reduce the probability of 

their invasion of the Great Lakes. An Asian Carp Marketing Summit was convened in Illinois in 

the fall of 2010 to identify opportunities to market the fish as a way to reduce their numbers, and 

recommended that eating bighead and silver carp may be a feasible approach. Representatives 

from restaurants, commercial fishing, processing and related businesses, government agencies 

and academic institutions attended the summit and agreed that high value Asian carp fillets 

marketed to restaurants and retailers could provide a financial incentive for extensive harvesting 

of these fish. They further recommended that the harvested fish be exported to Asian markets 

where they are popular food fish, and that carp by-products be converted into pet food to 

eliminate waste and maximize efficiency and profit. Representatives also felt it was important for 

people with different expertise, for example, natural resource professionals and entrepreneurs, to 

work together to successfully market Asian carp. When the final summit report is completed, a 

summary of recommendations will be available online and updated as information progresses 

(From: ACES News (http://www.aces.uiuc.edu/news/stories/news5449.html).

An ecosystem context is desirable for management of invasive species (Arkema et al. 2006;

Schlaepfer et al. 2011) and management plans for ecosystems should include possible new 

invasive species. Wise management of such an approach requires the integration of data and 

information with modeling results when measured data are not available.

3.4.

Key elements of any restoration plan for the Great Lakes will have to target the principal sources 

of stress to reduce their effect on the Lake ecosystems, and the Action Plan does address these 

key elements. The SAB’s responses to Charge question 7 address the adequacy of the principal 

actions proposed for the Nearshore Health and Nonpoint Sources Focus Area and evaluate how,

if implemented, these actions would improve the Great Lakes and lead to a successful 

restoration. Many of the comments made relative to this charge question also can be applied to 

other focus areas as many of the issues raised are crosscutting. 

The SAB’s responses to the specific charge questions address the adequacy of actions and 

impacts associated with key stressors in the nearshore region that the agency should consider as 

it evaluates the GLRI and applies adaptive management to identify priorities. As identified in the 

Action Plan, the primary environmental stressors include excessive nutrient loadings from both 

point and nonpoint sources; bacteria and other pathogens responsible for outbreaks of avian 

botulism and beach closures; development and shoreline hardening that disrupt habitat and alter 

nutrient and contaminant runoff; and urban agricultural practices that increase nutrient and 

sediment loadings. The primary targets of restoration are aquatic living resources and human use.

Nearshore Health and Nonpoint Sources

3.4.1. Impacts from Phosphorus Loading

Question 7 - The report State of the Great Lakes 2009 has documented that “phosphorus loads 

may be increasing after a long period of decrease, and that an increasing proportion of the 

phosphorus is an available, dissolved form.” The increased phosphorus loads along with other 

stressors are degrading nearshore water quality as evidenced by eutrophication, harmful algal 

blooms (e.g. Cladophora and Microscystis) and avian botulism. To address these problems, the 
26

Action Plan identified a set of principal actions to improve the health of the nearshore areas and 

reduce nonpoint source pollution to levels that do not impair nearshore waters of the Great 

Lakes. These principal actions include identifying sources and reducing loadings of nutrients 

and soil erosion and targeting watershed plan implementation in high priority watersheds. 

Question 7a: Please comment on the adequacy of the principal actions to address the impacts 

associated with nearshore soluble reactive phosphorus, Cladophora biomass, and dreissenid 

biomass. 

As stated above, while the Action Plan is a five-year plan, it provides a unique opportunity to 

form the basis for a long-term restoration vision that could guide subsequent renewals of the 

Action Plan. To sustain that long-term vision, the SAB recommends strategic planning that 

includes mechanisms for assuring sound science and performance measures that would assess 

progress (see response to Question 3 in Section 3.1).

Reducing soluble reactive phosphorus loads is one of the more important measures of progress as 

it is a key stressor throughout the Great Lakes ecosystem. However, it is not clear if the proposed 

reduction targets will, as a whole, be large enough to make a measurable difference based upon 

the information provided. In addition, water quality will be an important part of assessing 

nearshore health but water quality measurements are highly variable in space and time. 

Performance assessment of the GLRI program should include statistically significant reductions 

in targeted measures, yet the monitoring program may not be sufficient for this purpose. This 

could lead to bias or a large degree of uncertainty in assessing performance if sufficient attention 

is not given to development of deliberate, science-based sampling designs. Failure to develop 

and implement sound sampling designs for targeted projects and long-term monitoring increases 

the likelihood that the Action Plan will not reach its goals. 

The SAB found that there was a lack of reference to dreissenids and Cladophora in this section 

of the Action Plan; however, there is some detail in the Scientific Background document (US 

EPA 2011). The International Joint Commission (IJC) Work Group on Eutrophication (2009c) 

addressed this issue and came to a similar conclusion. There is substantial evidence that 

phosphorus loads are contributing to nuisance and harmful algal blooms (Cladophora and 

cyanobacteria), but that there is weak evidence to support claims that a reduction in phosphorus 

loading will reduce the current problems in the nearshore. Given this uncertainty, the SAB 

recommends that the GLRI Action Plan address the need for rigorous monitoring and 

experimentation to separate and understand the effects of changing climate, water level variation, 

and invasion of dreissenids (see response to Question 3 in Section 3.1). 

It is not clear how metrics and their target quantities were determined. While the SAB recognizes 

that the targets were developed as first-cut policy measures (e.g., in response to GPRA), the SAB 

recommends thorough analysis and documentation to explain how the metric and target 

quantities relate to restoration. It is not clear if the quantities reflect significant or measurable 

improvement. For example, the increase in the percentage of good beach days seems very small. 

In the table on measures of progress (page 29 of the Action Plan), percentage of beaches meeting 

bacteria standards 95% or more of beach days has a 2006 baseline of 86%. The target for 2010 

was 86%, then 87% for 2011 and 2012. The target increases to 88% for 2013 and 89% for 2014. 

These are small changes in the targets for such an important measure of human health and 

restoration progress, and it is not clear if they are meaningful changes in terms of reducing 

human health risks. Bacterial problems in the nearshore appear to be acute and can lead to 
27

serious human health problems. A critical evaluation of what is a significant target to achieve in 

restoration is needed for this measure, in particular, and for other targets.

The baseline for the target parameters is provided in the Action Plan tables but the universe for 

these parameters is not always defined. It is very important that data on the parameter’s universe 

be given so readers can assess the magnitude of change associated with restoration efforts. The 

SAB recommends inclusion of the parameters range of values for all baselines. In addition,

discussion of the relative size of target numbers to universe is needed in the Scientific 

Background document (U.S. EPA 2011). For example, the U.S. Department of Agriculture

conservation practice acreage baseline is 165,000 acres. This represents about 0.4% of the total 

agricultural land in the U.S. Great Lakes watersheds (38,629,000 acres). The target percent 

increases out to 2014 would raise this percentage to 0.6%. While this change represents a 50% 

increase in conserved acreage, it is not clear if this is meaningful to the system. Details on where 

and how this percentage improvement will potentially result in positive restoration would be 

helpful.

The SAB could not assess if real ecological benefit will result from achieving the target numbers. 

For soluble reactive phosphorus, the Action Plan calls for a small, across-the-board reduction in 

all of the targeted watersheds. If this is achieved, it may result in different ecological benefits

within individual watersheds, ranging from no impact to some change in biological activity. 

Understanding how and why different systems responded the way that they did would be 

important information for planning future restoration efforts. No such mention of this complexity

is made in the Action Plan.

The SAB recommends that currently unexplained connections among actions and measures need 

to be addressed. For example, it is not clear how actions to “Identify sources and reduce loadings 

of nutrients and soil erosion” (the second principal action to achieve progress on page 30) will 

lead to a reduction in “the number and severity of incidences of ecosystem disruptions, including 

Cladophora, harmful algal blooms, [avian] botulism and other issues associated with 

eutrophication.” It is not clear if the target reductions will be enough to result in any 

improvement in the ecosystems and reduction in stress. While this is a weakness in the Action 

Plan, this is one place where the Action Plan recognizes the difficulty of setting complex targets 

and imbeds research and modeling efforts as part of the principal actions. The SAB considers 

research and modeling to establish the linkage between actions, measures, and targets to be a 

strength in the Action Plan and an essential strategic activity. The SAB recommends that the 

research and modeling effort be clearly identified and highlighted in the Action Plan as a 

separate activity (see response to Question 3 in Section 3.1). 

3.4.2. Other Recommended Actions

Question 7b: Are there other actions that [EPA] should consider?

The SAB recommends that greater consideration be given to how future development within the 

watersheds and how climate change will affect the Action Plan targets. From the establishment 

of Detroit in the early 1700’s to the present, human development has been the major driving 

force in altering the Great Lakes ecosystems. In particular, Lake Erie is prone to development of 

hypoxia (Delorme 1982). Now, global climate change needs to be added as a major driving 

force. Acknowledging climate change issues and how restoration efforts may be affected should 

be integrated throughout the Action Plan.
28

The Action Plan was released in February 2010. However, the tables in the Action Plan, prepared 

for a 2009 start, have not been updated since the release. The SAB recommends a column be 

added to the tables showing what was accomplished in 2010 and 2011 relative to target figures. 

