Great Lakes Restoration Initiative: Improved Data Collection and Reporting Would Enhance Oversight
Released: 2015-07-30T00:00:00

Letter

Background

The Great Lakes Basin covers approximately 300,000 square miles, encompassing Michigan and parts of Illinois, Indiana, Minnesota, New York, Ohio, Pennsylvania, Wisconsin, and the Canadian province of Ontario (see fig. 1), as well as lands that are home to more than 40 Native American tribes. It includes the five Great Lakes and a large land area that extends beyond the Great Lakes, including their watersheds, tributaries, and connecting channels. The Great Lakes contain nearly 90 percent of the surface freshwater in North America and 20 percent of the surface freshwater in the world. The Great Lakes provide drinking water; recreation opportunities, such as swimming, fishing, and boating; and economic benefits, including tourism, agriculture, and shipping, for an estimated 40 million people. In addition, nearly 7 percent of U.S. agricultural production comes from the basin, according to EPA.

History of Restoration Activities

Numerous environmental stresses threaten the health of the Great Lakes and adjacent land within the Great Lakes Basin. The Great Lakes has long been an area that attracted development, population, industry, and commerce, starting with the canals that joined the lakes to the eastern seaboard and allowed goods to be trafficked and traded between the Midwest and eastern states. Various environmental quality issues, particularly water quality pollution and contaminated sediments, have resulted from mining, timber harvest, steel production, chemical production, and other industrial activities that developed around the Great Lakes. Currently, all of the Great Lakes and the majority of the water bodies in the region are under fish consumption advisories, issued by state and provincial health agencies, due to mercury pollution primarily from coal-fired power plants. In addition, the fertile soil in the surrounding states makes them highly productive agricultural areas, and this has resulted in large amounts of nutrients such as phosphorus and nitrogen— as well as sediment, pesticides, and other chemicals—running off into the Great Lakes. Moreover, large population centers on both sides of the U.S. and Canadian border use the Great Lakes to discharge wastewater from treatment plants, which also introduces nutrients into the Great Lakes. Even with progress in reducing the amount of phosphorus in the lakes through mitigation techniques used in the 1970s, harmful algal blooms are once again threatening the Great Lakes Basin. These are a result of increases in phosphorus and nitrogen entering the lakes from nonpoint sources of runoff from urban and rural areas.

The United States has long recognized the threats facing the Great Lakes and has developed agreements and programs to fund and support restoration actions, including the following: In 1972, the United States and Canada agreed to take action by signing the Great Lakes Water Quality Agreement to restore, protect, and enhance the water quality of the Great Lakes to promote the ecological health of the Great Lakes Basin. The countries signed another Great Lakes Water Quality Agreement in 1978, which was amended several times. For example, most recently, in 2012, the nations added provisions to the agreement to address the effects of climate change, among other things.

In 1987, an amendment to the Great Lakes Water Quality Agreement resulted in the United States and Canada formally identifying a total of 43 severely degraded locations in the Great Lakes Basin as specific Areas of Concern, 31 of which are located entirely or partially in the United States. These areas are 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 1987 amendment also required the nations to develop and implement remedial action plans for the Areas of Concern.

In 2002, the Great Lakes Legacy Act authorized EPA to carry out sediment remediation projects in the 31 Areas of Concern located entirely or partially in the United States, among other things. For fiscal years 2004 through 2009, EPA’s budget authority totaled $162 million for work under this act, according to an OMB report.

Of the 12 Areas of Concern located entirely in Canada, 3 have been delisted.

Areas of Concern had been completed, as of October 2014, but formal delisting had not yet occurred, according to EPA.

The United States also recognized the growing pressures on the fish and wildlife resources of the Great Lakes Basin and developed plans to address these. For example, federal and state agencies became aware of the growing threat of invasive species, such as the sea lamprey, which is a parasite that can each kill up to 40 pounds of fish in its lifetime and was a major cause of the collapse of lake trout, whitefish, and chub populations in the Great Lakes during the 1940s and 1950s. Again, the United States took a series of actions as follows:

The Great Lakes Fish and Wildlife Restoration Act of 1990 directed the Fish and Wildlife Service to conduct a comprehensive study of the status of, and the assessment, management, and restoration needs of, the Great Lakes Basin’s fishery resources and to develop proposals for implementing the study’s recommendations.

The Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 established the Aquatic Nuisance Species Task Force and required it to develop and implement a program for waters of the United States to prevent introduction and dispersal of aquatic nuisance species; to monitor, control, and study such species; and to disseminate related information. The act also directed the Great Lakes Commission to establish the Great Lakes Panel on Aquatic Nuisance Species and directed the panel to identify Great Lakes aquatic nuisance species priorities and coordinate, where possible, aquatic invasive species program activities in the region that are not conducted under the act, among other things. Members of the panel, which meets twice a year, include U.S. and Canadian federal agencies, the eight Great Lakes states and the provinces of Ontario and Québec, local communities, and tribal authorities.

In 2009, the President created the Asian Carp Regional Coordinating Committee to coordinate efforts, including local, state, federal, and international efforts, to prevent Asian carp from spreading and becoming established. The term Asian carp refers collectively to four species of carp—including bighead and silver carp—that are native to Asia and were first introduced into the United States in 1963. Their rapid expansion and population increase can decrease populations of native aquatic species, in part by consuming vast areas of aquatic plants that are important as food and spawning and nursery habitats. Efforts to prevent Asian carp from entering the Great Lakes include the capture and removal of these fish from nearby waterways (see fig. 2). Since 2010, the committee has issued an annual Asian Carp Control Strategy Framework that outlines efforts to support activities that will directly prevent the introduction and establishment of Asian carp populations in the Great Lakes.most recent framework, for 2014, in June 2014.

