Great Lakes Restoration Initiative: Further Actions Would Result in More Useful Assessments and Help Address Factors That Limit Progress
Released: 2013-11-08T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: The Great Lakes contain about 84 percent of North America's surface freshwater and provide economic and recreational benefits in the Great Lakes Basin. However, the Great Lakes face significant stresses--such as toxic pollution--that have caused ecological and economic damage to the region.

Approximately $1.3 billion has been appropriated to the GLRI, created in fiscal year 2010, which an interagency Task Force of 11 federal agencies, chaired by the EPA Administrator, oversees. In 2010, the Task Force issued an Action Plan for fiscal years 2010 to 2014 to develop a comprehensive approach to restoring the health of the Great Lakes ecosystem. GAO was asked to review the GLRI. This report examines (1) how the GLRI is implemented by the Task Force agencies and other stakeholders, (2) the methods that EPA has in place to assess GLRI progress, (3) the progress identified by the Task Force agencies and nonfederal stakeholders, and (4) the views of nonfederal stakeholders on factors, if any, that may affect or limit GLRI progress. GAO analyzed the Action Plan, surveyed 205 non-federal recipients of GLRI funding, and interviewed Task Force agency officials and nonfederal stakeholders.

section_title: What GAO Found
paragraphs: The Task Force agencies use the Action Plan to implement the Great Lakes Restoration Initiative (GLRI) and use an interagency process to enter into agreements among themselves to identify GLRI projects and with other stakeholders to implement GLRI projects. The Action Plan includes guidance for implementing the GLRI in five focus areas (such as invasive species and habitat and wildlife protection and restoration) that encompass the most significant environmental problems in the Great Lakes. Each focus area includes, among other things, long-term goals, objectives to be achieved by fiscal year 2014, and 28 measures of progress that have annual targets for fiscal years 2010 to 2014.

EPA uses the Action Plan's measures to assess GLRI progress. However, its methods may not produce comprehensive and useful assessments of GLRI progress for several reasons. Among them, some of the goals and objectives do not link to any measures and, as a result, it is unclear how EPA will be able to assess progress toward them. In addition, some measures track actions that may not lead to the desired GLRI goal. For example, one measure tracks the reduction in concentrations of polychlorinated biphenyls (PCB) in fish as part of the goal to lift all restrictions on consumption of Great Lakes fish. However, stakeholders reported that the measure is too narrow and that mercury and other contaminants need to be addressed as well. Consequently, reducing PCB concentrations in fish is not likely to lead to the desired result of lifting all Great Lakes fish consumption restrictions. Without useful measures, EPA may not be able to determine that GLRI efforts are producing the desired results.

In spring 2013, the Task Force agencies issued two reports about GLRI progress in fiscal years 2010 and 2011, which state whether the targets for the Action Plan's 28 measures were being met (e.g., 15 of 28 measures met or exceeded in fiscal year 2011), but the reports include few specific examples of progress. As a result, GAO sought further insights into such progress by surveying nonfederal GLRI stakeholders. Overall, 87 percent of respondents cited at least one example of how one or more of their projects had, or was expected to, benefit the Great Lakes ecosystem. GAO and others have reported that quantifying overall Great Lakes restoration progress is difficult, that the environmental conditions of each lake are unique, and, according to a 2006 U.N. report, it is often impossible to attribute specific environmental changes to specific projects or programs.

In response to GAO's survey, among the factors respondents most often cited as potentially limiting GLRI progress are several outside the scope of the Action Plan, such as inadequate infrastructure for wastewater or stormwater and the effects of climate change. These factors could negatively affect GLRI restoration efforts. For example, as a result of climate change, warming water temperatures can lead to increased numbers of aquatic invasive species and a decline in native ones, a GLRI focus area. The Action Plan touches on these factors but does not state how they will be addressed. In 2012, EPA took steps to incorporate climate change considerations into a small number of GLRI projects but has yet to decide if the GLRI will consider climate change impacts on all GLRI projects. Without addressing these factors in the next Action Plan, EPA will not be able to more fully account for their impacts on GLRI restoration efforts.

section_title: Letter
paragraphs: The Great Lakes form the largest system of freshwater on earth. They  contain about 84 percent of North America’s surface freshwater and are  shared by eight U.S. states—Illinois, Indiana, Michigan, Minnesota, New  York, Ohio, Pennsylvania, and Wisconsin—the Canadian province of  Ontario, and more than 40 tribes. The Great Lakes provide a variety of  recreational, environmental, and economic benefits, including drinking  water, fishing, swimming, boating, agriculture, industry, and shipping, for  the more than 30 million people who reside in the Great Lakes Basin,  which includes the five Great Lakes and the large land area that extends  beyond the lakes, including their watersheds, tributaries, and connecting  channels. In addition, a 2011 Michigan Sea Grant study estimated that  1.5 million jobs in the United States were directly connected to the Great  Lakes and generated $62 billion in wages in 2009.

However, the Great Lakes face significant environmental and public  health stresses that continue to threaten their future. For example,  advisories that warn against the consumption of certain fish species have  been issued for each of the Great Lakes states due to their levels of  persistent toxic substances, such as mercury. Decades of industrial  activity in the region have left a legacy of contamination, such as from  polychlorinated biphenyls (PCB), that resulted in the United States and  Canada identifying, since 1987, a list of 43 severely degraded locations in  the Great Lakes Basin as areas of concern; 26 of these areas of concern  are located wholly in the United States, and 5 are shared between the two  nations. In addition, more than 180 nonnative or “invasive” aquatic  species have become established in the Great Lakes. Some invasive  species have caused extensive ecological and economic damage to the  Great Lakes. The zebra mussel, for example, outcompetes native species  for resources by removing live animals and algae that other fish eat from  water bodies, and it blocks pipes that deliver drinking water to cities and  cooling water to power plants. The Fish and Wildlife Service has  estimated a potential economic impact of $5 billion from 2000 to 2010  within the Great Lakes Basin alone. The discovery of Asian carp near  waterways connected to the lakes threatens to increase this problem.

Pub. L. No. 111-88, 123 Stat. 2904, 2938 (2009). For additional information on the Great  Lakes Initiative, see GAO, Great Lakes Initiative: EPA Needs to Better Ensure the  Complete and Consistent Implementation of Water Quality Standards, GAO-05-829  (Washington, D.C.: July 27, 2005).

GLRI. Nearly $300 million was appropriated in both fiscal years 2011 and  2012 for the GLRI and, according to EPA, about $284 million in fiscal year  2013, for a total of approximately $1.3 billion since fiscal year 2010.

The Great Lakes Interagency Task Force (Task Force)—created in May  2004 by Executive Order 13340—oversees the GLRI.  The Task Force is  chaired by the EPA Administrator, and it includes senior officials from the  U.S. Departments of Agriculture, Commerce, Defense, Health and  Human Services, Homeland Security, Housing and Urban Development,  the Interior, State, and Transportation and the White House Council on  Environmental Quality. The GLRI is implemented by EPA’s Great Lakes  National Program Office in conjunction with subagencies within the 11  Task Force agencies. EPA and the other Task Force agencies issued  the Great Lakes Restoration Initiative Action Plan Fiscal Years 2010-2014  (Action Plan) in February 2010. In addition, EPA created the Great Lakes  Accountability System (GLAS) as a mechanism for collecting information  to monitor GLRI projects and progress.

Both our work and that of EPA’s Office of the Inspector General have  documented concerns about Great Lakes restoration efforts in the past.  For example, we reported in May 2002 that the pace of cleaning up the  Great Lakes and restoring areas of concern was slower than anticipated  by the United States and Canada. In September 2004, we found that  EPA monitoring efforts did not provide comprehensive information on the  condition of the Great Lakes and that monitoring by other federal and  state agencies yielded information that that did not cover all areas related  to the condition of the Great Lakes or the entire Great Lakes Basin. In  September 2009, EPA’s Office of the Inspector General reported that  EPA had not developed an effective management framework to clean up  contaminated sediments in the Great Lakes areas of concern.

In light of these past issues and the significant federal funds targeted  toward addressing Great Lakes issues, you asked us to review the GLRI.  This report examines (1) how the GLRI is implemented by the Task Force  agencies and other stakeholders; (2) the methods that EPA has in place  to assess GLRI progress; (3) the progress identified by the Task Force  agencies and nonfederal stakeholders; and (4) the views of nonfederal  stakeholders on factors, if any, that may affect or limit GLRI progress.

To examine how Task Force agencies and other stakeholders implement  the GLRI and identify methods that EPA has in place to assess GLRI  progress, we analyzed key documents including the Action Plan, EPA’s  GLRI financial reports, and information about GLRI projects from GLAS.  In addition, we interviewed federal stakeholders—officials from each Task  Force agency and relevant subagencies responsible for implementing the  GLRI—and nonfederal stakeholders; specifically, representatives from  state and local governments, tribes, nongovernmental organizations— such as the Nature Conservancy and the Great Lakes Indian Fish and  Wildlife Commission—and academic institutions that that have received  GLRI funds to gain an understanding of the GLRI and how it is  implemented.Great Lakes interest group, the Healing Our Waters – Great Lakes  Coalition, that has not received GLRI funds. We visited GLRI projects,  and attended the Eighth Annual Great Lakes Restoration Conference in  Cleveland in September 2012. In addition, we interviewed a  nonprobability sample of 21 individuals with expertise in Great Lakes’  subject matter to obtain their views about the Action Plan and Great  Lakes restoration. The 21 subject matter experts who participated in  these interviews included officials from state agencies, members of  academia, and nongovernmental organizations. We selected these  experts in part through recommendations made by nonfederal attendees  at the Great Lakes Restoration Conference. Because we used a  nonprobability sample, the information obtained from these interviews is  not generalizable to other individuals with Great Lakes-related expertise  but provides illustrative information.

We also interviewed representatives from a prominent  To examine the progress identified by the Task Force agencies and  nonfederal stakeholders and the views of nonfederal stakeholders on  factors, if any, that may affect or limit GLRI progress, we reviewed key  documents detailing Great Lakes restoration efforts. We also  administered a web-based survey to each of the 205 nonfederal  stakeholders that, as of October 2012, had received GLRI funds from a  Task Force agency and had a project identified in GLAS. We conducted  this survey to identify examples of GLRI progress and obtain stakeholder  views on factors that might limit progress. Of the 205 stakeholders  contacted, 176 completed the survey, for an overall response rate of 86  percent. We also asked the 21 subject matter experts we interviewed to  provide their views about factors that may limit GLRI progress. Appendix I  presents a more detailed description of our objectives, scope, and  methodology.

We conducted this performance audit from June 2012 to September 2013  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The Great Lakes Basin spans more than 750 miles from east to west and,  as shown in figure 1, encompasses nearly all of Michigan, and parts of  Illinois, Indiana, Minnesota, New York, Ohio, Pennsylvania, Wisconsin,  and Ontario, Canada. The U.S. shoreline along the five Great Lakes— Erie, Huron, Michigan, Ontario, and Superior—is approximately 4,530  miles long, which is more than 2,000 miles longer than the U.S. coastline  on the Atlantic Ocean.

Numerous stresses threaten the health of the lakes themselves and the  adjacent land within the Great Lakes Basin. For example, Asian carp  threaten commercial and recreational fisheries in the Great Lakes  because they tend to outcompete native fish for resources and modify  habitat. In addition, despite progress in reducing the amount of  phosphorus in the lakes achieved through mitigation techniques  implemented in the 1970s, harmful algal blooms are once again  threatening the Great Lakes Basin.

The United States has taken several steps to restore the health of the  Great Lakes ecosystem during the last four decades. Examples are as  follows:  In 1972, the United States and Canada signed the first binational  Great Lakes Water Quality Agreement with the goal of restoring and  maintaining the chemical, physical, and biological integrity of the  Great Lakes Basin. The parties signed another Great Lakes Water  Quality Agreement in 1978 that was amended in 1983, 1987, and in  2012. The 1987 amendment resulted in the formal identification of  specific areas of concern, which were defined as geographic areas  where a change in the chemical, physical, or biological integrity of the  area is sufficient to cause restrictions on fish and wildlife or drinking  water consumption, or the loss of fish and wildlife habitat, among  other conditions, or impair the area’s ability to support aquatic life.  The 2012 amendment contains provisions for addressing the  nearshore environment,  aquatic invasive species, habitat  degradation, and the effects of climate change, among other things.

In 2002, the Great Lakes Legacy Act authorized EPA to, among other  things, carry out sediment remediation projects and to conduct  sediment contamination remediation research in areas of concern in  the Great Lakes.

In 2004, the Task Force agencies collaborated with Great Lakes  governors, mayors, tribes, and nongovernmental organizations in an  effort referred to as the Great Lakes Regional Collaboration, which led  to the development in 2005 of the Great Lakes Regional Collaboration  Strategy to Restore and Protect the Great Lakes. More than 1,500  individuals participated in this effort. A 2007 Brookings Institution  report estimated that the $26 billion dollar investment necessary to  implement this strategy would have resulted in $30 to $50 billion in  short-term benefits to the regional economy and at least $50 billion in  the long term.

H. R. Rep. No. 111-316, at 110-11 (2009). adaptive management framework for the GLRI and noted that EPA  should consider potential impacts of climate change on restoration.

In March 2013, the Chair of the Council on Environmental Quality  announced that the administration is committing to another 5-year GLRI  Action Plan, for fiscal years 2015 to 2019. In May 2013, EPA and the  Task Force agencies began conducting public meetings and webinars to  obtain comments on how the Action Plan could be refined to increase the  effectiveness of GLRI investments during the next phase of the Action  Plan.

section_title: Task Force Agencies Use the Action Plan and Agreements among Themselves and with Nonfederal Stakeholders to Implement the GLRI
paragraphs: The Task Force agencies use the Action Plan to guide implementation of  the GLRI. They also use an interagency process to identify and transfer  funds to GLRI work, and to enter into agreements among themselves and  with nonfederal stakeholders to identify and implement GLRI projects, or  they do the work themselves.
subsections: section_title: Task Force Agencies Use the Action Plan to Implement the GLRI
paragraphs: The Task Force agencies use the Action Plan to guide implementation of  the GLRI. The Action Plan is organized into five focus areas that,  according to the Task Force agencies, encompass the most significant  environmental problems in the Great Lakes: (1) toxic substances and  areas of concern; (2) invasive species; (3) nearshore health and nonpoint  source pollution; (4) habitat and wildlife protection and restoration; and (5)  accountability, education, monitoring, evaluation, communication, and  partnerships. Table 1 describes each focus area.