Hundreds of projects have been funded and it is necessary to include some information on what 

has been accomplished. Footnote 19 notes that targets for selected subwatersheds were still under 

development in 2010 and not included in the Action Plan (page 29 of the Action Plan). This a 

prime example of why the Action Plan will need to be updated or revised and tables reset for 

2012. The agency should consider developing a separate mechanism to update the public and 

interested members of the scientific community, perhaps by using a status update or an annual 

report card.

3.4.3. Targeting Stressed Subwatersheds

Question 7c: Please comment on the Action Plan’s intent to target Great Lakes subwatersheds5

The focus on stressed watersheds and subwatersheds is good, but the selection process for the 

subwatersheds needs to be more understandable and transparent. In support of the selection 

discussions, the SAB recommends that at a minimum a complete list of stressed watersheds by 

Lake be included. It is likely that the value of this approach, to focus on the most stressed 

systems, can be made by the GLRI by 2014, if recommendations for outreach and monitoring are 

that show severe signs of stress for focused restoration activities as opposed to a broader 

approach that targets all watersheds (stressed and currently unstressed). 

The Action Plan’s intent to identify, map, and target the highest priority Great Lakes 

subwatersheds that show severe signs of stress for focused restoration activities is the best 

strategy for producing measurable positive outcomes. Overall, severely stressed systems respond 

positively and measurably to stressor relief. This is particularly true for stresses associated with 

excess nutrient loadings. Rabalais et al. (2010) documented at least 50 cases where hypoxia was 

reduced or eliminated by reductions in nutrient or organic matter loading. An approach that 

targets a broader range of watersheds in the Great Lakes likely would require significantly more 

resources.

While it is appropriate to implement projects at the subwatershed level based on severity of 

stressed habitats, restoring physical habitat also will require attention to stressors acting outside 

the subwatershed that may keep the restored habitat from functioning. For example, restoring

headwater habitat for anadromous fish may be irrelevant if their access to the habitat is blocked 

by degraded water quality down river. Thus, the SAB recommends that the subwatershed 

approach be backed by a sound plan for the entire watershed that considers how the ecosystem 

functions as a whole.

The SAB concurs that targeting BMPs is also a very good idea and may demonstrate the value of 

targeting to a broader community. In particular, the Action Plan should mention how agricultural 

BMP performance can be assessed. Some portion of the implementation resources needs to be 

targeted towards accounting for agricultural BMP performance, including selective monitoring 

and evaluation. The GRLI is not the first program developed to improve the Great Lakes’

degraded ecosystems. Some mention of previous and ongoing programs needs to be included so 

external observers can assess progress. One example would be to integrate the ongoing efforts on 

TMDL development and implementation with the recommended activities. 

 5 These include the targeted geographic watersheds identified on pages 16 and 28 of the Action Plan and other Areas of Concern
29

implemented. As the GLRI evolves and selects the next group of watersheds it will be important 

to demonstrate successful restoration and positive trends in metrics. Overall the Action Plan’s 

vision, goals, actions, and performance assessment need to be made clearer. 

3.5.

Focus Area 4 seeks to contribute to the improved health of the Great Lakes ecosystems through 

the restoration of key habitats. The goal is to implement these restorative measures in a manner 

that achieves five overarching goals in an environmentally sensitive manner:

Habitat and Wildlife Protection and Restoration

• Improve aquatic ecosystem resiliency;

• Maintain, improve or enhance populations of native species;

• Enhance wetlands, wetland-associated uplands, and high priority coastal upland and 

island habitats; 

• Identify, inventory and track progress on Great Lakes habitats including coastal wetlands 

restoration; and

• Restore habitat functioning in areas of concern.

Achieving the five goals of the focus area will require the development and application of a 

range of critical management actions and sound decision-making to protect and restore critical 

habitats and species. This focus area also addresses the restoration of habitat functions in, and 

native species use of, AOCs where contaminant remediation actions will be implemented. 

3.5.1. Aquatic Ecosystem Resiliency

Question 8 – One of the Action Plan’s principal actions to protect and restore habitat and 

wildlife is aimed at improving “aquatic ecosystem resiliency.” “Resiliency” is loosely defined in 

the Action Plan as providing an ecosystem with the capability to buffer the impacts of potential 

problems such as climate change. 

Question 8a: Please comment on the concept of “resiliency” in restoring and protecting aquatic 

habitats in the Great Lakes ecosystem. Does the SAB have any recommendations on actions to 

increase “resiliency?”

Restoring resiliency is an appropriate goal for this focus area. However, the Action Plan does not 

clearly articulate the concept of resiliency in the context of this Action Plan. In addition, 

adequate information was not presented to judge whether the actions associated with Focus Area 

4 would be effective at attaining enhanced ecosystem resilience in the face of disturbances.

The SAB recommends that a clear, working definition of resiliency be developed along with 

metrics that can be used to track changes in the resiliency over time as restoration measures are 

implemented. The topic of resilience of ecosystems is wide-ranging, and often misunderstood

(Holling 1973; Walker et al. 2002). It has received very little attention with respect to habitat 

restoration. It is critical that the Action Plan strive not just for resilience, but also for resilience 

associated with desirable future ecosystem conditions. Resilience can be high in systems 

dominated by invasive species (e.g., Phragmites) and low in some pristine systems (e.g., some 

oligotrophic lakes). Therefore, resilience alone does not define a desirable ecosystem condition. 

The resilience of an ecosystem condition that supports habitats of native and desirable aquatic 

and terrestrial species should be the goal. 
30

Ecosystems often appear to be resilient until a level of perturbation occurs that exceeds a tipping 

point (Ellis et al. 2011). Once a tipping point is reached, the ecosystem undergoes a dramatic 

change in condition. Such altered systems often have little resiliency as they cannot return to 

their original condition without intervention; in some cases restoring ecosystem conditions is not 

feasible. An example of a tipping point is increased turbidity in a shallow lentic habitat that 

reduces light reaching the lakebed enough to prevent the growth of submerged aquatic vegetation

(SAV). The changes associated with the SAV loss can include alterations in nutrient cycling, 

trophic organization and a shift in the animals occupying the site. Once such a change in system 

condition occurs, return to the original condition is unlikely without restoration actions. In the 

example above, reducing turbidity would represent the initial step and may require nutrient and 

sediment abatement actions. Even when light conditions are again appropriate to support 

SAVgrowth, revegetation of the site may occur very slowly if a source population of the plants is 

not proximate to the site. In some cases, moving vegetation from a donor site to the affected site 

may be required. Identifying these tipping points and implementing corrective actions before 

they are reached should be a component of any process to enhance ecosystem resilience. It is far 

more efficient and effective to identify and avoid these tipping points rather than attempt to 

restore conditions after they have shifted. 

A variety of stressors have challenged the resiliency of the Great Lakes over the past century. 

Excess nutrients, invasive species and toxic chemicals have caused fundamental changes in 

ecosystem characteristics. Climate change will affect the Great Lakes with increasing severity 

over the next century. Focus Area 4 is the only place in the Action Plan where climate change is 

explicitly identified as an issue, yet climate change also will affect efforts to achieve the 

objectives of the other focus areas. As noted earlier, the effect of climate change should be 

considered, as appropriate, for all focus areas of the Action Plan. Climate-forced changes in 

conditions over the next few decades may negatively influence the effectiveness of actions 

implemented to address Focus Area 4 objectives. Some potential effects of climate change 

include increased frequency and severity of major storms, increased temperature and elevated 

evapotranspiration. The increase in evapotranspiration may contribute to a drop in water level, 

threatening coastal wetlands and other aquatic habitats. The SAB recommends that, as a first 

step, the program evaluate climate change model predictions for the region and use this 

information to develop a habitat restoration strategy that will enhance the resiliency of the Great 

Lakes ecosystem to climate change. This strategy should include the consideration of the extent 

to which climate change may compromise the effectiveness of proposed restoration projects, the 

identification of particularly vulnerable key habitats and the development of methods to secure 

these vulnerable areas. 

3.5.2. Restoration Principles

Question 8b and 8c: Are there additional ecological elements or measures that should be 

considered to better improve resiliency or buffering capacity and our progress in habitat 

restoration and ecosystem protection projects? What about actions in other focus areas?

Questions 8b and 8c of the Charge are closely related. The SAB’s responses equally apply to 

both questions and are presented together. The SAB concludes that these recommendations may 

increase the resiliency of an ecosystem and identify additional ecological elements and measures 

the agency should consider as it evaluates the progress of the Action Plan and plans next steps. 