Each focus area includes a description of its stresses and several long- term goals to address them. For example, one long-term goal in the  invasive species focus area is to eliminate the introduction of new  invasive species to the Great Lakes Basin. In addition, each focus area  includes a number of objectives to be completed within the 5-year period  covered by the Action Plan. For example, in the habitat and wildlife  protection and restoration focus area, one objective is to assess 100  percent of U.S. coastal wetlands in the Great Lakes Basin by 2014.

The focus areas also include measures of progress—28 in total—each of  which has annual targets for fiscal years 2010 to 2014 that are designed  to ensure that efforts are on track to meet the long-term goals. Some of  the measures address environmental conditions. For example, one  measure for the habitat and wildlife protection and restoration focus area  addresses the number of fish passage barriers that are to be removed or  bypassed annually for the period of time covered by the Action Plan. The  annual targets for the measure are the removal or bypassing of 100  barriers in 2010, 150 in 2011, 250 in 2012, 350 in 2013, and 450 barriers  in 2014.

The last part of each focus area is the principal actions, broad statements  of the most significant activities that EPA and its federal partners  conclude need to be done in order to achieve the goals, objectives, and  targets in the Action Plan. For example, a principal action for the invasive  species focus area is to promote the development and use of new control  technologies, including biological control methods, that will significantly  reduce the cost or increase the effectiveness of invasive species control  measures.

See appendix VI for a complete list of the Action Plan long-term goals,  objectives, and measures of progress.

section_title: Task Force Agencies Use Interagency Process to Identify and Fund GLRI Work
paragraphs: The Task Force agencies identify the GLRI projects they plan to  implement through an interagency process. EPA and the other Task  Force agencies then enter into interagency agreements that describe the  scope of the GLRI work that is to be undertaken and the amount of GLRI  funds EPA will transfer to the Task Force agency doing that work.

The Task Force agencies and nonfederal stakeholders have started more  than 1,450 GLRI projects since the program began. GLRI projects can  range in size from 0.25 acres for a fish spawning project to 10 million  acres for a project to update habitat and wetland maps to identify  sensitive and restorable wetlands across the basin. These projects may  take place in one location or across multiple states within the Great Lakes  Basin. GLRI projects have also ranged in cost from $3,000 to protect  nesting piping plovers to $60.5 million to address contaminated sediment  in multiple areas of concern.complete and, as a result, many projects funded in fiscal years 2010 to  2012 are still under way. For example, approximately 64 percent of the  fiscal year 2010 to 2012 projects reported in GLAS were at least half  completed as of May 2013. Tables 2 and 3 show the number of projects   Many GLRI projects take several years to  funded by Task Force agency and by focus area as of May 2013,  respectively.

Although we did not break down GLRI funding per project in detail, some  Task Force agency officials told us that they use a small percentage of  that funding for administrative tasks. For example, officials from one Task  Force agency told us that they used 5 percent of GLRI funds for one  agency project for overhead and indirect costs. In this case, the agency  performs laboratory and monitoring work that the nonfederal stakeholders  that implement the project do not have the capacity to do. As shown in  figures 2 and 3, most GLRI funding has been utilized by EPA, the  Department of the Interior’s Fish and Wildlife Service, and the U.S. Army  Corps of Engineers, and focus area one—toxic substances and areas of  concern—has received more GLRI funding than the other focus areas in  each of the past 4 years.

EPA and the Task Force agencies have 2 years to obligate GLRI funds,  which means that the amounts allocated in fiscal years 2010 and 2011  are not likely to change, but fiscal year 2012 and 2013 amounts may  change as the period for obligating those funds comes to an end. In  addition, while nearly all of the GLRI appropriations from fiscal years 2010  to 2012 have been obligated, not all of those obligations have been  outlayed because many GLRI projects take several years to complete.Table 4 shows the extent to which GLRI appropriations for fiscal years  2010 to 2012 have been obligated and outlayed as of July 2013.

After EPA and the Task Force agencies have agreed to the GLRI fund  transfers to each agency and the work that will be done, each agency  either does the work itself or implements it through mechanisms such as  cooperative agreements, contracts, or grants with nonfederal  stakeholders. In the case of GLRI grants, a Task Force agency  announces the availability of the grants through a request for application  process. For example, EPA announced on April 19, 2012, that the agency  planned to award approximately $20 million for about 100 projects in four  of the five focus areas, and that the applications were due on May 24,  2012. The request for application document included the amount of  money and number of grants that would be awarded in each focus area  and grant eligibility information, among other things. Similar  announcements were made by other Task Force agencies for their GLRI  grants, and EPA issued its first request for applications for fiscal year  2013 projects in July 2013.

section_title: EPA’s Methods to Assess GLRI Progress May Not Produce Comprehensive and Useful Assessments or Support Program Adjustments
paragraphs: Although EPA uses information from GLAS and a variety of other sources  to assess GLRI progress in meeting the annual targets associated with  each of the 28 measures of progress in the Action Plan to assess GLRI  progress, this information may not produce sufficiently comprehensive or  useful assessments or support program adjustments. Specifically, (1) the  Action Plan measures of progress currently in place may not provide  sufficiently comprehensive or useful information and (2) EPA and the  Task Force agencies have not fully established a plan to guide an  adaptive management process for the GLRI that could allow them to  assess the effectiveness of GLRI actions and, if needed, adjust their  efforts.
subsections: section_title: EPA Uses the Action Plan Measures to Assess GLRI Progress
paragraphs: EPA assesses GLRI progress primarily by evaluating performance toward  meeting the annual targets for the 28 measures of progress in the Action  Plan, which EPA officials said are intended as indicators of success for  each focus area. Of the 28 measures, 15 are also used in the agency’s  performance plan and performance report, which are required by the  Government Performance and Results Act of 1993 (GPRA) as  amended.consultation with the Office of Management and Budget, a limited set of  measures that could be used to evaluate GLRI progress on an annual   According to EPA officials, the agency sought to develop, in  basis. EPA officials said that, in developing the set of measures, they  considered such factors as the availability of relevant data, the suitability  of the data for measuring year-to-year changes, a focus on environmental  outcomes, and the existing federal authorities available to address the  measure. Officials from EPA and another Task Force agency also told us  that many of the measures were based on existing baseline information  and were practical because they used existing agency databases for  information.

To gauge GLRI progress toward meeting the targets for the measures,  EPA obtains the data needed using information from GLAS, EPA  programs, other federal agencies, states, and universities. For example,  for 7 of the 28 measures of progress, GLAS provides progress data  specific to individual GLRI projects. In addition, states provide information  on progress at areas of concern, the National Oceanic and Atmospheric  Administration provides progress information from a database it manages  on invasive species in the Great Lakes, and the Fish and Wildlife Service  provides progress information related to habitat and wildlife protection  and restoration. In March 2013, the Task Force agencies issued the first  GLRI progress report to Congress, which identified fiscal year 2011  progress using the measures for each focus area and described the  accomplishments of some projects. The Task Force agencies also  issued a report on fiscal year 2010 progress in April 2013.

section_title: Action Plan Measures of Progress May Not Provide Sufficiently Comprehensive or Useful Information
paragraphs: Assessments of GLRI progress could help GLRI stakeholders, Congress,  and the public discern the extent to which the health of the Great Lakes  ecosystem has been restored, as well as what has been achieved by the  approximately $1.3 billion appropriated to the program since fiscal year  2010. However, the Action Plan measures of progress may not provide  sufficiently comprehensive or useful information on GLRI progress  because (1) some goals and objectives do not link to any measures that  will allow EPA to assess progress toward achieving them; (2) the  measures do not capture the results of many of the GLRI projects; (3)  data used to evaluate some measures of progress may not be complete;  and (4) some Task Force and state agency officials, subject matter  experts, and EPA’s Science Advisory Board raised concerns about the  usefulness of some measures or their targets for indicating progress  toward the GLRI goals and objectives.

The Action Plan does not identify the links between a focus area’s goals,  objectives, and measures. Specifically, based on our analysis of the GLRI  Action Plan, some of the goals and objectives in the Action Plan do not  link to any measures of progress, which EPA uses to assess GLRI  progress. For example, one of the goals of the habitat and wildlife  protection and restoration focus area is that development activities are  planned and implemented in ways that are sensitive to environmental  considerations and compatible with fish and wildlife and their habitats.  However, we found that none of the six objectives and nine measures of  progress in this focus area link to this goal. Similarly, in its 2012 review of  the GLRI Action Plan, EPA’s Science Advisory Board commented on the  ambiguity in the links between the elements of the plan, such as between  the long-term goals and the objectives. The Science Advisory Board also  recommended that the Action Plan tie the measures more directly to the  goals, noting that the more clear and transparent the connection between  the measures and the goals, the easier it will be to document how well the  actions are working to meet the goals.

EPA officials told us that the Action Plan was not intended to contain  direct linkages between every goal, objective, and measure but rather  that the measures were to serve as key indicators of success for each  focus area. They said that the rationale for that decision was to provide  some flexibility, recognizing that not all important restoration work may fall  within the measures of progress and that the Action Plan does not  represent the entirety of actions necessary for Great Lakes protection and  restoration. However, based on our review of documents on planning for  restoration of natural resources, we believe that clear linkages between a  plan’s goals, objectives, and measures are critical to achieving and  assessing progress over time. For example, the National Research  Council recommended such linkages in its checklist for planning and  evaluating aquatic ecosystem restoration. Specifically, the National  Research Council recommended constructing specific performance  indicators that are directly and appropriately linked to each objective,  noting that these performance indicators are specific, measureable  quantities that reveal to what extent the objectives are being achieved.  In addition, the Department of the Interior’s 2009 technical guidance on  managing natural resources emphasizes that, to be useful for decision  making and evaluation, objectives need to be unambiguous, with specific  metrics and specific target conditions.

We recognize that it may not always be feasible or appropriate to identify  measures for every aspect of each goal or objective. Nonetheless,  although some objectives in the Action Plan describe quantifiable actions,  the Action Plan contains no measures of progress for them. For example,  two Action Plan objectives for the nearshore health and nonpoint source  pollution focus area state that, by 2014, (1) 50 percent of high priority  Great Lakes beaches will have been assessed using a standardized  sanitary survey tool to identify sources of contamination and (2) rapid  testing or predictive modeling methods (i.e., to improve the accuracy of  decisions on beach postings to better protect public health) will be  employed at 33 percent of high-priority beaches. However, because the  Action Plan contains no measures of progress that link to these  objectives, it is unclear how EPA will be able to assess annual progress  toward these and other objectives that do not have linked measures. EPA  officials told us that they recognize the need to report a more  comprehensive assessment of objectives and are considering options for  evaluating and reporting on them.

Many of the projects funded by the GLRI do not have an Action Plan  measure of progress assigned to them, which means that the results of  those projects are not captured by the measures. Specifically, nearly 60  percent of the more than 1,450 GLRI projects reported in GLAS as of May  2013 did not have an associated Action Plan measure of progress. One  reason for this is that, according to a Task Force agency, some projects  contribute to the Action Plan measures but are not the type of on-the- ground restoration projects that are addressed by most of the measures  of progress. Officials from the U.S. Geological Survey told us that this is  the case for much of their agency’s GLRI work. For example, the  agency’s work has included efforts to develop new methods of controlling  phragmites, an invasive plant. This work contributes toward the Action  Plan’s objective of developing or refining and pilot testing five  technologies to contain or control invasive species by 2014. However,  there is no linked measure of progress for this objective or assigned to  the project. As a result, EPA’s progress assessments may inaccurately  capture the extent of progress being made toward containing or  controlling invasive species.

According to EPA officials, projects without assigned measures address  the Action Plan goals, objectives, or principal actions; the reason these  projects do not have measures assigned to them is that they do not  directly provide data for any of the Action Plan’s 28 measures. They told  us that they monitor the results of individual projects through standard  agency practices, but that they are not currently tracking cumulative  results that are not addressed by an Action Plan measure of progress.  According to agency officials, future GLRI progress assessments may  capture more information. Specifically, they said that the cumulative  results of some of the projects without assigned measures of progress  may ultimately be captured by some of the existing measures. We  recognize that this may be the case for some projects. For example,  projects to restore native fish habitat that do not have assigned measures  of progress could help lead to progress over time toward the measure  that addresses the percentage of native aquatic species populations that  are self-sustaining in the wild. However, a cumulative approach may not  allow EPA to capture specific progress information from those projects  without measures, and EPA uses the measures to assess GLRI progress  and has been directed to report on that progress annually. As we reported  in November 2002, one attribute of successful performance assessment  is that there should be enough measures to ensure that an agency has  the information it needs about project performance. Without methods to  include the results of such projects, EPA cannot ensure that the agency is  assessing the full extent of progress being made.

Data used to evaluate some measures of progress may not be complete  because GLAS users are limited to reporting progress using a single  measure, and GLRI projects may directly address multiple measures  across different focus areas. We found that 7 of the 28 measures of  progress are tracked primarily in GLAS and, as we noted previously, EPA  uses information from GLAS, as well as other sources, to gauge GLRI  progress toward meeting the targets for the measures. Officials from five  Task Force agencies told us that this is a significant limitation that can  result in underreporting of progress. For example, a National Park Service  GLRI project has involved managing acres for invasive species, which is  one measure, as well as outreach to the public on practices that prevent  the introduction and spread of invasive species, which is another  measure. However, GLAS requires the agency to choose only one of  these measures for reporting progress. EPA officials told us that GLAS  users are restricted to reporting on a single measure due primarily to a  decision by EPA to simplify the reporting process during the initial stages  of the GLRI. Agency officials said that this decision was made for several  reasons, including concerns about double-counting and overreporting, a  desire to minimize the reporting burden for GLAS users and EPA, and the  need to ensure appropriate data quality review before making the  progress information public. They said that the current design of GLAS  reflects this decision and that system modifications would be necessary to  allow reporting on multiple measures. However, by limiting users to  reporting information on only a single measure for each project, GLAS  prevents EPA from collecting complete progress information on GLRI  projects—that is, information on each of the measures addressed by  GLRI projects. As we noted previously, there should be enough measures  to ensure that an agency has the information it needs to assess project  performance. Without collecting information about the multiple measures  affected by a project, the data EPA is using for certain measures of  progress cannot be complete, and EPA is likely underreporting progress  for these measures.

EPA officials told us that they began to address this issue in fiscal year  2012 for two complementary measures in the habitat and wildlife  protection and restoration focus area, the miles of rivers reopened for fish  passage, and the number of fish passage barriers removed or bypassed.  Specifically, EPA has begun asking GLRI funding recipients reporting on  one of these measures to indicate progress, if any, on the complementary  measure. This effort will help EPA obtain more complete information on  these two measures, but it does not address the broader reporting  limitation in GLAS, which EPA officials told us may result in  underreporting of progress for certain measures. EPA officials told us that  they will consider addressing this limitation in GLAS, but they did not  indicate a time frame for doing so.

In addition, although EPA officials told us that they have concerns about  the quality of GLRI progress information in GLAS, they have not fully  assessed the quality of that information, such as its completeness,  accuracy, and consistency. As a result, the agency has not made this  information available to the public. While practices required under GPRA,  as amended, are required at the federal department or agency level, we  have previously reported that these requirements can serve as leading  practices for planning at lower levels within federal agencies, such as  individual programs or initiatives. Thus, EPA is not required to address  requirements under GPRA, as amended, for GLAS, but by following  them, the agency would be implementing leading practices. The GPRA  Modernization Act of 2010 requires, among other things, that agency  performance plans and reports describe how the agency ensures the  reliability of the data used to measure progress toward its performance  goals, including how it verifies and validates measured values of  performance and compensates for any limitations to the data to reach the   Verification includes the assessment of data  required level of accuracy.completeness, accuracy, and consistency to ensure that the data will be  of sufficient quality to document performance and support decision  making. In light of this and EPA’s concerns about the quality of the GLRI  progress data in GLAS, we also have concerns about the use of these  data for measuring progress toward the Action Plan goals and objectives.

GLRI funding recipients are responsible for entering information about the  progress of their GLRI projects directly into GLAS, and EPA has methods  in place to review this information on a project-by-project basis. For  example, EPA has developed a plan for managing the grants, interagency  agreements, and contracts the agency awards for GLRI projects.  According to agency officials, this plan synthesizes existing agency  standards and policies and itemizes the activities to be undertaken by  project officers and others to ensure an effective grant oversight process.  Among other things, this plan specifies that, for interagency agreements,  EPA officials who are GLRI project officers will review progress reports  submitted by GLRI funding recipients and that the project officers will  compare the information in those reports to the information entered in  GLAS.  According to EPA officials, project officers for grants are also  expected to compare information in progress reports with information in  GLAS.

GLRI funding recipients are required to submit semiannual progress reports to EPA.  According to EPA officials, they do not use these project reports to assess GLRI progress.  This is because the progress reports are for administrative management purposes and not  for reporting progress made toward the Action Plan measures. identifying improvements. The officials noted that they are also  considering whether GLAS is the right tool for the GLRI. EPA officials had  not determined a time frame for this work as of June 2013.

Some Task Force and state agency officials, subject matter experts, and  EPA’s Science Advisory Board, raised concerns that certain measures of  progress or their targets may not be useful for indicating GLRI progress  toward the Action Plan’s goals and objectives.

Climatic factors may affect the usefulness of some measures. Five of the  six measures of progress for the nearshore health and nonpoint source  pollution focus area may not be useful for indicating GLRI progress over  the short term toward the Action Plan’s goals and objectives. Specifically,  EPA officials and others have noted that these measures address  environmental conditions that are influenced by climatic factors, such as  precipitation and wind patterns. These factors make it difficult to identify  whether the restoration efforts are having the desired effects. For  example, one of the measures of progress in the Action Plan for this  focus area tracks the square miles of harmful algal blooms in the Great  Lakes. According to information from EPA officials, such algal blooms are  influenced by climatic factors such as precipitation patterns, water  temperature, and wind speed and direction. Officials from another Task  Force agency also told us that because of factors such as weather that  cannot be controlled, the extent of algal blooms in any given year is not  directly related to the management actions being taken in the GLRI and,  as a result, the measure is not useful for indicating GLRI progress toward  the Action Plan’s goals and objectives. EPA officials told us that, given  the short period of time the GLRI has been under way, factors such as  temperature and the amount and timing of precipitation are currently the  primary factors affecting the extent of algal bloom. Officials also told us  that, over the long term, management actions will lead to lower  phosphorous levels, which will have a minimizing affect on the extent of  such algal blooms. However, over the short term, this measure may not  be useful for indicating GLRI progress toward the focus area’s objective  of significantly reducing the number and severity of incidences of harmful  algal blooms by 2014. In addition, we have previously reported criteria for  determining the extent to which an agency’s performance plan provides a  clear picture of intended performance, including that measures must  clearly represent or be related to the performance they are trying to  assess.related to management actions being taken may not be useful for  indicating GLRI progress toward the Action Plan’s goals and objectives.  While we recognize that the Action Plan is not a performance plan, using  criteria intended for performance plans is appropriate because EPA uses  the Action Plan’s measures of progress to assess GLRI progress as an  agency would use the measures in a performance plan.

Therefore, measures that track conditions that are not directly  Some measures track actions that may not be sufficient to lead to the  desired GLRI goals. For example, one of the goals for the toxic  substances and areas of concern focus area is that environmental levels  of toxic chemicals are reduced to the point that all restrictions on the  consumption of Great Lakes fish can be lifted. A measure of progress that  links to this goal tracks the long-term reduction in average concentrations  of PCBs in Great Lakes fish. However, officials from two Task Force  agencies and two state agencies, as well as five subject matter experts,  reported that the measure’s focus on PCBs is too narrow and that other  contaminants, particularly mercury, need to be addressed as well. EPA’s  Science Advisory Board also noted this narrow focus in its 2012 review of  the Action Plan. Mercury is important because, according to a 2011  binational study of mercury in the Great Lakes region, it has widely  contaminated the region and has been responsible for fish consumption  advisories in the eight Great Lakes states and the Canadian province of   The study concluded that mercury, largely due to atmospheric  Ontario. emissions from coal-fired power plants, remains a pollutant of major  concern with an impact on fish in the region that is much greater than  previously recognized. Consequently, reducing average concentrations of  PCBs in fish is not likely to lead to lifting all restrictions on the  consumption of Great Lakes fish. Because this measure does not clearly  represent all of the contaminants that need to be addressed, it may not be  useful for indicating GLRI progress toward the Action Plan’s goals and  objectives.

D. C. Evers, J . G. Wiener, C. T. Driscoll, D. A. Gay, N. Basu, B. A. Monson, K. F.  Lambert, H. A. Morrison, J. T. Morgan, K. A. Williams, and A. G. Soehl, Great Lakes  Mercury Connections: The Extent and Effects of Mercury Pollution in the Great Lakes  Region, Biodiversity Research Institute, Report BRI 2011-18 (Gorham, Maine: 2011).

Monitoring practices may affect the usefulness of some measures. For  example, one goal of the invasive species focus area is to eliminate the  introduction of new invasive species, with a 2014 objective of reducing  the yearly average rate of invasive species newly detected in the Great  Lakes ecosystem by 40 percent, compared with the period from 2000 to  2009. The linked measure of progress addresses the rate at which  nonnative species are newly detected in the Great Lakes ecosystem. The  source of data used to evaluate this measure is a database maintained by  the National Oceanic and Atmospheric Administration. According to  information on this database, the identification of new species depends  on the ability to find, recognize, verify, and document new species, which  is, in turn, dependent on the ability to adequately sample the Great Lakes  ecosystem. Officials from a state agency and four subject matter experts  raised concerns about the usefulness of this measure for assessing  progress toward the Action Plan objectives, noting that the number of new  species detected will increase if surveillance for invasive species  increases or improves. One of these experts noted that meeting the  targets may not represent progress because monitoring efforts are low,  and another of these experts told us that the measure needs to be  combined with a known level of monitoring. Similarly, National Oceanic  and Atmospheric Administration officials agreed that progress toward the  targets for this measure will vary depending on the extent of monitoring  and the ability of surveillance to detect new nonnative species, and they  told us that, without a known level of monitoring, it may not be possible to  reliably identify trends in the introduction or detection of new species  using this measure. As we reported in November 2002, one attribute of  successful performance measures is that they are likely to produce the  same results if applied repeatedly to the same situation. If efforts to  identify new species depend on the ability to adequately sample the Great  Lakes ecosystem and surveillance or levels of monitoring are not  consistent throughout the program, then this measure may not be useful  for indicating GLRI progress toward the Action Plan’s goals and  objectives.

Targets for some measures may not represent significant ecological  improvement. EPA’s Science Advisory Board reported in its 2012 review  of the GLRI Action Plan that it is not clear whether the targets for the  measures of progress reflect significant or measurable improvement, or  whether achieving the targets will result in real ecological benefit. It also  noted that it is not clear how the targets were developed and, that while  the measures of progress include baselines for the targets, the universe  is not always defined. For example, one measure in the nearshore  health and nonpoint source pollution focus area addresses the amount of  land with certain conservation practices implemented to reduce erosion,  nutrients, and pesticides. The Action Plan reports a baseline of 165,000  acres with such practices already being implemented and identifies a  2014 target of 247,500 acres, a 50 percent increase. However, the Action  Plan does not identify the universe (i.e., the total acreage of land upon  which such practices could be implemented), which the Science Advisory  Board reported is more than 38 million acres of agricultural land in the  United States within the Great Lakes Basin. Consequently, using this  universe, the 50 percent increase in acreage using such conservation  measures represents a change from 0.4 percent to 0.6 percent of the total  U.S. agricultural land in the Great Lakes Basin. According to the Science  Advisory Board, it is not clear if this change is meaningful and how this  percentage of improvement will potentially result in the restoration of the  Great Lakes ecosystem. In November 2002, we reported that clarity is a  key attribute of successful performance measure.clarification, this measure may not be useful for indicating GLRI progress  toward the Action Plan’s goals and objectives.

A subgroup of the Task Force agencies has been evaluating how well the  measures of progress and targets are working and has identified some  that will need revisions. For example, the subgroup found that some  measures of progress have been difficult to implement or difficult to  demonstrate scientifically, particularly in the nearshore health and  nonpoint source pollution focus area. However, as this subgroup has  acknowledged, there is no defined process for the Task Force agencies  to revise the Action Plan, such as updating or replacing the measures of  progress or for updating their targets.

section_title: EPA and the Task Force Agencies Have Not Fully Established an Adaptive Management Plan for the GLRI
paragraphs: EPA and the Task Force agencies have not fully established a plan to  guide an adaptive management process for the GLRI. Although there is  no requirement that the Task Force establish an adaptive management  plan for the GLRI, an adaptive management process could allow EPA and  the Task Force agencies to evaluate whether GLRI projects are leading to  the Action Plan’s objectives and goals and, if needed, use the results to  adjust future actions. EPA and several Task Force agencies in 2000  adopted a unified federal policy on watershed management that defined  adaptive management as a type of natural resource management in  which decisions are made as part of an ongoing science-based process  that involves (1) testing, monitoring, and evaluating applied strategies; (2)  incorporating new knowledge into management approaches that are  based on scientific findings and the needs of society; and (3) using results  to modify management policy, strategies, and practices. This policy  stated that the agencies would incorporate adaptive management  principles into their programs and use adaptive management to improve  watershed conditions. More recently, in the 2012 amendment to the Great  Lakes Water Quality Agreement, the United States and Canada agreed to  be guided by the principles and approaches of adaptive management,  which is described in the agreement as a systematic process to assess  the effectiveness of actions and adjust future actions to achieve the  objectives of the agreement, as outcomes and ecosystem processes  become better understood.

There is no universal definition for adaptive management or fixed set of  steps that constitutes an adaptive management process, but key  elements of this iterative process based on guidance documents from  several Task Force agencies are summarized in figure 4. In addition,  according to guidance from the Forest Service, adaptive management  requires explicit designs that, among other things, specify documentation  and monitoring protocols; roles, relationships, and responsibilities; and,  assessment and evaluation processes. This guidance also notes that it is  important for an adaptive management effort to have clear documentation  describing details of the adaptive management process, and an absence  of explicit plans can diminish the potential benefits of adaptive  management.

In its 2012 review of the Action Plan, EPA’s Science Advisory Board  found that the GLRI Action Plan did not establish an adaptive  management framework and recommended that EPA develop a science- based plan that, when coupled with the Action Plan, would create an  adaptive management framework for the GLRI. In response to this  recommendation, in May 2013, the Task Force agencies released the  draft GLRI Adaptive Science-Based Framework for Great Lakes  Restoration, or draft framework, for public comment.

The draft framework recommends use of an “adaptive restoration”  approach for the GLRI that includes most of the key elements of adaptive  management. According to the draft framework, adaptive restoration  involves exploring alternative ways to meet the goals and objectives in  the Action Plan, predicting the outcomes of alternatives based on the  current state of knowledge, implementing one or more of these  alternatives, monitoring to learn about the impacts of restoration actions,  and incorporating new knowledge into restoration strategies that are  based on scientific findings and the needs of society. However, the draft  framework does not provide details on how the elements of adaptive  management will be implemented. For example, neither the draft  framework, nor the Action Plan, addresses how the agencies will  complete the adaptive management loop by incorporating the information  gained in future decision making and adjusting the GLRI, if needed. The  draft framework indicates that re-assessment of the Action Plan goals,  objectives, and measures of progress should be considered every 5  years. However, neither the framework nor the Action Plan outlines a  process for assessing or incorporating new information or altering the  Action Plan, such as by refining the measures or their targets, as  recommended by the adaptive management section of EPA’s 2003  guidance for states and communities on watershed analysis and   For example, neither the draft framework nor the Action  management.Plan identifies decision thresholds or criteria for making changes, which  the Science Advisory Board’s 2012 report and EPA’s 2003 guidance have  identified as important.

In addition, the draft framework does not include two of the key elements  of adaptive management shown in figure 4: engaging stakeholders, and  identifying and evaluating uncertainties.

Engaging stakeholders. According to guidance from several Task Force  agencies, active and sustained stakeholder involvement is essential for  effective implementation of adaptive management. The draft framework  does not explicitly include stakeholder engagement as an element of the  adaptive restoration process. It acknowledges that engaging scientists,  stakeholders, and the general public should be considered for updating  the GLRI over time and states that interactive engagement in setting  goals and objectives is a key element for producing results. Nevertheless,  it does not address how the Task Force agencies will ensure ongoing  stakeholder engagement in the GLRI. Without explicit plans in the draft  framework for engaging stakeholders, it is not clear how the Task Force  agencies will consider and account for potential changes in stakeholder  perspectives and priorities. As the Department of the Interior’s guidance  notes, conflicting priorities among stakeholders can be enough to prevent   This guidance  the successful implementation of adaptive management.also explains that differing stakeholder views about how natural  processes work and how they respond to management are examples of  uncertainties that can limit the effectiveness of management efforts.