Resiliency is not explicitly discussed in the other focus areas of the Action Plan. The SAB finds 

that it should be a key consideration in the program. The general principles and concepts 
31

provided in the response to Question 8a, 8b and 8c are applicable to the other four focus areas 

and should be incorporated in the decision framework as appropriate.

There are certain ecosystem characteristics that have been shown to contribute to ecosystem 

capacity to resist state changes in the face of disturbances. This capacity is frequently what is 

meant by resilience. Restoration actions that enhance these ecosystem characteristics, therefore, 

should contribute to resilience. The SAB urges the agency to consider these following 

recommendations as appropriate to restoration actions:

• Reconnect the landscape elements (e.g., remove hydrological barriers) to enhance the 

flow of energy, materials and species throughout the ecosystem. 

• Consider natural habitat complexity as a key feature to enhance resilience. Use reference 

sites as models where appropriate (Bisson et al. 1997). 

• Utilize buffers of appropriate size and quality to mitigate impacts from various stressors

(Lowrance et al. 1995).

• Protect areas that currently support quality habitat and high levels of native biodiversity. 

Locating restoration projects near these high-quality protected sites can enhance the 

effectiveness of restoration actions (Doppelt et al. 1993).

• Cluster restoration projects in a manner that will contribute to the development of a 

restored landscape. Restoring ecological function at a landscape scale will greatly 

enhance ecosystem resilience (Naiman et al. 1997). 

• Establish recovery goals for populations of species of interest that specify abundance, 

density or productivity required to achieve a reasonable probability of persistence in the 

face of natural variation (McElhany et al. 2000). Restoration efforts can then be designed 

to re-create habitat to meet these demographic targets for focal species.

• Select restoration projects with some understanding of the “return time” of disturbances. 

Some understanding of the frequency and severity of disturbance events a restored site is 

likely to experience provides useful information regarding project design and 

effectiveness (Bisson et al. 1997).

The SAB concludes that considering and incorporating these elements, as appropriate, in the 

Action Plan will enhance ecosystem resilience and therefore, contribute to long-term 

sustainability of habitat conditions and improved levels of native of biodiversity.

3.5.3. Restoring Resilience and Measuring Progress

Question 9 – The Action Plan broadly defines “restoration” to encompass physical, biological, 

and chemical functions and processes. Are the actions listed in the Action Plan “restoration” 

actions?

The simple answer to this question is that most of the actions listed under Focus Area 4 are 

“restoration” actions. The more relevant question for the GLRI is whether these actions will 

enable the attainment of the Focus Area 4 objectives. The SAB finds that the italicized principal 

actions (page 34 of the Action Plan) may be more appropriate as goals for the protection and 

restoration of habitat and wildlife. Actions that are more specific would further describe the 

efforts to achieve these goals. This change would represent the first step towards addressing the 

ambiguity in the links between vision, long-term goals, objectives, and principal actions in the 

Action Plan. Additionally the SAB recommends that the Action Plan tie monitoring elements 
32

more directly to goals. The more clearly and transparently the agency can communicate the 

connection between the monitoring metrics and the goals, the easier it will be to document how 

well the actions are working to meet the goals.

The Action Plan includes stocking native fish and other aquatic species as a critical management 

activity under long-term goal 2 of this Focus Area. The SAB notes that fish stocking programs as 

a tool for restoration may have unintended consequences. There are many examples where 

stocking has hurt native populations, and generally degraded ecosystem conditions (Evans and 

Wilcox 1991; Fitzsimmons et al. 2007; Chilcote et al. 2011; Carpenter et al. 2011). Although the 

SAB understands the need for this type of action, application of fish stocking programs requires 

careful evaluation. 

The SAB acknowledges the unprecedented scale of the GLRI, which bounds on intractable in 

terms of size and complexity. For this reason, the SAB recommends that specific actions that are 

implemented have at least a moderate probability of working at a scale and in locations where 

they have the potential greatest positive impact on the ecosystem. In order to determine the 

potential of a specific action to succeed at an appropriate scale, the SAB provides a list of 

considerations (Appendix B) to stimulate discussion by the participating agencies as actions or 

projects are solicited, implemented, and evaluated. These considerations include a systematic 

approach to evaluating actions, locations, and uncertainties relative to the goals for the program. 

Measuring Progress Toward Goals

It is important to develop a transparent method and set of metrics to measure net ecosystem 

improvement that is sustained by building resilient systems. Some methods and attributes for 

doing this include sources and levels of evidence, detectable signals in the broader ecosystem, 

and quantification of cumulative effects of multiple actions.

The SAB recommends the formal integration of an adaptive management program with clearly 

articulated goals and explicit statements of what the program seeks to accomplish. This involves 

the development of a system-level model, which identifies and prioritizes all factors (natural and 

anthropogenic) that could potentially affect attainment of the stated goal(s). Once the goals are 

clearly articulated, the current management efforts are assessed to identify gaps and/or overlaps 

in the management programs addressing the priority factors affecting goal attainment. A 

management strategy is then developed in coordination with implementation planning by 

stakeholders.

A monitoring program can only be designed after the goals and management strategy have been 

determined. Assessing management performance is the first priority to support adaptive 

management. The criteria for success and/or failure of management efforts should be known 

when the strategy is developed and the monitoring program is designed. This analysis informs 

adaptation. It involves defining uncertainties around intermediate targets and establishes decision 

thresholds that trigger a change in management actions. Based on the monitoring assessment, the 

system-level model for goal attainment is amended and monitoring strategies revised to improve 

performance and reduce uncertainty (Hershner 2011).

Products and Tools for the GLRI

Outcomes from an effective adaptive management approach may include model runs to predict 

outcomes of future actions based on what has been learned, recommendations for improvements 
33

and research to reduce uncertainty of actions, and annual reports or report cards that summarize 

progress and provide recommendations, define the decision process, and develop action 

recommendations.

3.6. Accountability, Education, Monitoring, Evaluation, Communication, and 

Partnerships

Question 10

3.6.1. Integrated Assessment, Evaluation and Accountability

– Focus Area 5: Accountability, Education, Monitoring, Evaluation, 

Communication, and Partnerships, is intended to provide the “necessary backbone” of the entire 

GLRI through oversight, monitoring and assessment, education and outreach, and partnerships. 

This focus area is intended to implement assessment and evaluation actions to address gaps in 

knowledge and an inadequate understanding of complex and emerging issues. 

The topics addressed under Focus Area 5 are important to the overall success of the GLRI. 

Question 10 focuses on critical data gaps and tools to increase collaboration and implement the 

GLRI focus areas. Question 11 addresses outreach and education to incorporate Great Lakes 

stewardship into curricula across the Great Lakes region. As previously discussed, the SAB 

concludes that the monitoring and other elements presented in this focus area may be better 

addressed in each of the specific focus areas rather than a combined focus area and notes that 

monitoring, synthesis and integration across the focus areas should be included in the Action 

Plan to bolster the accountability goals of the GLRI. The SAB further provides recommendations 

to provide greater accountability, increase collaboration among partners, and enhance 

educational and outreach opportunities. 

Question 10a: Does the SAB have any recommendations of critical data gaps for which 

programs or tools should be implemented in the other focus areas? 

The SAB concurs that overall assessment and a management framework are necessary for the 

GLRI, and provides recommendations on how best to achieve this in Section 3.1. In addition, the 

SAB has discussed data gaps, tools, and other implementation recommendations for each of the 

focus areas in the response to the charge questions. Monitoring is a concern in each of the other 

focus areas, and the SAB endorses efforts to include sufficient monitoring to allow meaningful 

assessment and evaluation of individual project activities. In contrast, monitoring and evaluation 

in Focus Area 5 should be broader in order to assess integration and synthesis of actions to 

achieve overarching goals and the accountability of the GLRI as a whole. This assessment 

requires measures of progress based on benchmarks for expected outputs and outcomes relative 

to attainment of Action Plan objectives. 

The SAB notes that a framework and important tools to develop a holistic approach to evaluation 

of the effectiveness of Action Plan are missing. The SAB has previously noted the lack of a

science-based, integrated outcome evaluation program in the Action Plan. Future iterations of the 

GLRI would benefit from the inclusion of a section that explicitly addresses synthesis and 

integration. Synthesis and integration are relevant to the Great Lakes effort in many ways.

Identifying how efforts in one action area may be synergistic or antagonistic with goals in other 

areas, how well the missions and mandates of different managing entities line up, and how 

efforts under one LaMP or a case study on one AOC can provide “lessons learned” for others.
34

The SAB also notes there is no discussion of management and the arrangements by which key 

commitments are established and maintained to achieve Action Plan goals. For example, 

identifying which entities, projects, or actions most contribute to the achievement of which goals 

and how progress is being measured can only be evaluated through integration and synthesis

using metrics that examine trends and meaningful change. Monitoring and evaluation is a key 

ingredient of accountability, and the LaMP framework seems to be a good place to focus 

development of monitoring efforts and accountability reporting. The SAB notes that EPA and 

Environment Canada, through the Great Lakes Water Quality Agreement, have made 

extraordinary efforts to use LaMPs to develop common ecosystem objectives for each of the 

Great Lakes and to identify Beneficial Use Impairments. The LaMP process has grown to 

include lake committees of the Great Lakes Fishery Commission, water quality managers, and 

other stakeholders who participate in public Forums, and the LaMP framework is thus potentially 

suitable for science-based integration of monitoring and accountability of the Action Plan.