Identifying and evaluating uncertainties. Neither the draft framework, nor  the Action Plan, identifies, prioritizes, and evaluates critical scientific or  policy uncertainties. In addition, the draft framework does not include  such uncertainties in its list of elements of adaptive restoration planning.  Such uncertainties could include critical assumptions, gaps in knowledge,  or uncertainties about the relationships between ecological processes  and stresses, such as the potential effects of climate change on the Great  Lakes. Identifying and explicitly accounting for critical uncertainties in  designing the GLRI could increase the likelihood that the GLRI will meet  its goals and objectives. Several Task Force agencies have emphasized  the use of models as an important way to evaluate and account for such  uncertainties by, for example, representing how the ecosystem may  respond to restoration actions or environmental changes. The draft  framework notes that predictive modeling plays an important role in  adaptive restoration, and it recommends evaluation of uncertainties in the  context of reporting on progress. However, the framework does not  identify and account for critical uncertainties.

section_title: Task Force Agencies and Nonfederal Stakeholders Report GLRI Progress, but Overall Great Lakes Restoration Progress Is Difficult to Quantify
paragraphs: The Task Force agencies have issued two GLRI progress reports, but the  reports include few specific examples of progress. To obtain further  insights about GLRI progress, we surveyed nonfederal GLRI stakeholders  and interviewed Task Force agency officials. However, quantifying overall  Great Lakes restoration progress is difficult for several reasons, including  the unique environmental conditions of each of the Great Lakes.
subsections: section_title: Task Force Agencies Report Progress
paragraphs: As we noted previously, the Task Force agencies have issued two GLRI  progress reports to Congress; one on fiscal year 2011 progress and one  on progress in fiscal year 2010. EPA officials told us that the report on  progress in fiscal year 2011 includes more information and was released  earlier than the fiscal year 2010 report because GLRI funding was  available late in fiscal year 2010 and not as much was achieved that year.  Both reports identified whether the targets for the GLRI Action Plan’s 28  measures of progress had been met or exceeded in the related fiscal  year, or that data were unavailable for a specific measure. For example,  the fiscal year 2011 report states that 15 measures were met or  exceeded, 9 measures were not met, and data were not available to  determine the status of 4 measures. However, as we noted earlier, the  measures may not provide sufficiently comprehensive or useful  information for a number of reasons, including that the measures do not  capture the results of many of the GLRI projects and that some measures  or their targets may not be indicative of progress.

In the first years of the GLRI, no new aquatic invasive species populations have been  detected in the Great Lakes. The GLRI is at the forefront of invasive species prevention,  control, and rapid response. The GLRI is supporting investments in technologies that  prevent the introduction of invasive species, including the Department of Transportation’s  Maritime Administration’s verification of new ballast water treatment technologies, which is  an important step before conducting ship-scale testing.

However, except for the two projects highlighted in each focus area, the  fiscal year 2011 report does not identify the GLRI projects that led to the  progress achieved. In addition, neither of the two reports integrates  accomplishment and progress information into conclusions about overall  GLRI progress or contains specific information about the extent of  progress toward GLRI goals, and neither includes an assessment of  changes in the health of the Great Lakes ecosystem that could be  attributed to the projects. As a result, the information in the GLRI progress  reports was not sufficient for determining if GLRI projects had led to the  described progress and how much progress has been made in restoring  the health of the Great Lakes ecosystem.

section_title: Nonfederal Stakeholder and Task Force Agency Examples of GLRI Progress
paragraphs: In light of the limited information included in the two GLRI progress  reports, we sought to obtain further insights by surveying nonfederal  stakeholders and interviewing officials from Task Force agencies. The  information we gathered in the survey allows us to provide more  information on how nonfederal stakeholders describe GLRI progress, and  it is not intended to determine the extent of GLRI progress toward  restoring the health of the Great Lakes ecosystem. When asked to  provide examples of how one or more of their organization’s GLRI  projects had benefitted the Great Lakes ecosystem, 87 percent (153) of  the 176 respondents provided at least one example of how one or more  of their GLRI projects had benefited, or was expected to benefit, the  Great Lakes ecosystem in each of the five focus areas. Specifically:

55 percent (96) of respondents provided at least one example of how  one or more of their GLRI projects had directly benefited the Great  Lakes ecosystem, such as by restoring habitat or by trapping invasive  species.

27 percent (47) of respondents provided at least one example of how  one or more of their GLRI projects indirectly benefited the Great  Lakes ecosystem, such as by improving the understanding of part of  the ecosystem or identifying future restoration work.

44 percent (77) of respondents reported that they expected at least  one of their projects to result in a direct or indirect benefit to the  ecosystem, but that it was too early to report a benefit at this time.

13 percent (23) of respondents did not provide an example of how  one of their projects had, or was expected to, benefit the Great Lakes  ecosystem.

Toxic substances and areas of  concern

One survey respondent reported that her organization received two  GLRI grants to help clean up the Presque Isle Bay area of concern in  Lake Erie, in Pennsylvania; the two grants totaled $664,789. The  respondent told us that, prior to the GLRI, the organization was  devoting all of its resources to addressing only one of the specific  conditions—fish tumors—that were responsible for the bay being  identified as an area of concern, and that GLRI funding made it  possible for her organization to do additional work. Specifically, GLRI  funding enabled the organization to undertake a number of monitoring  and investigative projects; develop a target for being removed from  the list of areas of concern; and, develop a long-term monitoring,  restoration, and protection plan for the bay’s watershed. The  respondent reported that GLRI funding was also used for specific  investigations in the watershed that will provide her organization with  an updated set of data to use in identifying priority areas for  restoration and protection. According to the respondent, without that  information, the organization would not have a blueprint to maintain  and continue protecting the bay. In December 2012, 21 years after the  bay had been identified as an area of concern, the survey respondent  told us in an interview that her organization was in the process of  sending a formal request to remove Presque Isle Bay’s designation as  an area of concern. EPA announced in February 2013 that the bay  had been delisted. It is the second U.S. area of concern to be  removed from the list. The respondent estimated that GLRI funding  had accelerated the process of removing Presque Isle Bay from the  list of areas of concern by 10 years.

Officials we interviewed from the U.S. Geological Survey told us that  the agency had used GLRI funds to complete three basin-wide  sampling efforts of the water column, bottom sediments, and two  other types of samples across the entire Great Lakes Basin as a part  of its methylmercury sampling and analysis project. Methylmercury— an organic form of mercury—is a highly toxic substance that can build  up in predatory fish, including fish that people eat. According to the  officials, the sampling efforts took place in August 2010, April 2011,  and August 2011, and data from these efforts have revealed a  previously unknown source of methylmercury that likely is the  dominant source leading to elevated concentrations in fish throughout  the Great Lakes.

One survey respondent reported progress made by a project to  improve control of sea lampreys, an invasive species in the Great  Lakes, for which his organization had received $8,203,561 in GLRI  funding. According to the U.S. Geological Survey, sea lampreys have  devastated fish communities in the Great Lakes by feeding on the  bodily fluids of host fish, such as the native lake trout. According to  the respondent, the project worked to develop a new sea lamprey  control technique that relies on the sea lamprey’s sense of smell. The  respondent reported that field trials using this technique increased  trapping efficiencies by up to 53 percent and that traps used with this  technique can capture more than twice as many sea lampreys as  traps that do not use the technique. According to the respondent, this  new technique may make it possible not only to capture more sea  lampreys but also to reduce the amount of pesticides introduced into  the Great Lakes that are used to kill sea lampreys.

Officials we interviewed from the U.S. Coast Guard told us that the  agency’s invasive species-related projects will increase its  enforcement capability and address some technical problems relating  to the installation and operation of freshwater ballast treatment  systems for vessels operating on the Great Lakes. Ballast water is  water that is taken into or discharged from a ship to accommodate  changes in weight as a ship loads or unloads cargo. According to the  U.S. Coast Guard, ballast treatment systems are intended to reduce  the number of invasive species that can be transported into the Great  Lakes in ballast water. The U.S. Coast Guard’s Research and  Development Center worked with the Naval Research Laboratory to  design, build, test, and verify a system for testing treated ballast water  under both shoreside and shipboard conditions. According to U.S.  Coast Guard officials, this project will facilitate rigorous testing of the  performance of ballast water treatment systems under shipboard  conditions, ensuring greater protection against the introduction of  invasive species into the Great Lakes.

Nearshore health and nonpoint  source pollution

One survey respondent reported that her organization received  $85,000 in GLRI funding for a project to reduce the amount of bacteria  in beach sand at a park on Lake Erie, in New York. According to the  respondent, work completed in 2011 with GLRI funds determined that  beach sand is acting as a reservoir for Escherichia coli, abbreviated  as E. coli, which can negatively impact public health. The  organization then compared three sand grooming techniques to no  beach grooming. According to the respondent, the results indicated  that sand grooming using a specific tractor attachment can reduce the  amount of bacteria in the sand. In 2012, the organization compared  water quality when sand was groomed using two different grooming  techniques. The respondent reported that preliminary results indicate  that grooming the beach daily with the specific tractor attachment  significantly reduced the number of beach closures. The respondent  reported that this fiscal year 2011 to 2012 GLRI project resulted in an  improvement in water quality.

The Natural Resources Conservation Service received $75 million in  GLRI funding from fiscal years 2010 to 2012 to target conservation  efforts in selected priority areas. According to an agency official, this  funding provides an opportunity to implement additional scientifically  proven conservation practices in the priority watersheds, accelerating  conservation practice implementation above what other programs  would have provided. Landowners can take advantage of GLRI funds  through a Natural Resources Conservation Service cost-share  assistance program to install conservation practices. The agency  helps landowners with conservation planning using various  conservation practices, such as cover crops, conservation crop  rotations, filter strips, prescribed grazing, and wetlands restoration.  For example, the practice of cover crops establishes close-growing  grasses, or other crops, to help improve soil and water quality by  reducing soil erosion, among other things. A filter strip is a strip of  herbaceous vegetation that is situated between crop or grazing land  and a stream, river, or wetland, in order to reduce contaminated  runoff. An agency official reported that GLRI funded efforts have led to  the use of cover crops and filter strips on nearly 70,000 acres and 143  acres of priority watersheds respectively. For example, one landowner  used the funds to develop a prescribed grazing system that  encourages groundwater recharge, improves soil quality and prevents  sediment and nutrient losses. The landowner is also installing a waste  collection system to keep contaminated water out of nearby surface  water and plans to plant 34 acres of cover crop.

Habitat and wildlife protection  and restoration

A survey respondent reported that his organization had a project to  help restore a marsh area that is among the roughly 15 costal marsh  areas along Lake Michigan’s Lower Peninsula shoreline. The  organization received $783,823 in GLRI funds for the project. One  component of the project was to replace seven misaligned culverts.  According to the respondent, the new culverts will allow unimpeded  fish passage to more than 12 miles of stream habitat, which improves  habitat for trout and other aquatic organisms. In addition, the  respondent reported that the project restored a mile-long section of  trout stream back to its original watercourse. This was necessary  because the hydrology of an adjacent 75-acre wetland had been  significantly degraded when the trout stream had been diverted into a  straightened channel decades ago. The project also resulted in the  eradication of types of invasive plants. The survey respondent  reported that this project will improve fisheries habitat, help restore  hydrology to a large wetland for waterfowl and many other species of  wildlife and fish, and improve public recreational opportunities.

Officials from the Fish and Wildlife Service told us that the agency has  received $11,590,857 in GLRI funds in fiscal years 2010 to 2012 for a  project that focuses on restoring habitats for native lake sturgeon,  brook trout, migratory birds, and threatened and endangered species  populations within the Great Lakes Basin by removing barriers to fish  passage, stabilizing stream banks and riparian areas (narrow  vegetated areas adjoining rivers, streams, and lakes), improving in- stream habitat and restoring costal, wetland and upland areas.  According to agency officials, the project has protected, restored, or  enhanced more than 2,000 acres of wetlands and uplands, removed  or bypassed more than 30 fish passage barriers, and reopened more  than 210 stream miles to fish movement. Agency officials said that  improving aquatic connectivity in the Great Lakes Basin is one of the  more prominent achievements of the project, and that removing  barriers to fish passage creates a healthier aquatic habitat and  improves water quality and sediment management. In addition,  according to agency officials, free-flowing rivers provide new  recreational opportunities.

Accountability, education,  monitoring, evaluation,  communication, and  partnerships

One survey respondent reported that his organization received GLRI  funding to map and describe all of the wastewater treatment plants in  the Great Lakes Basin, both in the United States and Canada, and to  develop a binational aquatic invasive species response plan. The  respondent’s organization received $300,000 in GLRI funding for  these projects. According to the respondent, the project to map and  describe wastewater treatment plants resulted in the first ever  binational map of these facilities and will inform management  decisions about the level and consistency of water treatment and help  protect human and environmental health. In addition, the respondent  reported that the aquatic invasive species response plan developed  by his organization provides a foundation for work on a basinwide  plan that will be an important backup plan in the event that aquatic  invasive species prevention efforts fail. According to the respondent,  the plan his organization developed will directly assist the  governments of the United States and Canada in meeting their  obligations under the 2012 amendment to the Great Lakes Water  Quality Agreement, which requires the two governments to develop  and implement an early detection and rapid response initiative for  aquatic invasive species, among other things.

Officials we interviewed from the National Oceanic and Atmospheric  Administration told us that the agency’s dissemination of training  materials for educators and climate curricula for elementary through  high school students, which is customized for the Great Lakes region,  is on target to reach more than 3,000 students and 50 teachers by the  end of fiscal year 2013. As a result, officials said, the number of  institutions incorporating this information into existing curricula far  exceeds the GLRI Action Plan targets. Specifically, the Action Plan’s  2013 target for the measure that addresses the number of educational  institutions incorporating Great Lakes protection and stewardship  criteria into their environmental education curricula is 10 institutions.  This measure corresponds to the Action Plan’s goal to increase  outreach and education for the Great Lakes so that students  understand the benefits and ecosystem functions of the Great Lakes  and are able to make decisions to ensure that restoration investments  are enhanced over time.

In addition to these examples of progress, respondents to our survey and  other stakeholders we interviewed reported that the GLRI had allowed  them to do restoration work that they previously identified as important  but could not undertake because of limited funds or staff, among other  reasons. For example, one survey respondent noted that due to GLRI  funding, progress has been made on problems that had been languishing  for years due to inadequate funding such as high-priority restoration  projects, aquatic invasive species control, and actions to reduce  beneficial use impairments. In addition, a state agency official we  interviewed told us that without GLRI funding his state would not have  had the capacity to help coordinate restoration efforts for areas of  concern or conduct necessary monitoring of fish toxicity. Furthermore, in  commenting on a draft of this report, National Park Service officials noted  that GLRI funds have proven to be invaluable for helping the Service  accomplish significant restoration of wetlands and areas affected by  invasive species, among other things.

section_title: Overall Great Lakes Restoration Progress Is Difficult to Quantify
paragraphs: We, and other organizations, have documented the difficulties associated  with efforts to quantify overall progress toward Great Lakes restoration.  For example, we reported in 2004 that it is difficult to describe restoration  progress across the basin because of the unique environmental  conditions of each of the Great Lakes. Specifically, the Great Lakes are  not one contiguous water body but rather distinct lakes with unique  environmental conditions—such as lake depth—that present challenges  to setting goals and developing a monitoring system that can be used to  describe restoration progress across the basin and also capture the  uniqueness of each lake. In addition, according to a 2006 United Nations  report, it is usually difficult, and sometimes impossible, to attribute  changes in the state of a large ecosystem solely to the efforts of a specific  ecosystem management program. agency officials, nonfederal stakeholders, and subject matter experts told  us that it may take time for some Great Lakes restoration efforts to show  measurable results.

Furthermore, several Task Force  EPA officials told us that it may not be possible to summarize Great  Lakes restoration progress with one simple statement due to the size and  complexity of the Great Lakes ecosystem. They said that when the Action  Plan was created, the Task Force agencies incorporated a measure the  agency had created as part of its GPRA reporting requirements, the Great  Lakes 40-point scale (also called the Great Lakes Index), as a measure of  progress intended to represent progress across the focus areas by  measuring improvement in the overall health of the aquatic ecosystem.  The index rates eight indicators on a scale from 1 to 5, where 1 is poor,  and 5 is good, to produce an assessment of overall Great Lakes health  that is represented by one number.

However, some stakeholders and subject matter experts we interviewed  raised concerns about the index and some of its indicators. For example,  they said that the index is missing key ecosystem indicators, such as  those related to invasive species and the health of native species. In  addition, they said that the index is better suited for assessments of long- term, as opposed to annual, changes in the health of the ecosystem. EPA  officials also questioned how meaningful it was to use just one number to  convey information about the state of the multiple ecosystems and  indicators within the Great Lake basin.

EPA officials also explained that the GLRI is a relatively new undertaking  and that getting visible, lake-wide and basin-wide ecosystem  improvements from Great Lakes restoration efforts is a slow process.  According to the officials, benefits, such as improvements in areas of  concern, are being seen at the local level and by the end of the GLRI’s  lifespan in 2014, EPA will be able to show progress at a local level as a  step toward improving the health of the lakes overall.

The Task Force agencies’ draft framework includes direction to report on  restoration progress and accomplishments, and transfer knowledge and  lessons learned, among other things. The draft framework also notes that,  while assembling project specific results can begin to offer a picture of  cumulative progress and local success, reporting on GLRI at the program  level can inform whether or not the GLRI is making restoration progress  at other levels, such as the regional, lake, or ecosystem level.

section_title: Nonfederal Stakeholders Identified Key Factors That May Affect and May Limit GLRI Progress
paragraphs: In response to our survey, respondents reported on what they believed to  be the key factors that may affect and may limit GLRI progress. They  cited practical issues related to implementing GLRI projects, such as the  time it takes to complete quality assurance requirements and obtain  permits. They also cited broader issues outside the scope of the Action  Plan, for which realistic solutions may be expensive, pointing in particular  to inadequate infrastructure for wastewater and stormwater and the  effects of climate change.
subsections: section_title: Factors Related to Implementing GLRI Projects Affected Progress
paragraphs: Survey respondents most often reported that their GLRI projects started  later than planned because of quality assurance requirements and the  length of time needed to obtain permits. It is important to emphasize that  quality assurance requirements for environmental programs play a critical  role in ensuring the success of those programs and that permits for  environmental activities are required by a number of federal and state  laws. Moreover, survey respondents did not suggest that either process  should be eliminated when asked to comment on GLRI’s quality  assurance requirements. Nonetheless, later start times can slow GLRI  implementation and, as a result, may affect the pace of progress.

Quality assurance requirements. Organizations that receive GLRI  funds through federal grants may be required to meet specific quality  assurance requirements for projects and tasks involving  environmental data in order to receive the funds. Seventy-seven  percent (135) of the 176 survey respondents reported that they  needed to complete quality assurance requirements for at least one of  their GLRI projects and, that on average, it took nearly 4 months to  complete those requirements. Of those 135 respondents, 28 percent  (38) reported that their projects started later than planned because of  the time it took to complete quality assurance requirements, and 13  percent (17) reported that they could not start their project until the  next spring because the ground or water was frozen. EPA officials told  us that the GLRI quality assurance process was slow at the start of  the program because the agency had not previously assessed quality  assurance requirements for the kind of work being proposed in some  of the projects. However, several survey respondents reported that  the time it takes to complete GLRI quality assurance requirements  has decreased since the program began in fiscal year 2010.

Time needed to obtain permits. Organizations implementing GLRI  projects might need to obtain federal or state permits for certain  efforts, such as using herbicides to reduce invasive species,  conducting controlled burning to enrich soil nutrients, or enhancing  habitat for endangered species and communities. About half (87) of  the 176 survey respondents reported that they needed a permit for at  least one of their GLRI projects and that it took an average of 5  months to obtain the necessary permits. Of those 87 respondents, 31  reported that their projects started later than planned as a result of the  time needed to obtain permits, and 13 reported that they could not  start their project until the next spring because the ground or water  was frozen. In addition, in the fiscal year 2011 GLRI progress report,  the Task Force agencies identified permit processing as one of the  factors for slowed project implementation for the habitat and wildlife  protection and restoration measure of progress addressing the  number of acres of coastal, upland, and island habitats protected,  restored, and enhanced.

Survey respondents also reported that the timing of award notification  resulted in later-than-planned start times for their GLRI projects (30  percent, or 52 out of 176, respondents), and that weather events limited  the implementation of their GLRI projects (26 percent, or 45 out of 176,  respondents). Specifically, 16 percent (29) reported that weather events  caused their GLRI projects to be completed later than planned, 15  percent (27) reported weather events caused a suspension of GLRI  activities, and 6 percent (11) reported that weather events resulted in  later-than-planned start times for their GLRI projects.may cause GLRI projects to start later than planned because work cannot  proceed on some projects—such as those that involve planting, doing  construction, or monitoring stormwater—if there is a drought, too much   Weather events  rain, or the ground does not freeze in winter, among other things. For  example, three survey respondents reported that work on their projects in  wetlands was delayed because the wetlands involved with their  organization’s projects did not sufficiently freeze one winter.

section_title: Factors Outside the Scope of the Action Plan May Limit GLRI Progress
paragraphs: Once started, the success of GLRI projects and of the GLRI as a whole  can depend upon factors outside the scope of the Action Plan—that is,  factors that are not addressed by the Action Plan’s long-term goals,  objectives, or measures of progress—that affect the Great Lakes  ecosystem. One such factor is atmospheric deposition, which is a process  that transfers pollutants from the air to the earth’s surface and can  significantly impair water quality in the nation’s rivers, lakes, bays, and  estuaries, and harm human health and aquatic ecosystems. Airborne  pollutants transferred by atmospheric deposition can fall to the ground in  precipitation or as a gas or particle and be deposited either directly onto  the surface of a water body or onto land and then transported into a water  body through runoff. Atmospheric deposition contributed to the presence  of toxaphene in the Great Lakes. Toxaphene is an insecticide that was  once primarily used in southern states from 1947 to 1980, and it was  banned in the United States for all uses in 1990. It is toxic for many  aquatic organisms and accumulates in fish and shellfish causing health  problems in humans who consume them.

We asked survey respondents to rank nine factors that are not addressed  in the Action Plan on the basis of their potential to limit the restoration of  the health of the Great Lakes ecosystem. As indicated in figure 5, survey  respondents most frequently reported that inadequate infrastructure for  wastewater or stormwater (72 percent, or 126 of 176, respondents) and  the effects of climate change (65 percent, or 114 of 176, respondents)  have the greatest potential to limit the restoration of the health of the  Great Lakes’ ecosystem in comparison with other factors outside the  scope of the Action Plan. Survey respondents also reported that factors  such as the removal of water from the Great Lakes for use outside of the  region and the effects of population growth in the Great Lakes region  have the potential to limit the restoration of the health of the Great Lakes’  ecosystem to a great or very great extent by 57 percent (101 out of 176  respondents) and 49 percent (87 out of 176 respondents) respectively.

In addition, we asked 21 Great Lakes subject matter experts we  interviewed to rank these factors, and 13 of the 21 experts identified the  same top two factors the survey respondents did, noting that both  inadequate infrastructure for wastewater or stormwater and the effects of  climate change have the potential to limit the restoration of the health of  the Great Lakes ecosystem to a great or very great extent.

Inadequate infrastructure for wastewater or stormwater refers to the  deteriorating condition of the nation’s wastewater systems. These  systems include sewer pipes that convey wastewater from homes and  businesses to treatment facilities before discharging it into water bodies  or land. In a 2004 report to Congress, EPA estimated that more than 1.2  million miles of pipes delivered wastewater into these systems. EPA has  also reported that the vast majority of the pipes making up the nation’s  wastewater systems were installed more than 50 years ago and are  reaching the end of their useful lives. In addition to the age of these  systems, their conveyance capacity (i.e., the rate at which they can  transport water) is often exceeded during rainfall or snowmelt, which adds  to the discharge of wastewater into U.S. surface waters. According to the  American Society of Civil Engineers, the age and inadequate capacity of  wastewater infrastructure systems lead to the discharge billion of gallons  of untreated wastewater into U.S. surface waters each year.

Inadequate infrastructure can cause conditions that may slow, if not  negate, restoration efforts, such as to improve water quality or reduce the  number of days a beach is closed. This is because most wastewater  systems are designed to discharge flows that exceed conveyance  capacity directly to rivers, streams, and other surface waters. One Great  Lakes interest group reported that five U.S. cities alone discharged 41  billion gallons of untreated sewage and stormwater into the Great Lakes  from January 2009 to January 2010. needs survey report, EPA stated that $19.7 billion was needed to address  publicly owned wastewater and stormwater infrastructure needs in the  Great Lakes Basin.

Healing Our Waters – Great Lakes Coalition, Turning the Tide: Investing in Wastewater  Infrastructure to Create Jobs and Solve the Sewage Crisis in the Great Lakes (Ann Arbor,  MI: August 2010). According to the report, data for this statement was provided by the five  cities and EPA. but a strong scientific consensus has emerged in recent years from the  U.S. Global Change Research Program and the National Research  Council that the future likely entails greater risks of flooding, drought, and  changes in the frequency and severity of storms. In addition, several  organizations have predicted specific effects of climate change in the  Great Lakes, which could negatively affect GLRI restoration efforts, such  as to remove contaminated sediments from areas of concern or reduce  the introduction of invasive species. For example, according to a 2000  report by the U.S. Global Change Research Program, drought could lead  to certain situations in the Great Lakes that may require additional  dredging of sediments at an annual cost of from $75 million to $125  million—about $101.6 million to $129.6 million in 2013 dollars—simply to  maintain shipping lanes. In addition, the U.S. Global Change Research  Program reported in 2009 that warming water temperatures can lead to  increased numbers of aquatic invasive species, which tend to thrive under  a wide range of environmental conditions, and a decline in native species,  which are adapted to a narrower range of conditions. As we noted  previously, invasive species such as the zebra mussel have caused  extensive ecological and economic damage to the Great Lakes.

One way to reduce the potential effects of climate change is to invest in  enhancing resilience. As defined by the National Academies, resilience is  the ability to prepare and plan for, absorb, recover from, and more  successfully adapt to adverse events.  Enhanced resilience results from better planning to reduce losses, rather than waiting for an event to occur  and paying for recovery afterward. Many jurisdictions in the Great Lakes  region have recognized the threat of climate change and committed  resources to prepare for its effects, according to a 2012 report focused on  the region. Among these efforts, several Great Lakes states and the city  of Chicago have each created climate change action plans that identify  steps being taken to reduce the effects of climate change. For example,  the city of Chicago identified the use of green roofs as one of many  climate change mitigation and adaptation actions in its 2008 Chicago  Climate Action Plan. In its subsequent progress report, Chicago  reported that more than 4 million square feet of green roofs had been   A green roof is a vegetative layer  planned or completed since 2008.grown on a rooftop that provides shade and removes heat from the air,  reducing temperatures of the roof surface and the surrounding air. As a  result, green roofs act as insulators for buildings and reduce the energy  needed to provide cooling and heating, which can decrease the  production of associated air pollution and greenhouse gas emissions that  contribute to climate change.

In addition, some Great Lakes jurisdictions have recognized that climate  change can exacerbate other factors that may limit Great Lakes  restoration. As we reported in April 2013, the Milwaukee Metropolitan  Sewerage District officials employed what they called “green  infrastructure” programs to make the district’s sewer system more  resilient to climate change by capturing and holding or slowing the flow of  stormwater. This was done as part of broader efforts to meet growing  demand for sewer capacity, and officials plan to incorporate climate  change adaptation into infrastructure planning and design where it makes  sense as their facilities age and are replaced over time.

The Action Plan does not include goals, objectives, or measures of  progress that show how the GLRI should address inadequate  infrastructure, the effects of climate change, or other key factors that may  limit the Action Plan’s success and overall progress concerning the health  of the Great Lakes ecosystem, with two exceptions. In some cases,  such as with inadequate infrastructure for wastewater or stormwater and  atmospheric deposition of pollutants from sources outside the Great  Lakes Basin, the Action Plan notes that some of these issues are  addressed by other federal programs. For example, the Action Plan  states that infrastructure needs will be addressed through increased  funding for EPA’s Clean Water State Revolving Funds, a program that  provides states and local communities with independent and sustainable  sources of financial assistance, such as low- or no-interest loans, to fund  water quality projects identified by the states and localities. EPA reported  in 2010 that the program has provided more than $74 billion for these  projects since 1988. As we testified in March 2013, however,  wastewater infrastructure needs are made more daunting by the limited  resources and budgets facing all levels of government.

The Action Plan acknowledges that the effects of climate change may  have implications across all five of the Action Plan’s focus areas, and that  the needs of communities to adapt to those effects will be assessed and  addressed by GLRI projects and programs where appropriate. However,  the Action Plan does not state how these effects will be addressed. To  date, EPA has made some modest efforts to acknowledge the issue in  the context of the Great Lakes. In its 2012 request for grant applications,  for example, EPA included $200,000 for two to five grants for projects to  increase climate change resiliency in Great Lakes communities. EPA also  included an incentive in the request for applications for 2012 for the  applicants to consider climate change impacts through vulnerability  assessments or the integration of climate change adaptation measures  into their project. Specifically, applicants could increase their eligibility for  a grant by addressing climate change in their proposal.