The Action Plan addresses a wide variety of management activities and seeks to coordinate them 

through an adaptive management process. Without an explicit representation of management, 

however, the GLRI faces substantial challenges implementing performance evaluation based on 

principles of adaptive management. Management of the stressors affecting the heath of the Great 

Lakes involves direct and indirect actions. Some regulatory policies address stressors indirectly 

and depend upon various management agencies for implementation. Other management 

activities, such as fisheries regulation and regulation of point source discharges of contaminants,

address stressors directly. Management decisions concerning remediation action fall in between. 

Oversight of the Action Plan ultimately depends upon attribution of changes in state of a Great 

Lake’s ecosystem(s) to a management action through a scientifically defensible monitoring and 

assessment framework. In its present form, the Action plan lacks both an explicit representation 

of management activities and a science-based, comprehensive evaluation framework. The need 

for overall program management that provides program integration, monitors and evaluates 

outputs/outcomes, drives an adaptive management process, identifies uncertainties and data gaps, 

and examines trade-offs in management decisions is thus unmet. Without an accountability 

framework, the GLRI will do little to advance coordination and collaboration among Great Lakes 

partners to address key scientific issues.

The SAB recommends that EPA initiate four actions to provide greater accountability for GLRI 

projects and results:

• Place all project decisions in an explicit management accountability framework. The 

framework should identify the goal or objective addressed by the project, stressors 

affected and scale of effects, and specific management actions and responsible parties. A 

revised version of GLAS could provide a central repository for this information.

• Improve the logical connection of goals, objectives, actions, and metrics for evaluation 

across focus areas to permit an integrative assessment of the effectiveness of funded 

projects.

• Create a formal mechanism for overall program evaluation of the GLRI Action Plan that 

is explicitly linked to adaptive management.

• Fund a specific monitoring and assessment effort to evaluate progress at the project level.
35

3.6.2. Coordination and Collaboration Among Partners

Question10b: Please comment on the Action Plan’s approach for enhancing coordination and 

collaboration among Great Lakes partners to address key scientific issues.

The Action Plan lists the federal department-level members of the IATF and Regional Working 

Group that developed the Action Plan. It also alludes to approximately 200 organizations at the 

federal, state, local, and sovereign tribal nation levels. While it is clear that a great many 

stakeholder organizations are involved in the program, the key members among this complex 

constellation of interests and the roles they play are not apparent. There is little information on 

the participation at the international or state level. How is intergovernmental cooperation 

directed at Great Lakes recovery and how is it sustained? How does the current program build on 

existing efforts of the federal agencies, the states, and activities carried out under treaty 

agreements with Canada? A functional approach to partnerships needs to be described, what they 

are (e.g., science or outreach) and where they fit within the other focus areas.

Given the lack of specifics, it is difficult for the SAB to determine whether there are missing 

organizations. One important organizational tool that seems to be missing, however, is a standing 

science panel integrated into the management system discussed in the response to Charge 

Question 3. A well-integrated panel could influence the program’s evolution by providing 

assessments of progress in key areas. The science panel input on design, implementation,

monitoring, and evaluation efforts would provide a scientific basis for setting priorities across 

disparate actions. Members should be independent experts drawn from universities and other 

research institutions, the private sector, and government agencies, but selected for their expertise 

and not to represent their agencies. Such a panel could make substantial contributions to the 

development of both robust monitoring efforts and the adaptive management plan that would be 

a logical outgrowth of well-designed monitoring. This panel should have social as well as natural

and physical scientific expertise, and the social science represented should go beyond economics. 

Behavioral, social, and decision scientists can provide many kinds of insights and advice, 

ranging from assistance in targeting education and outreach efforts to identifying critical insights 

into the likely workability of particular institutional arrangements. It is likely that there are 

significant gaps in scientific understanding that will impede progress in the program, and a 

science panel would be instrumental in identifying those gaps and providing advice on how they 

can be addressed. The science panel should develop a strategic science plan and update it on a 

regular (e.g., biennial) basis.

Increased coordination and collaboration could be achieved by employing social media and 

increasing the availability of data and information from GLRI projects. For example, web-based 

GIS or other tools can be used to provide public access to site-specific data and data analyses at 

different scales. The GLRI could be informed by the experiences of other large restoration 

efforts (e.g., Chesapeake Bay, Puget Sound) and smaller efforts (e.g., Sacramento –San Joaquin 

Delta, Tahoe Basin).

3.6.3. Outreach and Education

Question 11 - Outreach and education are crucial in the effort to restore the Great Lakes. The 

Action Plan identifies the need to educate future generations to extend restore efforts. Please 

comment on the Action Plan’s approach to incorporate Great Lakes stewardship into 

environmental education curricula.
36

The Action Plan contains highly laudable goals for outreach and education, but generally lacks a 

strategic approach to achieve the stated objectives. Measures of progress were ambiguous and 

will be difficult to track. Currently, there are no specific indications in the Action Plan of the 

amount or type of resources allocated to these aspects of the program. The EPA needs to 

describe allocation of resources to educational efforts, and take a systematic approach to building 

new efforts and tapping into existing efforts (the NSF-funded regional Centers for Ocean 

Sciences Education Excellence are one example) to further the GLRI goals.

It is not clear if any education planners were involved in developing the Action Plan. If not, then 

educators and planners need to be engaged early in the process to help ensure that education 

materials developed under the GLRI are incorporated into the curriculum. For example, the 

Action Plan did not address the reality that new curricula in K-12 are difficult to introduce unless 

they help teachers meet assessment standards or state mandates. If environmental education 

about the Great Lakes is not part of a district's or State's Graduation Test, chances are that new 

modules will not be incorporated into the curriculum. Thus, the Action Plan should include a 

benchmarking effort on State(s) guidelines to determine how Great Lakes activities could be 

included in State electives or requirements.

The emphasis in this focus area seems to be on K-12 education and outreach, with the 

assumption that these activities will extend into higher education and graduate education. In 

terms of curriculum development, the initial focus should be teaching the teachers so that they 

are equipped to use the information. In addition, the development of human capital – the 

scientists, engineers, managers, and educators of the future – is an essential part of this program 

and should be explicitly considered. During presentations of the Action Plan at the July 2011 

SAB panel meeting, EPA stated that they use cooperative agreements to accomplish many of 

these activities using graduate students and postdoctoral researchers, but this is not indicated as a 

goal or measure of progress in the Action Plan. The SAB recommends that the Action Plan 

include a specific goal to develop human capital within the higher education network.

The SAB discussed the need for explicit requests for activities within the program to enhance 

educational and outreach opportunities. The SAB notes that in the 2010 round of funding, there 

were a number of funded outreach activities, but only one curriculum development project was 

listed. The EPA should consider targeted outreach and curriculum development projects that 

include activities from not only the natural sciences, but also behavioral and social sciences and 

humanities. For example, modules could be developed to incorporate ethical frameworks (i.e.,

European vs. Tribal worldviews) or environmental justice concepts into eco-curriculum or into 

history or philosophy programs (e.g., in an American and World Cultures classes). In addition, 

good opportunities exist within this framework for service learning and citizen science, 

especially in monitoring efforts (e.g., NSF's Science Education for New Criteria Engagements 

and Responsibilities program).

The SAB agrees that there is a need to incorporate educational and outreach activities as an 

overarching theme in all projects. During the July meeting, EPA stated that education and 

outreach activities are considered in peer-review, but this is not indicated as a goal or measure of 

progress in the Action Plan. The SAB recommends that EPA and its partners consider explicit 

peer review criteria for all activities (internally and externally funded) that include education and 

outreach with significant weighting. This is parallel with the peer-review process of the NSF 

(2011a and b.). The NSF's statement (NSF 1999) on the integration of research and education is: 
37

One of the principal strategies in support of NSF's goals is to foster 

integration of research and education through the programs, projects 

and activities it supports at academic and research institutions. These 

institutions provide abundant opportunities where individuals may 

concurrently assume responsibilities as researchers, educators, and 

students, and where all can engage in joint efforts that infuse education 

with the excitement of discovery and enrich research through the 

diversity of learning perspectives.