The GLRI was created to accelerate the protection, maintenance, and  restoration of the integrity of the Great Lakes. If the Action Plan does not  state how the GLRI should address key factors—such as inadequate  infrastructure and the effects of climate change—then the ability of  restoration efforts guided by the Action Plan to achieve the GLRI’s goal is  uncertain because these factors may negatively affect restoration efforts.  EPA has acknowledged that the effects of climate change can be  detrimental to the Great Lakes and stated in its fiscal year 2013 budget  justification that it is imperative that consideration of climate change and  climate adaptation be integrated into GLRI grants and projects to ensure  the overall success of the GLRI. Nonetheless, to date, EPA has made  few connections between this key issue and the potential effects of  climate change. At a series of public meetings and webinars beginning in  May 2013, EPA requested input regarding whether the connection  between the Action Plan focus areas and the protection of the Great  Lakes from the effects of climate change should be expressed more  clearly in the next Action Plan. In commenting on a draft of this report,  EPA officials told us that they have heard from many stakeholders about  the need for the fiscal year 2015 to 2019 Action Plan to place additional  emphasis on climate change, and that there is broad agreement on this  point among the task force agencies.

section_title: Conclusions
paragraphs: As directed by Congress, EPA and the other Task Force agencies began  implementing the GLRI in fiscal year 2010 to address the stresses that  threaten the health of the Great Lakes ecosystem and help restore the  health of the Great Lakes and issued the GLRI Action Plan to guide  implementation of the approximately $1.3 billion appropriated to the  program. A collaborative and comprehensive approach, it is clear that  both federal and nonfederal GLRI stakeholders believe that the program  is making strides toward its goals. For example, GLRI efforts enabled  EPA to remove the Presque Isle Bay area of concern from the list of  areas of concern identified by the United States and Canada.  Nonetheless, the threats to the Great Lakes persist, and EPA and the  other Task Force agencies face significant challenges in ensuring the  future success of the GLRI due to issues involving their abilities to assess  and achieve progress. EPA and the Task Force agencies are currently  obtaining input for the next version of the GLRI Action Plan for fiscal  years 2015 to 2019.

EPA has assessed GLRI progress primarily by using information from  various sources to determine whether the GLRI is meeting the annual  targets for the 28 measures in the Action Plan. Assessments of GLRI  progress could help GLRI stakeholders, Congress, and the public discern  the extent to which the health of the Great Lakes ecosystem has been  restored, as well as what has been achieved by the approximately $1.3  billion appropriated to the program since fiscal year 2010. Moreover, such  assessments can be used by EPA and the Task Force agencies to  assess the effectiveness of GLRI actions and adjust their efforts if  needed. However, we believe EPA is not well positioned to produce  comprehensive and useful assessments for several reasons. Specifically:

Some of the Action Plan’s long-term goals and objectives do not have  measures of progress that link to them. We believe that clear linkages  between a plan’s goals, objectives, and measures are critical to  achieving and assessing progress over time. Without such linkages in  the current Action Plan, it is unclear how EPA will be able to assess  progress in meeting the Action Plan’s long-term goals and objectives.

Similarly, without identifying linkages between long-term goals,  objectives, and measures in the Action Plan for 2015 to 2019 now  under development, it is unclear how EPA will be able assess  progress in meeting the long-term goals and objectives in that plan.

The measures of progress do not capture the results of many of the  GLRI projects because more than half of the projects are not  associated with an Action Plan measure of progress in GLAS, which  is a mechanism EPA created for collecting information to monitor  GLRI projects and progress. We recognize that some projects do not  directly provide data for any of the Action Plan’s 28 measures, and  that the cumulative results of some of the projects without assigned  measures may ultimately be captured by some of the existing  measures. With so many instances in which a project does not have  an assigned measure, it is unclear if EPA will have the information it  needs to capture the results of these projects and, therefore, if the  agency can assess the full extent of progress being made.

GLRI projects may directly address multiple measures of progress,  but GLAS limits users to reporting the information for just one  measure for each project even if more measures are being  addressed. Without complete progress information on GLRI projects,  the data EPA is using for certain measures of progress cannot be  complete, and EPA may be underreporting GLRI progress. EPA  officials told us that they will consider addressing this limitation in  GLAS, but they did not specify a time frame for doing so.

Some Action Plan measures or targets may not be useful because,  among other things, they track activities that may not be sufficient to  lead to the desired GLRI goals. Without useful measures, EPA may  not be able to determine that GLRI efforts are producing the desired  results.

EPA and the Task Force agencies have not fully established an  adaptive management plan. Although there is no requirement that the  Task Force agencies establish an adaptive management plan for the  GLRI, EPA and several of the Task Force agencies agreed in a 2000  to incorporate adaptive management principles into their programs.  EPA and the Task Force agencies recently issued a plan that includes  most but not all of the key elements of adaptive management, and it  does not provide details on how the elements of adaptive  management will be implemented. Without a fully established  adaptive management plan, EPA and the other Task Force agencies  may be limited in their ability to assess the effectiveness of GLRI  efforts and adjust future actions to achieve the goals and objectives of  the GLRI as results and ecosystem processes become better  understood.

We recognize the potentially significant contributions that individual GLRI  projects can make to resolving specific environmental and public health  stresses that threaten the Great Lakes. However, we believe that these  contributions need to be viewed in the context of larger factors affecting  the Great Lakes, in order to more fully appreciate the long-term future of  the Great Lakes and to develop optimal strategies to help ensure the best  possible outcome. Some of these factors can lead to problems that will be  very expensive to address. Most notably, inadequate infrastructure for  wastewater and stormwater and the effects of climate change may lead to  conditions that can negatively affect GLRI restoration efforts. One way to  reduce the potential impacts of climate change is to invest in planning to  reduce losses, rather than waiting for an event to occur and paying for  recovery afterward. The Action Plan touches on these factors, but it does  not directly address how these factors may affect GLRI efforts to restore  the health of the Great Lakes ecosystem or provide strategies to address  them. Without more clearly expressing that connection in the next Action  Plan, EPA will not be able to help address the effects of these factors,  including climate change, on GLRI restoration efforts.

section_title: Recommendations for Executive Action
paragraphs: To address challenges the Task Force faces in producing comprehensive  and useful assessments of progress and addressing factors that may limit  GLRI progress, we recommend that the EPA Administrator, in  coordination with the Task Force, as appropriate, take the following seven  actions: ensure progress toward long-term goals or objectives that are  identified in the Action Plan, but which do not have measures that link  to them, is assessed; ensure that linkages between long-term goals, objectives, and  measures are identified in the Action Plan for 2015 to 2019; ensure that the progress being made by projects that do not have an  Action Plan measure assigned to them is captured in assessments of  GLRI progress; capture complete information about progress for each of the  measures that are addressed by a project; further evaluate the usefulness of the current measures and targets  and the need, if any, for the creation of additional measures; establish an adaptive management plan that includes all of the key  elements of adaptive management and provides details on how these  elements will be implemented; and address how factors outside of the scope of the Action Plan that may  limit progress, such as inadequate infrastructure for wastewater or  stormwater and the effects of climate change, may affect GLRI efforts  to restore the Great Lakes.

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to EPA, the Departments of Agriculture,  Commerce, Defense, Health and Human Services, Homeland Security,  the Interior, State, and Transportation, and the Council on Environmental  Quality for comment. In written comments from the EPA Region 5  Administrator, which are reproduced in appendix II, EPA generally agreed  with the conclusions and recommendations in our report. EPA noted in  particular that our report is well-timed because it comes at the beginning  of a new 5-year GLRI planning cycle. The agency also noted that we  rightly acknowledged the complexity of assessing and quantifying overall  Great Lakes health, the difficulty of attributing specific environmental  changes to specific projects or programs, and the slow pace of  ecosystem change.

In addition, EPA noted that the agency is already taking actions  consistent with our recommendations, including working to develop more  appropriate measures of progress in the Action Plan for fiscal years 2015  to 2019 and finalizing the draft framework. The agency also noted it is  working with the task force agencies to link all activities described in  interagency agreements to goals, objectives, and measures of progress  in the Action Plan to help to track projects where there is not currently an  associated measure of progress for which data can be reported in GLAS.  EPA also noted that the agency has heard from many stakeholders about  the need for the next Action Plan to place additional emphasis on climate  change, and that there is broad agreement on this point from Task Force  agencies. Taken together, we believe comprehensive actions along the  lines stated in the EPA letter would constitute important steps forward,  and we will look forward to seeing the progress the agency has made in  taking these actions in the 2015 to 2019 Action Plan.

In written comments from the Department of the Interior’s Assistant  Secretary for Policy, Management, and Budget, which are reproduced in  appendix III, Interior noted that information in our report is accurate and  relevant, and the agency acknowledged the challenges in quantifying the  progress toward restoration goals that we identified in our report. The  Department of Agriculture provided technical comments but did not  comment on our recommendations. Its letter is reproduced in appendix  IV.

In addition to these written comments, the Council on Environmental  Quality submitted an e-mail on September 13, 2013, that further  emphasized our findings on the need for accountability. Specifically, this  e-mail stated that GLAS limitations have led to an underreporting of  progress for certain measures, so that they are not most accurately  reflecting what benefits are accruing under the measures and projects  implemented. EPA and the Departments of Agriculture, the Interior, and  Transportation, provided technical comments that we incorporated as  appropriate.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Administrator of the  EPA, the appropriate congressional committees, and other interested  parties. In addition, the report will be available at no charge on the GAO  website at http://www.gao.gov.

If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or gomezj@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made significant contributions  to this report are listed in appendix VII.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This appendix provides information on the scope of work and the  methodology used to examine (1) how the Great Lakes Restoration  Initiative (GLRI) is implemented by the Task Force agencies and other  stakeholders; (2) the methods that the Environmental Protection Agency  (EPA) has in place to assess GLRI progress; (3) the progress identified  by the Task Force agencies and nonfederal stakeholders; and (4) the  views of nonfederal stakeholders on factors, if any, that may affect or limit  GLRI progress.

To examine how the GLRI is implemented by the Great Lakes  Interagency Task Force (Task Force) agencies and other stakeholders  we analyzed key documents and interviewed individuals involved with the  GLRI. Specifically, we analyzed the Great Lakes Restoration Initiative  Action Plan Fiscal Years 2010-2014 (Action Plan) to understand its  structure and identify the long-term goals, objectives, measures of  progress and related annual targets, and principal actions in each of the  Action Plan’s five focus areas; EPA GLRI financial reports and the  agency’s fiscal year 2014 budget justification to determine the amount of  GLRI funds that have been allocated for fiscal years 2010 to 2013 to each  Task Force agency and each focus area; and, information from the Great  Lakes Accountability System (GLAS) to identify the number of GLRI  projects in each focus area and to learn more about GLRI projects, such  as location, size, and funding.

We also reviewed interagency  agreements between EPA and the Task Force agencies that identify the  amount of GLRI funds EPA will allocate to each agency and the GLRI  projects the agencies will implement. In addition, we conducted interviews  with federal stakeholders, officials from EPA headquarters, EPA’s office  responsible for implementing the GLRI, the Great Lakes National  Program Office, and the other Task Force agencies. We also interviewed  representatives from nonfederal GLRI stakeholders—such as the Nature  Conservancy and the Great Lakes Indian Fish and Wildlife  Commission—and a prominent Great Lakes interest group, Healing Our  Waters – Great Lakes Coalition, to gain an understanding of the GLRI  and how it is implemented. Nonfederal stakeholders are state and local  governments, tribes, nongovernmental organizations, and academic  institutions that have received GLRI funds. We also attended the Eighth  Annual Great Lakes Restoration Conference in Cleveland in September  2012 to learn more about the GLRI and Great Lakes restoration, and  webinars to learn about the GLRI grant application process and how to  use GLAS.

To examine the methods that EPA has in place to assess GLRI progress,  we analyzed the Action Plan, documentation about GLAS, information  from GLAS about GLRI project measures of progress, information  provided by EPA on the sources of data for each of the plan’s measures  of progress, the draft GLRI Adaptive Science-Based Framework for Great  Lakes Restoration (draft Framework), and EPA’s Science Advisory  Board’s 2012 review of the Action Plan.

We interviewed EPA officials to  discuss their methods of assessing GLRI progress. We used the  interviews with Task Force agency officials described above, and we  conducted interviews with relevant officials from each of the Great Lakes  states—Illinois, Indiana, Michigan, Minnesota, New York, Ohio,  Pennsylvania, and Wisconsin—to discuss the Action Plan. We also  conducted interviews with subject matter experts, to obtain their views  about the achievability and usefulness of the Action Plan’s measures of  progress and related annual targets.

As part of our analysis of the Action Plan, we evaluated the extent to  which the long-term goals and objectives in the plan have corresponding  measures of progress. One analyst first compared the objectives for each  focus area with the goals. The analyst considered whether it appeared  that an objective would clearly contribute to attaining a goal. For example,  in the invasive species focus area, the objective of developing and  refining/piloting technologies that contain or control invasive species  appears to clearly contribute to attaining the goal of preventing the spread  of invasive species. The analyst also considered whether there was  consistent or similar language in any of the goals and objectives that  helped identify links between them. For example, the analysts examined if  aspects of a goal in one focus area could be identified in an objective in  the same focus area, such as in the toxic substances and areas of  concern focus area, we identified similar language between the objective  of reducing the concentrations of polychlorinated biphenyls (PCBs) in fish  through 2014 and the goal of reducing environmental levels of toxic  chemicals to the point that all restrictions on the consumption of Great  Lakes fish can be lifted. Objectives could correspond to multiple goals.  The analyst then compared the measures for each focus area to the  objectives and looked for consistent or similar language in any of them  that helped identify links between the objectives and measures. The  analyst considered whether a measure was closely related to an objective  and whether it appeared that progress toward at least part of the objective  could clearly be assessed by a corresponding measure of progress.  Measures could correspond to multiple objectives. We requested  additional information from EPA officials on goals, objectives, and  measures as needed to improve our understanding of them. A second  analyst examined the conclusions of the first. In cases where there were  initially disagreements between the two analysts regarding the  identification of linkages between goals, objectives, and measures, all  disagreements were resolved through analyst discussions. Ultimately,  there was 100 percent agreement between the analysts. In addition, we  evaluated the extent to which EPA and the Task Force agencies had  established an adaptive management plan for the GLRI by first reviewing  guidance from several Task Force agencies to identify key elements of  adaptive management. We then examined the extent to which the GLRI  Action Plan and draft Framework addressed those elements.

For our interviews with officials from each of the Great Lakes states, we  developed a set list of open-ended questions for these interviews to  obtain official’s views about the Action Plan, among other things. We  identified the state agencies that we would contact by starting with the list  of state agencies identified at EPA’s Great Lakes website as interested  parties. We then contacted officials from each interested party to  determine if their agency was the lead GLRI agency for the state or to  learn if we should contact a different agency. As a result of this process,  we identified the following as lead GLRI state agencies: the Illinois  Department of Natural Resources; the Indiana Department of  Environmental Management; the Michigan Department of Environmental  Quality; the Minnesota Pollution Control Agency; the New York  Department of Environmental Conservation; the Ohio Lake Erie  Commission; the Pennsylvania Department of Environmental Protection;  and, the Wisconsin Department of Natural Resources.

For the interviews with subject matter experts, we developed a set list of  questions about the Action Plan’s long-term goals, objectives, and  measures of progress. The experts we interviewed included state agency  officials, members of academia, and representatives of nongovernmental  organizations who had expertise in one or more of the Action Plan’s five  focus areas. We identified these experts by asking for recommendations  of at least three experts in each of the focus areas from 24  representatives of nonfederal Great Lakes stakeholders or Great Lakes  interest groups organizations: 12 were nonfederal attendees of the Eighth  Annual Great Lakes Restoration Conference that we selected randomly to  conduct interviews about the Action Plan and the GLRI, and 12 were  representatives of nonfederal organizations that we contacted as part of  learning more about the GLRI and the Great Lakes. We received  responses from 17 of the 24 individuals who recommended a total of 187  subject matter experts. We then created a list of the 33 experts who had  been recommended two or more times and invited 31 of them to  participate in interviews to obtain their views on the Action Plan goals,  objectives, and measures of progress, among other things. Of those 31  experts, 21 agreed to be interviewed: five experts in focus area one; six  experts in focus area two; three experts in focus area three; four experts  in focus area four; and three experts in focus area five. Because we used  a nonprobability sample, the information obtained from these interviews is  not generalizable to other individuals with expertise in the Action Plan  focus areas but provides illustrative information.

To examine the progress identified by the Task Force agencies and  nonfederal stakeholders, we took several steps: we reviewed the fiscal  year 2010 and 2011 GLRI progress reports that EPA and the other Task  Force agencies issued to Congress in April and March 2013,  respectively; we administered a web-based survey to each of the 205 nonfederal stakeholders that, as of October 2012, had received GLRI  funds from a Task Force agency and had a project identified in GLAS; we  used the interviews with officials from each Task Force agency identified  above; and, we visited several GLRI projects in Illinois.

We conducted a web-based survey of all of the nonfederal GLRI  stakeholders that have reported projects in GLAS, as of October 10,  2012, to identify examples of GLRI progress by obtaining their views on  how their GLRI projects have benefited the ecosystem, among other  things. The questionnaire used for this study is in appendix V. EPA  provided us with contact information for each of those stakeholders, and  we sent at least one e-mail to a point of contact from each stakeholder to  identify the best point of contact for our survey. We surveyed the universe  of the 205 nonfederal stakeholders that have projects in GLAS, as of  October 10, 2012, and received responses from 176 nonfederal GLRI  stakeholders for a response rate of 86 percent.

We designed draft questionnaires in close collaboration with a GAO  social science survey specialist. We conducted pretests with three  nonfederal GLRI stakeholders to help further refine our questions,  develop new questions, and clarify any ambiguous portions of the survey.  We conducted the pretests over the phone, and we selected one GLRI  nonfederal stakeholder that had received GLRI funds for one grant and  two GLRI nonfederal stakeholders that had each received GLRI funds for  multiple grants for the pretest.

We developed and administered the web-based questionnaire accessible  through a secure server, and we e-mailed unique identification numbers  and passwords to points of contact at the 205 nonfederal GLRI  stakeholders February 4, 2013. We sent follow-up e-mail messages  beginning February 11, 2013. Then we contacted all remaining  nonrespondents by telephone, starting February 26, 2013. The  questionnaire was available online until March 28, 2013. For questions  that should have been skipped but were not, we attempted to contact the  respondents for clarification and edited their responses where warranted.

Because this was not a sample survey, it has no sampling errors.  However, the practical difficulties of conducting any survey may introduce  errors, known as nonsampling errors. For example, difficulties in  interpreting a particular question, sources of information available to  respondents, or when entering data into a questionnaire or analyzing the  data can introduce unwanted variability into the survey results. We took  steps in developing our questionnaire, collecting the data, and analyzing it  to minimize these errors. In addition, as indicated above, social science  survey specialists designed the questionnaire in collaboration with GAO  staff that had subject matter expertise. We then conducted three pretests  to check that (1) the questions were clear and unambiguous, (2)  terminology was used correctly, (3) the questionnaire did not place an  undue burden on respondents, (4) the information could feasibly be  obtained, and (5) the survey was comprehensive and unbiased. We made  multiple contact attempts with nonrespondents during the survey by e- mail, and some nonrespondents were also contacted by telephone. When  we analyzed the data, an independent analyst checked all computer  programs. Since this was a web-based survey, respondents entered their  answers directly into the electronic questionnaire, eliminating the need to  key data into a database, minimizing error.

We conducted a computer-enabled content analysis to analyze  responses to the question “Please provide examples of how one or more  of your organization’s GLRI projects have benefitted the Great Lakes  ecosystem.” Of the 176 respondents, 163 provided information in  response to this question. We categorized the responses along two  dimensions: direct and indirect benefits, and observed or expected  benefits. We defined these categories based on whether respondents  reported that their organization’s GLRI projects resulted in changes in the  ecosystem, such as reduced beach closure days, or other types of  changes, such as improved understanding of the ecosystem, and if  respondents reported that they had observed the result or expected to  observe them a later time. One reviewer developed content categories  based on survey responses and, after obtaining agreement on the  categories from the second reviewer, assessed and coded each survey  response into those categories. The second reviewer examined the  coding. In cases where disagreements among the two reviewers  regarding the coding of responses into content categories were found, all  disagreements were resolved through reviewer discussion. Ultimately,  there was 100 percent agreement between the reviewers. In addition, we  conducted follow-up interviews by phone and e-mail with those survey  respondents whose examples we wanted to include in the report to collect  clarifying information, if necessary.

In addition to the survey, we used the interviews with Task Force agency  officials identified above to obtain information about GLRI progress. We  also visited several GLRI projects in Illinois. We traveled to Illinois  because EPA’s Great Lakes National Program Office is located in  Chicago. We met with representatives from two nonfederal GLRI  stakeholders who took us to the sites of their GLRI projects; the two  nonfederal GLRI stakeholders—the Chicago Park District and Waukegan  Harbor Citizens Advisory Group—were recommended to us by an official  from the Illinois Department of Natural Resources.

To examine the views of nonfederal stakeholders on factors, if any, that  may affect or limit GLRI progress, we used the web-based survey  described above. Specifically, we used the survey to obtain nonfederal  GLRI stakeholder views about factors that may have limited their ability to  carry out GLRI projects and factors that have the potential to affect the  restoration of Great Lakes health. As part of creating the survey, we  developed lists of factors that might limit GLRI project implementation  progress and factors that might limit the restoration of Great Lakes health  in general through interviews we conducted with 19 randomly selected  individuals at the Eight Annual Great Lakes Restoration Conference and  interviews we conducted with representatives from five nonfederal GLRI  stakeholders and one Great Lakes interest group. We narrowed the list of  factors that might limit GLRI project implementation progress to four  factors most often cited by interviewees as hindering their abilities to start  a project or to successfully carry out a project, and asked survey  respondents if they had experienced these factors and about the effects  of each of these factors on their GLRI projects. We narrowed the list of  factors that might limit the restoration of Great Lakes health in general to  the nine factors most often cited by grouping similar factors together and  eliminating those factors that are addressed by the Action Plan either  through Action Plan long-term goals, objectives, or measures of progress.  We eliminated those factors addressed by the Action Plan because this  meant they had already been identified by the GLRI as factors that had  the potential to limit restoration of Great Lakes health. We asked survey  respondents to identify the extent to which each of these factors had the  potential to limit the restoration of the health of the Great Lakes  ecosystem.

We also used the interviews with subject matter experts mentioned above  to obtain information about the factors that may limit progress by asking  them to identify the extent to which each of the same nine factors we  included in the survey had the potential to limit the restoration of the  health of the Great Lakes ecosystem.

We conducted this performance audit from June 2012 to September 2013  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

section_title: Appendix II: Comments from the Environment Protection Agency

section_title: Appendix III: Comments from the Department of the Interior

section_title: Appendix IV: Comments from the Department of Agriculture

section_title: Appendix V: Survey Questions
paragraphs: We conducted a web-based survey of nonfederal GLRI stakeholders that  have reported projects in the Great Lakes Accountability System, as of  October 10, 2012, using all of the questions below as stated here. Non- federal stakeholders are state and local governments, tribes,  nongovernmental organizations, and academic institutions that that have  received GLRI funds.

section_title: Appendix VI: Great Lakes Restoration Initiative Action Plan Long-term Goals, Objectives, and Measures of Progress for Each of the Five Focus Areas
paragraphs: The GLRI Action Plan for fiscal years 2010 to 2014 is organized by five  focus areas that, according to the federal agencies responsible for  implementing the GLRI, encompass the most significant environmental  problems in the Great Lakes: (1) toxic substances and areas of concern;  (2) invasive species; (3) nearshore health and nonpoint source pollution;  (4) habitat and wildlife protection and restoration; and (5) accountability,  education, monitoring, evaluation, communication and partnerships. Each  focus area includes several long-term goals to address these problems,  as well as objectives to be completed within the 5 years of the plan and  measures of progress to ensure that efforts are on track to meet the long- term goals.
subsections: section_title: Focus Area One, Toxic Substances and Areas of Concern
subsections: section_title: Long-term Goals
paragraphs: Goal 1: Areas of concern are cleaned up, restoring the areas and  removing the beneficial use impairments.

Goal 2: The release of toxic substances in toxic amounts is prevented  and the release of any or all persistent toxic substances to the Great  Lakes Basin ecosystem is virtually eliminated.

Goal 3: Exposure to toxic substances from historically contaminated  sources is significantly reduced through source reduction and other  exposure reduction methods.

Goal 4: Environmental levels of toxic chemicals are reduced to the  point that all restrictions on the consumption of Great Lakes fish can  be lifted.

Goal 5: The health and integrity of wildlife populations and habitat are  protected from adverse chemical and biological effects associated  with the presence of toxic substances in the Great Lake Basin.

section_title: Objectives
paragraphs: By 2014, delist five areas of concern.

By 2014, 46 beneficial use impairments will be removed in areas of  concern.

By 2011, 15 million pounds of electronic waste and 15 million pills of  unwanted medicines will be collected or their release will have been  prevented.

By 2014, 45 million pounds of e-waste, 45 million pills of unwanted  medicines, and 4.5 million pounds of household hazardous waste in  the Great Lakes Basin will have been collected or their release will  have been prevented.

By 2014, 9.4 million cubic yards of contaminated sediments will be  remediated.

Through 2014, an annual average of up to 5 percent annual decline  will be maintained or improved for the trend (year 2000 and on) in  average concentrations of PCBs in whole lake trout and walleye  samples.

section_title: Measures of Progress
paragraphs: Number of areas of concern in the Great Lakes where all  management actions necessary for delisting have been implemented  (cumulative).

Area of concern beneficial use impairments removed (cumulative).

Beneficial use impairment delisting project starts at areas of concern  (cumulative).

Cubic yards (in millions) of contaminated sediment remediated in the  Great Lakes (cumulative).

Pollution (in pounds) collected through prevention and waste  minimization projects in the Great Lakes Basin (cumulative).

These projects represent on-the-ground actions that are being implemented in order to  remove beneficial use impairments. For example, sediment removals, Superfund  cleanups, habitat projects and others.

This is an existing measure [used in the agency’s performance plan and performance  report, which are required by the Government Performance Results Act, as amended].

Cumulative percentage decline for the long term trend in average  concentrations of PCBs in Great Lakes fish.

section_title: Focus Area Two, Invasive Species
subsections: section_title: Long-term Goals
paragraphs: Goal 1: The introduction of new invasive species to the Great Lakes  Basin ecosystem is eliminated, reflecting a “zero tolerance policy”  toward invasives.

Goal 2: The risk of introduction of species, which are imported for  various uses, in the Great Lakes is minimized.

Goal 3: The spread of invasive species, by means of recreational  activities, connecting waterways, and other vectors, beyond their  current range is prevented.

Goal 4: A comprehensive program for detection and tracking newly  identified invasive species in the Great Lakes is developed and  provides up-to-date critical information needed by decision makers for  evaluating potential rapid response actions.

Goal 5: An effective, efficient and environmentally sound program of  integrated pest management for invasive species is developed and  implemented, including program functions of containment, eradication,  control, and mitigation.

section_title: Objectives
paragraphs: By 2011, eight state aquatic nuisance species management plans will  be established or revised to include rapid response capabilities. By  2014, eight state-based, multiagency rapid response plans will be  implemented and 22 mock exercises to practice responses carried out  under those plans and/or actual response actions will be completed.

Six technologies that prevent the introduction of invasive species and  four technologies that either contain or control invasive species will be  developed or refined and piloted by 2011. Ten technologies that  prevent the introduction of invasive species and five technologies that  either contain or control invasive species will be developed or refined  and piloted by 2014.

By 2011, methodology and protocols will be piloted for the  coordinated monitoring methodology and shared protocols for  basinwide invasive species surveillance. By 2014, a basinwide  surveillance program with shared sampling protocols and  methodologies to provide early detection of nonnative species will be  operational.

By 2014, a 40 percent reduction in the yearly average rate of invasive  species newly detected in the Great Lakes ecosystem will be  achieved, compared with the period 2000-2009.

By 2014, invasive species populations within the Great Lakes  ecosystem will have been controlled and reduced, as measured in  populations controlled to a target level in 6,500 acres of managed  area and by removing 5,000 pounds of invasive species from the  Great Lakes ecosystem.

By 2014, approximately 10 million recreation and resource users will  be educated on best practices that prevent the introduction and  spread of invasive species.

section_title: Measures of Progress
paragraphs: Rate of nonnative species newly detected in the Great Lakes  ecosystem.

Acres managed for populations of invasive species controlled to a  target level (cumulative).

Number multiagency plans established, mock exercises to practice  rapid responses carried out under those plans, and/or actual rapid  response actions (cumulative).

Number of recreation and resource users contacted on best practices  that prevent the introduction and spread of invasive species  (cumulative).

section_title: Focus Area Three, Nearshore Health and Nonpoint Source Pollution
subsections: section_title: Long-term Goals
paragraphs: Goal 1: Nearshore aquatic communities consist of healthy, self- sustaining plant and animal populations dominated by native and  naturalized species.