The SAB agrees with this principle and recommends that the Action Plan incorporate and utilize 

the same or similar criteria in its funded projects. These criteria involve a review of (1) 

Intellectual Merit, (2) Broader (i.e., societal) Impacts, (3) Project Assessment Plan, and (4) 

Project Data Management Plan. As discussed, the SAB underscores the importance of explicitly 

incorporating all of these criteria into the review process of all project proposals, both internal 

and external to the agencies. 
38

REFERENCES

Anderson, M.C., H. Adams, B. Hope and M. Powell. 2004. Risk assessment for invasive species. 

Risk Anal. 24:787-93.

Ankley, G.T., Black, M.C., Garric, J., Hutchinson, T.H., and T. Iguchi. 2005. A framework for 

assessing the hazard of pharmaceutical materials to aquatic species. In: R.T Williams 

(Ed.), Human Pharmaceuticals: Assessing the impacts in aquatic ecosystems. SETAC 

Press. Pensacola, FL.

Arkema, K.K., S. C Abramson and B. M Dewsbury. 2006. Marine ecosystem-based 

management: from characterization to implementation. Front. Ecol. Envir. 4:525–532.

Bisson, P.A.; Reeves, G.H., Bilby, R.E., Naiman, R.J. 1997. Watershed management and Pacific 

salmon: desired future conditions. Stouder, D.J.; Bisson, P.A., Naiman, R.J., eds. Pacific 

salmon and their ecosystems. Pages 447-474. Chapman and Hall. New York, NY.

Boogaard, M., T D. Bills and D. A. Johnson. 2003. Acute toxicity of TFM and a 

TFM/Niclosamide mixture to selected species of fish, Including Lake Sturgeon 

(Acipenser fulvescens) and mudpuppies (Necturus maculosus), in laboratory and field 

exposures. J. Great Lakes Res. 29 (supplement 1): 529-541.

Bulleri, F., J. F. Bruno, and L. Benedetti-Cecchi. 2008. Beyond competition: Incorporating 

positive interactions between species to predict ecosystem invasibility. PLoS Biol. 

6(6):162.

Busse, M.D., A. W. Ratcliff, C. J. Shestak and R. F. Powers. 2001. Glyphosate toxicity and the 

effects of long-term vegetation control on soil microbial communities. Soil Biol.

Biochem. 33:1777-1789.

Carls, M.G., L. Holland, M. Larsen, T.K. Collier, N.L. Scholz, and J.P. Incardona. 2008. Fish 

embryos are damaged by dissolved PAHs, not oil particles. Aquatic Toxicol. 88:121-127.

Carpenter, S.R., J. J. Cole, M. L. Pace, R. Batt, W. A. Brock, T. Cline, J. Coloso, J. R. Hodgson,

J. F. Kitchell, D. A. Seekell, L. Smith, B. Weidel1. 2011. Early Warnings of Regime 

Shifts: A Whole-Ecosystem Experiment. Science 332:1079-1082.

Chilcote, M.W., K.W. Goodson and M.R. Falcy. 2011. Reduced recruitment performance in 

natural populations of anadromous salmonids associated with hatchery-reared fish. Can. 

J. Fish. Aquat. Sci. 68:511-522.

Conover, G., R. Simmonds and M. Whalen (Editors). 2007. Management and control plan for 

bighead, black, grass, and silver carps in the United States. Asian Carp Working Group, 

Aquatic Nuisance Species Task Force, Washington, D.C. 223 p.

Davis, M.A.,M. K. Chew, R. J. Hobbs, A. E. Lugo, J.J. Ewel, G. J. Vermeij, J.H. Brown, M.L. 

Rosenzweig, M.R. Gardener, S.P. Carroll, K. Thompson, S.T. A. Pickett, J.C. 

Stromberg,.P. Del Tredici, K.N. Suding, J.G. Ehrenfeld, J. P. Grime, J. Mascaro, and J. 

C. Briggs. 2011. Don't judge species on their origins. Nature 474:153-154.

Delorme L. D. 1982. Lake Erie oxygen: the prehistoric record. Canadian Journal of Fisheries 

and Aquatic Sciences 39:1021-1029.
39

Doppelt, R., M. Scurlock, C. Frissell and J. Karr. 1993. Entering the Watershed: A New 

Approach to Save America's River Ecosystems. Island Press. Washington, D.C.

Ellis, B.K., J.A.Stanford, D. Goodman, C.P. Stafford, D.L. Gustafson, D.A. Beauchamp, D.W. 

Chess, J.A. Craft, M.A. Deleray and B.S. Hansen. 2011. Long-term effects of a trophic 

cascade in a large lake ecosystem. Proc. Nat. Academ. Sci. 108:1070-1075. 

Evans, D.O. and C.C. Wilcox. 1991. Loss of exploited, indigenous populations of Lake Trout, 

Salvelinus namaycush, by stocking of non-native stocks. Can. J. Fish. Aquat. Sci. 48 

(Suppl. 1):134-147.

Fitzsimmons, J.D. et al. 2007.Egg thiamine status of Lake Ontario salmonines 1995-2004 with 

emphasis on lake trout. J. Great Lakes Res 33:93-103.

Hellman, J.J., J.E. Beyers, B.G. Bierwagen, and J.S. Dukes. 2008. Five potential consequences 

of climate change for invasive species. Conserv. Biol. 22:534-543.

Hershner, C. 2011. Enabling effective adaptive management in the Chesapeake Bay Program. 

Http://archive.chesapeakebay.net/pubs/calendar/55106_03-03-11_Handout_3_11186.pdf

(Accessed 9/29/2011).

Hershner, C. and K. J. Havens. 2008. Managing invasive aquatic plants in a changing system: 

Strategic consideration of ecosystem services. Conserv. Biol. 22:544-550.

Hicken, C.L., T.L. Linbo, D.W. Baldwin, M.L. Willis, M.S. Myers, L. Holland, M. Larsen, N.L. 

Scholz, T.K. Collier, G.S. Rice, M.S. Stekoll, and J.P. Incardona. 2011. Sublethal

exposure to crude oil during embryonic development alters cardiac morphology and 

reduces aerobic capacity in adult fish. Proc. Natl. Acad. Sci. 108:7086-7090.

Hochanadel, D. 2010. Asian carp might have second route to Great Lakes. Great Lakes Scientist 

Available online. http://www.lakescientist.com/2010/asian-carp-might-have-secondroute-to-great-lakes (Accessed July 31, 2011).

Holling, C. S. 1973. Resilience and stability of ecological systems. Annu. Rev. Ecol. Syst. 4:1-23. 

Holzapfel, A.M. and R.D. Vinebrooke 2005. Environmental warming increases invasion 

potential of alpine lake communities by imported species. Global Change Biology 11:

2009-2015.

Incardona, J.P., T.K. Collier, and N. L. Scholz. 2004. Defects in cardiac function precede 

morphological abnormalities in fish embryos exposed to polycyclic aromatic 

hydrocarbons. Toxicol. Appl. Pharmacol. 196:191-205.

Incardona, J.P., Carls, M.G., Day, H.L., Sloan, C.A., Bolton, J.L., Collier, T.K., and Scholz N.L. 

2009. Cardiac arrhythmia is the primary response of embryonic Pacific herring (Clupea 

pallasi) exposed to crude oil during weathering. Environ. Sci. Technol. 43:201-207.

International Joint Commission (IJC). 1988. Revised Great Lakes Water Quality Agreement of 

1978, as amended by Protocol signed November 18, 1987. Consolidated by the 

International Joint Commission, United States and Canada. 

http://www.ijc.org/rel/agree/quality.html#ann2. (Accessed 9/7/2011).

International Joint Commision (IJC). 2004. Great Lakes Fish Consumption Advisories: The Public 

Health Benefits and Risks. Discussion Paper prepared by the Health Professional Task Force 

for the International Joint Commission. http://www.ijc.org/php/publications/pdf/ID1540.pdf

(Accessed 9/29/2011).
40

International Joint Commission (IJC). 2006. Advice to Governments on Their Review of the 

Great Lakes Water Quality Agreement: A Special Report to the Governments of Canada 

and the United States August 2006. http://www.ijc.org/php/publications/pdf/ID1603.pdf

(Accessed 9/26/2011).

International Joint Commission (IJC). 2009a. Great Lakes Water Quality Agreement Priorities 

2007-09 Series. Work Group Report on Risks and Benefits of Great Lakes Fish 

Consumption, 2009. IJC, Special Publication 2009-06, Windsor, On.

International Joint Commission (IJC). 2009b. Great Lakes Chemicals of Emerging Concern 

Advisory Work Group to the Great Lakes Water Quality Agreement Priorities 2007-09 

Series. Work Group Report on Great Lakes Chemicals of Emerging Concern, 2009. IJC, 

Special Publication 2009-01, Windsor, On.

International Joint Commission (IJC). 2009c. Eutrophication Advisory Work Group to the. Great 

Lakes Water Quality Agreement Priorities 2007-09 Series. Work Group Report on 

Eutrophication, 2009. IJC, Special Publication 2009-02, Windsor, On.

Jerde, C., A. R. Mahon, W. L. Chadderton and D. M. Lodge. 2011. “Sight-unseen” detection of

rare aquatic species using environmental DNA. Cons. Lett. 4:150–157.

Johnson, L.E., A. Ricciardi and J. T. Carlton. 2001. Overland dispersal of aquatic invasive 

species: A risk assessment of transient recreational boating. Ecol. Appl. 11:1789–1799.

Kolar, C. and D. Lodge. 2002. Ecological predictions and risk assessment for alien fishes in 

North America. Science 298:1233-1236.

Kuhn, I. and S. Klotz. 2007. From ecosystem invasibility to local, regional and global patterns of 

invasive species. Biol. Invas. 193:181-196.

Li, W., M. Twohey, M. Jones, and M. Wagner. 2007. Research to guide use of pheromones to 

control sea lamprey. J. Great Lakes Res. 33:70-86.

Lowrance R., L.S. Altier and J.D. Newbold. 1995. Water quality functions of riparian forest 

buffers in Chesapeake Bay watersheds. Washington, DC: U.S. Environmental Protection 

Agency Chesapeake Bay Program. EPA Publication 903-R-95-004 CBP/TRS 134/95.

McElhany, P., M.H. Ruckelshaus, M.J. Ford, T.C. Wainwright and E.P. Bjorkstedt. 2000. Viable

salmonid populations and the recovery of evolutionarily significant units. U.S. 

Department of Commerce., National Oceanic Atmospheric Administration Technical 

Memorandum. NMFS-NWFSC-42,156 p.

McLaughlin, R.L., J.E. Marsden and D.B. Hayes. 2003. Achieving the benefits of sea lamprey 

control while minimizing effects on nontarget species: conceptual synthesis and proposed 

policy. Can. J. Fish. Aquat. Sci. 29 (Supplement 1):755-765.

Milbau, A. and I. Nijs. 2004. The role of species traits (invasiveness) and ecosystem 

characteristics (invasibility) in grassland invasions: A framework. Weed Tech. 18:1301-

1304.

Muir, D.C.G. and Howard, P.H. 2006. Are there other persistent organic pollutants? A challenge 

to environmental chemists. Environmental Science & Technology 40(23): 7157-7166.

Naiman, R.J., P.A. Bisson, R.G. Lee and M.G. Turner. 1997. Approaches to management at the 

watershed scale. In: Kohm, K.A.; Franklin, J.F., eds. Creating a forestry for the 21st 

century: the science of ecosystem management. Pages 239-253. Island Press. Washington, 

D.C. 
41

National Research Council.1992. Restoration of Aquatic Ecosystems. Science, Technology, and 

Public Policy. National Academy Press. Washington, D.C.

National Science Foundation (NSF). 1999. National Science Foundation. Office of the Director 

Dear Colleague Letter. "Merit Review Criteria. NSF 99-172. Available on line. 

http://www.nsf.gov/pubs/1999/nsf99172/nsf99172.htm. (Accessed 9/23/2011).

National Science Foundation. (NSF). 2011a. Merit Review Factsheet. Available on line. 

http://www.nsf.gov/bfa/dias/policy/meritreview/facts.jsp. (Accessed 7/31/2011).

National Science Foundation. (NSF). 2011b. Dissemination and Sharing of Research Results 

Factsheet. Available on line. http://www.nsf.gov/bfa/dias/policy/dmp.jsp. Accessed

7/31/2011.

Rabalais, N. N., Diaz, R. J., Levin, L. A., Tuner, R. E., Gilbert, D. and Zhang, J. 2010. Dynamics 

and distribution of natural and human-caused hypoxia, Biogeosciences 7:585-619.

Rahel, F.J. and J.D. Olden 2008. Assessing the effects of climate change on aquatic invasive 

species. Conserv. Biol. 22:521-533.

Rasmussen, J., H. A. Regier, R. E. Sparks, and W. W. Taylor. 2011. Dividing the waters: The 

case for hydrologic separation of the North American Great Lakes and Mississippi River 

Basins. J. Gr. Lakes Res. In press.

SAB 2011. Efficacy of Ballast Water Treatment Systems: a Report by the EPA Science Advisory 

Board. EPA-SAB-11-009. 

http://yosemite.epa.gov/sab/sabproduct.nsf/02ad90b136fc21ef85256eba00436459/9e6c79

9df254393a8525762c004e60ff!OpenDocument&TableRow=2.3#2. Accessed 8/21/2011.

Schlaepfer, M.A., D.F.Sax and J.D. Olden. 2011. The potential conservation value of non-native 

species. Conservation Biol. 25:428-437.

State of the Lakes Ecosystem Conference (SOLEC). 2009. Environment Canada and U. S. 

Environmental Protection Agency. State of the Great Lakes 2009 Technical Report.

http://www.epa.gov/glnpo/solec/sogl2009/sogl2009complete.pdf. (Accessed 8/24/2011).

Sorenson, and Hoye 2007. A critical review of the discovery and application of a migratory 

pheromone in an invasive fish, the sea lamprey, Petromyzon marinus. J. Fish Biol. 71 

(suppl.) 100-114.

Tewksbury, L., R. Casagrande, B. Blossey, P. Häfliger and M. Schwarzländer. 2002. Potential 

for biological control of Phragmites australis in North America. Biol. Control. 23:191-

212

Thom, R.M., H.L. Diefenderfer, J.E. Adkins, C. Judd, M.G. Anderson, K.B. Buenau, A.B. Borde 

and G.E. Johnson. 2010. Guidelines, processes and tools for coastal ecosystem 

restoration, with examples from the United States. Plankton and Benthos Res. 5 (suppl.):

185-201.

Tsui, M.T. and L. M. Chu. 2003. Aquatic toxicity of glyphosate-based formulations: comparison 

between different organisms and the effects of environmental factors. Chemosphere. 52: 

1189-1197.

Turcotte, D., Akhtar, P., Bowerman, M., Kiparissis, Y., Brown, R. S. and Hodson, P. V. 2011. 

Measuring the toxicity of alkyl-phenanthrenes to early life stages of medaka (Oryzias 

latipes) using partition-controlled delivery. Environ. Toxicol. Chem. 30: 487-495.
42

United States Army Corps of Engineers (U.S. ACOE). 2010. Great Lakes and Mississippi River 

Interbasin Study: other pathways preliminary risk characterization. 

http://glmris.anl.gov/documents/docs/Other_Pathways_Risk.pdf . (Accessed 8/10/2011).

United States Environmental Protection Agency (EPA). 2010. Great Lakes National Program 

Office. Great Lakes Restoration Initiative Action Plan FY2010- FY2014. 

http://greatlakesrestoration.us/pdfs/glri_actionplan.pdf. (Accessed 7/12/2011).

United States Environmental Protection Agency (EPA). 2011. Great Lakes National Program 

Office. Great Lakes Restoration Initiative Action Plan Science Advisory Board 

Review:Scientific Background of the GLRI Action Plan.

http://yosemite.epa.gov/sab/sabproduct.nsf/C4139C3F39CBFE22852578B20063592F/$F

ile/Scientific+Background+of+the+GLRI+Action+PLanynthesis_Paper_GLRI_SAB+Re

view_final.pdf. (Accessed on 9/21/2011).

United States Environmental Protection Agency (EPA). Office of Water, 2003. National Listing 

of Fish and Wildlife Advisories. EPA-823-F-03-003. Washington, DC: Available: 

http://www.epa.gov/waterscience/fish.html. (Accessed 9/21/2011).

Wagner, C.M., E.E. Stroud and T.D. Meckle. 2011. A deathly odour suggests a new sustainable 

tool for controlling a costly invasive species. Can. J. Fish. Aquat. Sci. 68: 1157-1160.

Wainright, S., M.Weinstein, K. Able and C. Currin. 2000. Relative importance of benthic 

microalgae, phytoplankton and the detritus of smooth cordgrass Spartina alterniflora and 

the common reed Phragmites australis to brackish-marsh food web. Mar. Ecol. Prog. Ser.

200:77-91.

Walker, B., S. Carpenter, J. Anderies, N. Abel, G. Cumming, M. Janssen, L. Lebel, J. Norberg, 

G. D. Peterson and R. Pritchard. 2002. Resilience management in social-ecological 

systems: a working hypothesis for a participatory approach. Conservation Ecology 6(1): 

14.

Walther, G.R., E. Post, P. Convey, A. Menzel, C. Parmesan, T. Beebee, J.-M. Fromentin, O. 

Hoegh-Guldberg and F. Bairlein. 2002. Ecological responses to recent climate change. 

Nature 416:389-395.

Weis, J.S. and P. Weis. 2001. Behavioral responses and interactions of three animals with an 

invasive marsh plant: a laboratory analysis. Biol. Invasions 2:305-314.

Weis, J.S., L. Windham and P. Weis. 2002. Growth, survival and metal content in marsh 

invertebrates fed diets of detritus from Spartina alterniflora and Phragmites australis from 

metal-polluted and clean sites. Wetlands Ecology and Management 10:71-84.