Goal 2: Land use, recreation, and economic activities are managed to  ensure that nearshore aquatic, wetland, and upland habitats will  sustain the health and function of natural communities.

Goal 3: The presence of bacteria, viruses, pathogens, nuisance  growths of plants or animals, objectionable taste or odors, or other  risks to human health are reduced to levels in which water quality  standards are met and beneficial uses attained to protect human use  and enjoyment of the nearshore areas.

Goal 4: High-quality bathing beach opportunities are maintained by  eliminating impairments from bacterial, algal, and chemical  contamination; effective monitoring for pathogens; effective modeling  of environmental conditions, where appropriate; and timely  communications to the public about beach health and daily swimming  conditions.

Goal 5: A significant reduction in soil erosion and the loading of  sediments, nutrients, and pollutants into tributaries is achieved  through greater implementation of practices that conserve soil and  slow overland flow in agriculture, forestry and urban areas.

Goal 6: High quality, timely and relevant information about the  nearshore areas is readily available to assess progress and to inform  enlightened decision making.

section_title: Objectives
paragraphs: By 2010, EPA will compile and map the highest priority watersheds for  implementation of targeted nonpoint source pollution control  measures.

By 2014, remediation, restoration and conservation actions in at least  one targeted watershed in each Great Lake Basin will control erosion,  reduce nutrient runoff from urban and agricultural sources, and  improve habitat to protect nearshore aquatic resources.

By 2014, a baseline will be established for total suspended solids  loadings from targeted tributaries.

By 2014, a measurable decrease will be achieved in soluble  phosphorous loading from 2008 levels in targeted tributaries.

By 2014, the causes of nutrient-related nearshore biological  impairments will be better understood and, following local or  watershed remedial actions, the number and severity of incidences of  harmful algal blooms, avian botulism, and/or excessive Cladophora  growth will be significantly reduced from 2008 levels.

By 2014, a comprehensive nearshore monitoring program will have  been established and implemented, including a publicly accessible  reporting system, based on a suite of environmental indicators.

By 2014, 50 percent of high-priority Great Lakes beaches will have  been assessed using a standardized sanitary survey tool to identify  sources of contamination.

By 2014, 20 percent of high-priority Great Lakes beaches will have  begun to implement measures to control, manage or remediate  pollution sources identified through the use of sanitary surveys.

By 2014, rapid testing or predictive modeling methods (to improve the  accuracy of decisions on beach postings to better protect public  health) will be employed at 33 percent of high-priority beaches.

By 2014, the area of agricultural lands in conservation and/or utilizing  conservation tillage practices will increase by 50 percent over 2008  levels.

section_title: Measures of Progress
paragraphs: Five-year average annual loadings of soluble reactive phosphorous  from tributaries draining targeted watersheds.

Percentage of beaches meeting bacteria standards 95 percent or  more of beach days.

Extent (sq. miles) of Great Lakes harmful algal blooms.

Annual number of days U.S. Great Lakes beaches are closed or  posted due to nuisance algae.

Annual volume of sediment deposition in defined harbor areas in  targeted watersheds (cubic yards).

Acres in Great Lakes watershed with U.S. Department of Agriculture  conservation practices implemented to reduce erosion, nutrients  and/or pesticide loading under Farm Bill programs.

This metric will be added to national surveys for beach managers for 2010. Nuisance  algae can include Cladophora, harmful algal blooms or other species, all of which are  believed to be aggravated by elevated levels of phosphorous in the water.

U.S. Army Corps of Engineers dredges the federal shipping channel at Toledo Harbor  each year. This area receives the highest rate of sedimentation in the Great Lakes,  coming from the Maumee River watershed. Even small improvements in the rate of  sedimentation here would reflect considerable efforts in the watershed to reduce erosion  and farm runoff. Alternately, the Corps conducts bathymetric surveys of commercial  harbors each year, from which the volume of new fluvial sediment can be calculated for  targeted watersheds. Because the Corps does not dredge every location of every harbor  each year, the estimated accumulation from a designated area over time will reflect the  relative amount of sediments deposited from the tributary. This approach is currently in  development.

section_title: Focus Area Four, Habitat and Wildlife Protection and Restoration
subsections: section_title: Long-term Goals
paragraphs: Goal 1: Protection and restoration of Great Lakes aquatic and  terrestrial habitats, including physical, chemical, and biological  processes and ecosystem functions, maintain or improve the  conditions of native fish and wildlife.

Goal 2: Critical management activities (such as stocking native fish  and other aquatic species, restoring access of migratory fish species  at fish passage barriers, and identifying and addressing diseases)  protect and conserve important fish and wildlife populations.

Goal 3: Sound decision making is facilitated by accessible, site  specific and landscape-scale baseline status and trend information  about fish and wildlife resources and their habitats.

Goal 4: High-priority actions identified in strategic plans (such as state  and federal species management, restoration and recovery plans,  Lakewide Management Plans, Remedial Action Plans, and others) are  implemented, lead to the achievement of plan goals, and reduce the  loss of fish and wildlife and their habitats.

Goal 5: Development activities are planned and implemented in ways  that are sensitive to environmental considerations and compatible with  fish and wildlife and their habitats.

section_title: Objectives
paragraphs: By 2014, 4,500 miles of Great Lakes rivers and tributaries will be  reopened and 450 barriers to fish passage will be removed or  bypassed.

By 2014, 82 percent of recovery actions for federally listed priority  species will be implemented.

By 2014, 53 percent of populations of native aquatic non-threatened  and endangered species are self-sustaining.

By 2014, 97,500 acres of wetlands, wetland-associated uplands, and  high-priority coastal, upland, urban, and island habitats will be  protected, restored or enhanced.

By 2014, 100 percent of U.S. coastal wetlands in the Great Lakes  Basin will be assessed.

By 2014, 30 habitat-related beneficial use impairments will be delisted  across the areas of concern.

section_title: Measures of Progress
paragraphs: Miles of rivers reopened for fish passage.

Number of fish passage barriers removed or bypassed.

Number of species delisted due to recovery.

Percentage of recovery actions implemented for priority listed species.

Percentage of populations of native aquatic non-threatened and  endangered species self-sustaining in the wild.

Number of acres of wetlands and wetland-associated uplands  protected, restored and enhanced.

Number of acres of coastal, upland, and island habitats protected,  restored and enhanced.

Percent of U.S. coastal Great Lakes wetlands assessed.

Number of habitat-related beneficial use impairments removed from  the 27 U.S. areas of concern so impaired.

section_title: Focus Area Five, Accountability, Education, Monitoring, Evaluation, Communication and Partnerships
subsections: section_title: Long-term Goals
paragraphs: Goal 1: A cooperative monitoring and observing system provides a  comprehensive assessment of the Great Lakes ecosystem.

Goal 2: The necessary technology and programmatic infrastructure  supports monitoring and reporting, including Great Lakes Restoration  Initiative project deliverables by all agencies and participating  stakeholders. Data and information are provided in reports that are  public friendly, timely and available on the Internet. Reports present  integrated and scaled data from watersheds to lakes to Great Lakes  basinwide.

Goal 3: Increase outreach and education for the Great Lakes, and  provide ongoing K-12 education for students to understand the  benefits and ecosystem functions of the Great Lakes so they are able  to make decisions to ensure that restoration investments are  enhanced over time.

Goal 4: Expand the range of opportunities for Great Lakes  stakeholders and citizens to provide input to the governments and  participate in Great Lakes issues and concerns.

Goal 5: Work under the goals and objectives of the Great Lakes  Water Quality Agreement is coordinated between the United States  and Canada through Lakewide Management Plans and other  binational processes.

section_title: Objectives
paragraphs: By 2011, opportunities for collaboration, planning, data accessibility  and accountability will be increased through the expanded use of  Internet-based technology.

By 2011, an Accountability System will be developed and  implemented for the Initiative. The system will integrate and make  transparent strategic planning, budgeting, and results monitoring.

By 2011, a satellite remote sensing program will be implemented to  assess Great Lakes productivity and biological (e.g., algal bloom)  events.

By 2011, outreach and education efforts are increased, including  identifying and revising existing curricula to incorporate sustainable  education needs for the Great Lakes that meet state and other  relevant learning standards.

By 2011, a refined suite of science-based indicators for development  of a comprehensive assessment of Great Lakes ecosystem health will  be identified, monitoring programs for those indicators will begin to be  implemented, and restoration and protection actions tied to those  assessments and programs assured.

By 2011, social media access opportunities for basinwide public  involvement in the Initiative will be in place.

By 2012, education efforts under existing curricula that meet state and  other relevant learning standards will be coordinated across states,  and a system for tracking student and teacher outreach (quantitatively  and qualitatively) for their use.

By 2012, improved coordination with Canada will take place for  programs under the Great Lakes Water Quality Agreement,  particularly under the Lakewide Management Plans, which will result  in the achievement of 5-10 priority Lakewide Management Plans  goals and actions.

By 2014, a statistically valid and comprehensive assessment, using a  probability-based design, of Great Lakes water resources, will be  established. The system will integrate shipboard monitoring, remote  sensing, automated sampling, and other monitoring or observing  efforts. By 2016, the system will be in place for all of the Great Lakes  and it will be capable of providing a scientifically justifiable  assessment of Great Lakes water resources.

By 2014, timely data and information will be provided to decision  makers at multiple scales within a framework of established baselines,  targets, indicators of progress, and monitoring.

section_title: Measures of Progress
paragraphs: Improvement in the overall aquatic ecosystem health of the Great  Lakes using the Great Lakes 40-point scale.

Number of priority Lakewide Management Plans projects that are  completed.

Number of educational institutions incorporating new or existing Great  Lakes protection and stewardship criteria into their broader  environment education curricula.

section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Steven Elstein, Assistant  Director; Krista Breen Anderson; Cheryl Arvidson; Mark Braza; Lisa L.  Fisher; Stuart M. Kaufman; Armetha Liles; Marya Link; Michelle K.  Treistman; and Wayne Turowski made significant contributions to this  report.


Question-summary annotations: questions: question: What is the relationship between the Task Force agencies and the Great Lakes Restoration Initiative?
answer: The Task Force agencies use the Action Plan to implement the Great Lakes Restoration Initiative (GLRI) and use an interagency process to enter into agreements among themselves to identify GLRI projects and with other stakeholders to implement GLRI projects.
child_questions: question: What does the Action Plan include?
answer: The Action Plan includes guidance for implementing the GLRI in five focus areas (such as invasive species and habitat and wildlife protection and restoration) that encompass the most significant environmental problems in the Great Lakes.
child_questions: question: What does each focus area include?
answer: Each focus area includes, among other things, long-term goals, objectives to be achieved by fiscal year 2014, and 28 measures of progress that have annual targets for fiscal years 2010 to 2014.

questions: question: For what does EPA use the Action Plan's measures?
answer: EPA uses the Action Plan's measures to assess GLRI progress.
child_questions: question: How successful is this assessment?
answer: However, its methods may not produce comprehensive and useful assessments of GLRI progress for several reasons.
child_questions: question: What is the relationship between goals and measures in this plan?
answer: Among them, some of the goals and objectives do not link to any measures and, as a result, it is unclear how EPA will be able to assess progress toward them.
child_questions: question: What is one example of this gap?
answer: For example, one measure tracks the reduction in concentrations of polychlorinated biphenyls (PCB) in fish as part of the goal to lift all restrictions on consumption of Great Lakes fish. However, stakeholders reported that the measure is too narrow and that mercury and other contaminants need to be addressed as well. Consequently, reducing PCB concentrations in fish is not likely to lead to the desired result of lifting all Great Lakes fish consumption restrictions.

question: What might be the ramifications of this?
answer: Without useful measures, EPA may not be able to determine that GLRI efforts are producing the desired results.

questions: question: What do the Task Force's reports state?
answer: In spring 2013, the Task Force agencies issued two reports about GLRI progress in fiscal years 2010 and 2011, which state whether the targets for the Action Plan's 28 measures were being met (e.g., 15 of 28 measures met or exceeded in fiscal year 2011), but the reports include few specific examples of progress.
child_questions: question: What did GAO's research focus on?
answer: As a result, GAO sought further insights into such progress by surveying nonfederal GLRI stakeholders.
child_questions: question: How did respondents see their projects in relationship to the Great Lakes ecosystem?
answer: Overall, 87 percent of respondents cited at least one example of how one or more of their projects had, or was expected to, benefit the Great Lakes ecosystem.

question: What is GAO's stance regarding the quantification of restoration progress?
answer: GAO and others have reported that quantifying overall Great Lakes restoration progress is difficult, that the environmental conditions of each lake are unique, and, according to a 2006 U.N. report, it is often impossible to attribute specific environmental changes to specific projects or programs.

questions: question: What factors limit GLRI progress?
answer: In response to GAO's survey, among the factors respondents most often cited as potentially limiting GLRI progress are several outside the scope of the Action Plan, such as inadequate infrastructure for wastewater or stormwater and the effects of climate change. These factors could negatively affect GLRI restoration efforts.
child_questions: question: What is an example of one such factor?
answer: For example, as a result of climate change, warming water temperatures can lead to increased numbers of aquatic invasive species and a decline in native ones, a GLRI focus area.
child_questions: question: How has EPA addressed this problem?
answer: In 2012, EPA took steps to incorporate climate change considerations into a small number of GLRI projects but has yet to decide if the GLRI will consider climate change impacts on all GLRI projects.

question: How does the Action Plan deal with these factors?
answer: The Action Plan touches on these factors but does not state how they will be addressed.
child_questions: question: Why must EPI address these factors?
answer: Without addressing these factors in the next Action Plan, EPA will not be able to more fully account for their impacts on GLRI restoration efforts.

questions: question: How is GLRI administered?
answer: Approximately $1.3 billion has been appropriated to the GLRI, created in fiscal year 2010, which an interagency Task Force of 11 federal agencies, chaired by the EPA Administrator, oversees.

question: What did the Task Force's Action Plan propose?
answer: In 2010, the Task Force issued an Action Plan for fiscal years 2010 to 2014 to develop a comprehensive approach to restoring the health of the Great Lakes ecosystem.

question: What was GAO asked to review?
answer: GAO was asked to review the GLRI.
child_questions: question: What does this report examine?
answer: This report examines (1) how the GLRI is implemented by the Task Force agencies and other stakeholders, (2) the methods that EPA has in place to assess GLRI progress, (3) the progress identified by the Task Force agencies and nonfederal stakeholders, and (4) the views of nonfederal stakeholders on factors, if any, that may affect or limit GLRI progress.

question: What is GAO's methodology?
answer: GAO analyzed the Action Plan, surveyed 205 non-federal recipients of GLRI funding, and interviewed Task Force agency officials and nonfederal stakeholders.