Windham, L, J.S. Weis and P. Weis. 2001. Patterns and processes of mercury release from leaves of 

two dominant salt marsh macrophytes, Phragmites australis and Spartina alterniflora. 

Estuaries 24: 787-795.

Windham, L. and L. Meyerson. 2003. Impacts of Phragmites australis expansions on nitrogen 

dynamics of tidal marshes. Estuaries 26: 452-464.

Windham, L., J.S. Weis and P. Weis. 2003. Uptake and distribution of metals in two dominant salt 

marsh macrophytes, Spartina alterniflora (cordgrass) and Phragmites australis (common 

reed). Estuarine and Coastal Shelf Science 56: 63-72.
43

Yuhas, C., J.M. Hartman and J.S. Weis. 2005. Benthic communities associated with Spartina 

alterniflora and Phragmites australis in the Hackensack Meadowlands of NJ. Urban 

Habitats 31: 158-191.
A-1

APPENDIX A: CHARGE TO THE SAB

Great Lakes Restoration Initiative Action Plan

Science Advisory Board Review

I. Scope of Review

Charge to the SAB panel reviewing the GLRI Action Plan

The SAB panel is charged with reviewing the Great Lakes Restoration Initiative’s (GLRI or Initiative) 

Action Plan. A separate scientific background paper was developed to provide the review panel with an 

overview of the key ecological problems in the Great Lakes, and help the panel navigate through the 

extensive literature, strategies, and plans that informed the GLRI Action Plan. The SAB panel is 

requested to use the scientific background paper (and other relevant documentation cited in the 

background paper) in the review of the Action Plan.

II. Introduction

In 2010, President Obama announced and Congress appropriated $475 million in new funding for the 

GLRI to protect and restore the chemical, biological, and physical integrity of the Great Lakes. The 

Great Lakes contain 20 percent of the world’s surface freshwater, accounting for 95 percent of the 

surface freshwater in the United States. The watershed includes two nations, eight U.S. States, two 

Canadian provinces, more than 40 tribes, and more than one-tenth of the U.S. population. Led by the 

United States Environmental Protection Agency (EPA), the GLRI targets some of the most serious 

threats to the Great Lakes including toxic substances and contaminated sediment, invasive species, nonpoint source pollution, and habitat degradation.

To guide the efforts of the GLRI, EPA and our Federal partners, through the Great Lakes Interagency 

Task Force (IATF)6

• Toxic Substances and Areas of Concern

chaired by EPA Administrator Lisa Jackson, developed a comprehensive multi-year 

Action Plan. The GLRI Action Plan identifies goals, objectives, measurable ecological targets, and 

specific actions for five major focus areas: 

• Invasive Species

• Nearshore Health and Nonpoint Source Pollution

• Habitat and Wildlife Protection and Restoration

• Accountability, Education, Monitoring, Evaluation, Communication and Partnerships

III.Directive for Review of the GLRI Action Plan

The Congressional Conference Report accompanying H.R. 29967

 6 The Great Lakes Interagency Task Force (IATF) brings together eleven U.S. cabinet and Federal agency heads to coordinate restoration of the Great Lakes. 

Created by Executive Order from President Bush on May 18, 2004, the IATF mission is to focus on environmental outcomes like cleaner water and 

sustainable fisheries, and target measurable results. The IATF helps coordinate GLRI implementation. 

further specifies the need for EPA to 

"engage an independent, scientific panel to review the scientific credibility of the Action Plan to 

optimize the likelihood of successful restoration at appropriate scales."

http://www.epa.gov/greatlakes/iatf/index.html 7 Public Law 111-88, the Department of the Interior, Environment, and Related Agencies Appropriations Act, 2010.
A-2

IV.Charge Questions on the overall structure of the GLRI Action Plan

Question 1 - As presented in the scientific background document, the goals, objectives, measures, and 

actions of the Action Plan are based on the best available scientific analysis of environmental challenges 

and are consistent with the multitude of strategic plans and governing structures for the Great Lakes. 

Since the Action Plan is an “action driver”, we are most interested in the SAB’s recommendations on the 

identified principal actions to achieve progress. Are the principal actions proposed in the Action Plan 

consistent with the actions and/or recommendations of the previous collaborative plans and strategies for 

the Great Lakes (e.g. Great Lakes Regional Collaboration Strategy) as identified in scientific 

background document and other information of which you are aware? Are there other actions that we 

should consider for inclusion in the Action Plan that will better achieve the goals of the Action Plan?

Question 2 – As presented in the scientific background document, we have developed and currently 

operate the Great Lakes Accountability System (GLAS)8 as the primary mechanism for collecting 

information to monitor and report on GLRI progress. GLAS is still a work-in-progress at this time and it 

is not ready for external review. However, given the scope of the Action Plan and the nature and types 

of projects funded under the GLRI, we are interested in the SAB’s recommendations on how best to 

track the progress and accountability for a large ecosystem restoration program. What critical 

environmental elements, endpoints, or other measures would you include to those identified in the 

Action Plan?

Question 3

V. Charge Questions on Toxic Substances and Areas of Concern

– Please comment on the overall scope and framework of the Action Plan and its ability to 

organize environmental issues in a way that directs restoration actions. Does the SAB have any specific 

recommendations on how to improve or clarify the Action Plan?

Question 4 – The presence, significance, and trends of many historically-regulated (or “legacy”) 

contaminants in the Great Lakes are well-documented. Through the Action Plan, we are working to fully 

implement and enhance existing programs to eliminate releases of many of these contaminants. For 

example, the GLRI is working to accelerate the rate of sediment remediation in Areas of Concern 

(AOCs) through the Great Lakes Legacy Act9 among other programs. Similarly, the Action Plan calls 

for initiating strategic pollution prevention and toxics reduction efforts to minimize releases and 

emissions of many of these same contaminants. Please comment on the Action Plan’s approach for 

addressing so-called “legacy” contaminants through sediment remediation and toxics reduction efforts. 

Please comment on whether the Action Plan addresses the reduction of “legacy” contaminants at all 

geographic scales sufficiently to restore the Great Lakes ecosystem. Are there other actions that we 

should consider?

Question 5

 8 Available online at http://glri.us/projects.html 9 Funding under the Great Lakes Legacy Act is now part of the GLRI. 

– The Action Plan also acknowledges the threats posed to the ecosystem by chemicals of 

emerging concern, such as flame retardants, surfactants, pharmaceuticals and personal care product 

constituents. To devise and implement effective control strategies, EPA and the other federal agencies 

are coordinating efforts to identify significant sources and impacts of new toxics to the Great Lakes 

ecosystem through robust surveillance and screening. Please comment on our approach for assessing and 

managing the risks posed by chemicals of emerging concern. Are there other actions or specific 

chemicals of emerging concern that we should consider?
A-3

VI.Charge Question on Invasive Species

Question 6

VII. Charge Question on Nearshore Health and Nonpoint Sources

– Invasive species have dramatically altered the Great Lakes ecosystem. New species 

continue to threaten the Great Lakes. The Action Plan identifies a set of actions intended to eliminate 

new introductions, control the spread, and minimize the risks of invasive species. EPA has initiated 

separate reviews for some of the principal actions in this focus area. Ballast water technology is being 

reviewed by a separate SAB panel. The Asian Carp activities are being addressed through the Asian 

Carp Control Strategy Framework that is being elevated to a program unto itself in coordination with 

GLRI. Therefore, we are asking the SAB’s for advice and recommendations on the remaining actions to 

address invasive species. What are the key scientific data needed in an early detection surveillance 

network to provide up-to-date critical information for evaluating rapid response options? Does the SAB 

have any recommendations on demonstrated preventative and control technologies that could be applied 

to invasive species in the Great Lakes? Are there other actions that we should consider?

Question 7 - The report State of the Great Lakes 2009 has documented that “phosphorus loads may be 

increasing after a long period of decrease, and that an increasing proportion of the phosphorus is an 

available, dissolved form.” The increased phosphorus loads along with other stressors are degrading 

nearshore water quality as evidenced by eutrophication, harmful algal blooms (e.g. Cladophora and 

Microscystis) and avian botulism. To address these problems, the Action Plan identified a set of 

principal actions to improve the health of the nearshore areas and reduce nonpoint source pollution to 

levels that do not impair nearshore waters of the Great Lakes. These principal actions include identifying 

sources and reducing loadings of nutrients and soil erosion and targeting watershed plan implementation 

in high priority watersheds. Please comment on the adequacy of the principal actions to address the 

impacts associated with nearshore soluble reactive phosphorus, Cladophora biomass, and dreissenid 

biomass. Are there other actions that we should consider? Please comment on the Action Plan’s intent to 

target Great Lakes subwatersheds10

VIII. Charge Questions on Habitat and Wildlife Protection and Restoration

that show severe signs of stress for focused restoration activities as 

opposed to a broader approach that targets all watersheds (stressed and currently unstressed). 

Question 8 – One of the Action Plan’s principal actions to protect and restore habitat and wildlife is 

aimed at improving “aquatic ecosystem resiliency”. “Resiliency” is loosely defined in the Action Plan as 

providing an ecosystem with the capability to buffer the impacts of potential problems such as climate 

change. Please comment on the concept of “resiliency” in restoring and protecting aquatic habitats in the 

Great Lakes ecosystem. Does the SAB have any recommendations on actions to increase “resiliency”? 

Are there additional ecological elements or measures that should be considered to better improve 

resiliency or buffering capacity and our progress in habitat restoration and ecosystem protection 

projects? What about actions in the other focus areas?

Question 9

IX.Charge Question on Accountability, Education, Monitoring, Evaluation, Communication, 

and Partnerships

– The Action Plan broadly defines “restoration” to encompass physical, biological, and 

chemical functions and processes. Are the actions listed in the Action Plan “restoration” actions?

 10 These include the targeted geographic watersheds identified on pages 16 and 28 of the Action Plan and other Areas of Concern
A-4

Question 10 – Focus Area 5: Accountability, Education, Monitoring, Evaluation, Communication, and 

Partnerships, is intended to provide the “necessary backbone” of the entire GLRI through oversight, 

monitoring and assessment, education and outreach, and partnerships. This focus area is intended to 

implement assessment and evaluation actions to address gaps in knowledge and an inadequate 

understanding of complex and emerging issues. Does the SAB have any recommendations of critical 

data gaps for which programs or tools should be implemented in the other focus areas? Please comment 

on the Action Plan’s approach for enhancing coordination and collaboration among Great Lakes partners 

to address key scientific issues.

Question 11 - Outreach and education are crucial in the effort to restore the Great Lakes. The Action 

Plan identifies the need to educate future generations to extend restore efforts. Please comment on the 

Action Plan’s approach to incorporate Great Lakes stewardship into environmental education curricula.
B-1

APPENDIX B: CONSIDERATIONS FOR AN ECOSYSTEM 

RESTORATION PROGRAM 

The SAB recognizes and acknowledges the unprecedented scale of the GLRI. It bounds on 

intractable in terms of size and complexity. For these reasons, the SAB recommends that specific 

actions that are implemented have at least a moderate probability of working at a scale and in 

locations where they have the potential greatest positive impact on the ecosystem. In order to 

determine the specific action potential to succeed at an appropriate scale the SAB provides 

considerations across the definition, implementation and evaluation steps of the Action Plan that 

are intended to stimulate discussion by the participating agencies as actions or projects are 

solicited, implemented, and evaluated. These considerations include a systematic approach to 

evaluating actions, locations, and uncertainties relative to the goals for the program. 

Defining Restoration Goals

• What is wrong, where and why? Answering this question is fundamental to developing a 

plan. The SAB assumes that answers are reasonably well developed, but it was not 

apparent in the review of the Action Plan and Scientific background documents, whether 

this was the case. 

• At what scale are damages and stressors active, and potentially limiting restoration? This 

comment is related to responses provided to the questions above and involves a more in 

depth investigation of problems in the ecosystem. 

• What are the specific characteristics of a “restored” Great Lakes ecosystem? Program 

objectives that clearly articulate the desired future condition for the ecosystem should be 

developed. The National Research Council (1992) defined “restoration of aquatic 

ecosystems” as returning an ecosystem to a close approximation of what it was like prior 

to disturbance by humans. This goal may not be appropriate for the Great Lakes given 

their current condition. However, the Action Plan does not specifically define a set of 

goals. The scientific literature on restoration has developed some generic restoration 

goals, that are provided below. The SAB encourages EPA to review the generic goals and 

identify and define goals for the GLRI. It is likely that the restoration goals for the Great 

Lakes will vary spatially, include elements for most of the broad strategies below and 

should be fully developed specific to the GRLI . An overarching set of program goals 

will greatly help in setting priorities for restoration projects (Thom et al. 2010). 

o Restore to prehistoric conditions – conditions before man was present.

o Restore to historic conditions – man was present but had a minimal impact on natural 

ecosystems.

o Enhance selected attributes – improve conditions of habitat and landscapes by 

enhancing ecological attributes of the systems.

o Conserve biodiversity – some disturbance can be present but the native biodiversity is 

intact.

o Protection – all human-related disturbances and stressors are barred from the system. 

Protection differs from restoration in that there is no net gain associated from 

protection alone. However, protection of areas of the ecosystem can support other 

restoration projects through supplying materials and species to restored sites, and by 

preventing future habitat loss.

o Habitat creation – Constructing a habitat that is different than what existed 

historically or pre-historically in an area. In cases where there are considerable levels 

of disturbance on the landscape and site scales, creation may be the only viable 
B-2

option. In general, maintenance of created habitats requires expenditures of energy 

and funds because the processes that would normally maintain them are not present or 

are poorly developed.

• How sure are predictions of the response of the ecosystem and populations to specific 

actions? There is a need to specify the uncertainties associated with the goals. In the long 

run, identifying key uncertainties will aid in developing directed research questions that 

will help guide the restoration program in the future.

Prioritizing Actions

What are specific links between actions and goals? This element needs clarification, and more 

specific information because it helps develop more robust restoration plans that clearly target 

specific actions.

The process that will be used to determine what actions need to be accomplished and where

those actions should be deployed was not clearly explained in the Action Plan. The SAB 

expressed concerned about the lack of detail as to how projects would be prioritized and suggests 

the following recommendations for the agency to consider:

• Define and identify priority areas of the ecosystem where actions would have the greatest 

benefit. This analysis forms the foundation of a comprehensive restoration plan that 

identifies best actions and best locations.

• As opportunities arise, these opportunities can be assessed against the comprehensive 

plan maps to determine if actions are high priority. 

• Clearly articulate the restoration strategy that will be deployed in each action.

• Develop a set of case studies for each of the types of restoration actions that will be 

implemented to develop some understanding of effectiveness. This understanding will 

help design subsequent projects.

• Clearly define elements and criteria of prioritization process such as, 

o Habitat forming processes

o Landscape features

o Site condition

o Adjacent site conditions

o Self-maintenance

o Resilience potential 

o Time frame for development toward goal.

• Develop a Project Proposal Template that articulates goals, performance metrics. The 

template should address project criteria, location, size, time period to attain goal, 

effectiveness monitoring, uncertainties, and direct relationship to prioritization criteria.

Measuring Progress Toward Goals

• Develop a transparent method and set of metrics to measure net ecosystem improvement 

that is sustained by building resilient systems. Some methods and attributes for doing this 

include sources and levels of evidence, detectable metrics in the broader ecosystem, and 

quantification of cumulative effects of multiple actions.

• Formalize an integrated adaptive management program with the following elementso Clearly articulate the goal - everything hinges on a clear and explicit statement of 

what the program seeks to accomplish.
B-3

o Develop a system-level model for goal attainment - identify all factors (natural 

and anthropogenic) that could potentially affect goal attainment and rank their 

relative importance.

o Assess the current management efforts - which will identify gaps and/or/overlaps 

in existing management programs addressing the important factors affecting goal 

attainment.

o Develop management strategy - through coordination and implementation 

planning by stakeholders.

o Develop monitoring program(s)- monitoring can only be designed after the goals 

and management strategy are determined. Assessing management performance is 

the first priority to support adaptive management.

o Assess performance - the criteria for success/failure of management efforts should 

be known when the strategy is developed and the monitoring program is designed. 

This analysis informs adaptation and involves defining uncertainties around 

intermediate targets and establishes decision thresholds that trigger a change in 

management actions.

o Manage adaptively - based on the monitoring assessment, the system-level model 

for goal attainment is amended and monitoring strategies revised to improve 

performance. (Hershner 2011)

Products and Tools for the GLRI

Outcomes from an effective adaptive management approach may include:

• Report cards 

• Model runs to predict outcomes of future actions based on what has been learned 

• Recommendations for improvements and research to reduce uncertainty of actions 

• Annual report that summarizes progress and provides recommendations, defines the 

decision process, and develops action recommendations

References:

Hershner, C. 2011. Enabling effective adaptive management in the Chesapeake Bay Program. 

Http://archive.chesapeakebay.net/pubs/calendar/55106_03-03-11_Handout_3_11186.pdf.

(Accessed 9/29/2011).

National Research Council. 1992. Restoration of Aquatic Ecosystems : Science, Technology, and 

Public Policy. National Academy Press. Washington, D.C.

Thom, R.M., H.L. Diefenderfer, J.E. Adkins, C. Judd, M.G. Anderson, K.B. Buenau, A.B. Borde 

and G.E. Johnson. 2010. Guidelines, processes and tools for coastal ecosystem 

restoration, with examples from the United States. Plankton and Benthos Res. 5 (suppl.) 

185-201.