Organization of GLRI Projects, Reports, and Data

GLRI is implemented through a number of projects, large and small, carried out by the Task Force agencies or recipients of GLRI funds. One way that the Task Force agencies conduct GLRI work is to use financial agreements with nonfederal entities, such as grants and cooperative agreements, that provide funds to conduct specific projects. Grants and cooperative agreements are to be used when the principal purpose of a transaction is to accomplish a public purpose or action authorized by federal statute.using agency employees to carry out projects—which we refer to as Another way that the agencies conduct GLRI work is by agency-conducted work—or contracting with nonfederal entities to carry out projects. Contracts are to be used when the principal purpose is to purchase property or services for the direct benefit or use of the federal government. OMB is responsible for developing governmentwide guidance for the management of grants and cooperative agreements. Until December 2013, OMB provided guidance in the form of circulars for specific grants management areas to different types of grantees. In December 2013, OMB consolidated its grants management circulars into a single uniform guidance document. Requirements for contracts are found in the Federal Acquisition Regulation (FAR). Among other things, OMB’s circulars direct federal agencies to require progress and financial reports from academic institutions, nonprofit organizations, and state, local, and tribal entities that receive grants or are parties to cooperative agreements. For contracts, agencies can require such reports from contractors.

We provided a draft of this report to EPA in May 2015. In response, EPA officials informed us that the agency had replaced GLAS with the Environmental Accomplishments in the Great Lakes (EAGL) information system. Because EPA did not alert us to this new system until June 2015, we could not include a review of EAGL in this report. fields and instructions on how to enter project data into GLAS. GLAS was not a financial management system, and the Task Force agencies used their own financial management systems to track funding.

In our September 2013 report, we conducted a survey of nonfederal recipients of GLRI funding and found that several factors outside the scope of the Action Plan can limit GLRI progress. These factors include inadequate infrastructure for wastewater or storm water treatment and the effects of climate change. We also found that EPA and the Task Force agencies had not fully established a plan to guide an adaptive management process for the GLRI that could allow them to assess the We effectiveness of GLRI actions and, if needed, adjust their efforts.recommended, among other things, that the EPA Administrator, in coordination with the Task Force, address how factors outside the scope of the Action Plan that may limit progress, such as the effects of climate change, may affect GLRI efforts to restore the Great Lakes, and establish an adaptive management plan. EPA generally agreed with our conclusions and recommendations. In September 2014, EPA and the Task Force issued the 2015-2019 Action Plan, which includes ensuring climate resiliency of GLRI-funded projects as an objective in one of its focus areas. As of March 2015, EPA and the Task Force were in the process of revising a draft of an adaptive management framework for the 2015-2019 Action Plan.

$1.68 Billion Was Made Available for the GLRI in Fiscal Years 2010 through 2014, with $1.15 Billion Expended on 2,123 Projects as of January 2015

In fiscal years 2010 through 2014, $1.68 billion of federal funds was made available for the GLRI, and as of January 2015, EPA had allocated nearly all of the $1.68 billion, and the Task Force agencies had expended $1.15 billion on 2,123 GLRI projects. The five agencies we reviewed in greater detail had expended $993 million of the $1.43 billion allocated to them in fiscal years 2010 through 2014 on 1,696 GLRI projects, as of January 2015, and conducted those projects through a combination of work done by agency staff and a variety of GLRI funding recipients.

EPA Has Allocated Almost All of the $1.68 Billion Made Available for the GLRI in Fiscal Years 2010 through 2014, and Task Force Agencies Have Expended $1.15 Billion

Of the $1.68 billion made available for the GLRI in fiscal years 2010 through 2014, EPA had allocated $1.66 billion as of January 2015. EPA conducts and funds GLRI work itself and allocates GLRI funds to the other Task Force agencies responsible for carrying out GLRI work. As of January 2015, the Task Force agencies had obligated $1.61 billion and expended $1.15 billion, or about 68 percent of the funds made available for the GLRI in fiscal years 2010 through 2014, on 2,123 projects. Figure 3 shows the funds made available for the GLRI in fiscal years 2010 through 2014 and the extent to which they had been allocated, obligated, and expended by all Task Force agencies as of January 2015.

The Task Force agencies have not expended all of the funds made available for the GLRI for several reasons, chief among them being that many projects take several years to complete. Also, GLRI funds are available for obligation for the fiscal year the appropriation was made, and the successive fiscal year. After these 2 fiscal years of availability, GLRI funds can be used for 7 additional years to liquidate and adjust those obligations. In addition, final payments are made from the agencies to recipients after projects are completed. Furthermore, as we found in September 2013, weather events, among other things, caused some GLRI projects to be completed later than planned.

In addition to the GLRI, federal agencies have expended other funds on Great Lakes restoration activities, such as reducing atmospheric deposition and controlling the generation, transportation, storage, and disposal of hazardous wastes. GLRI funds allocated, obligated, and expended, data on other funds received, obligated, and expended by federal agencies for Great Lakes restoration activities are not easily available for comparison. Specifically, OMB’s budget crosscut reports have not identified federal agencies’ obligations and expenditures for Great Lakes restoration activities, as required by several appropriations laws since fiscal year 2008. Most recently, the Consolidated Appropriations Act for Fiscal Year 2014 required OMB to identify, among other things, (1) all funds received and obligated by all federal agencies for Great Lakes restoration activities during the current and previous fiscal years and (2) all federal government expenditures in each of the 5 prior fiscal years for these activities. Instead, the reports presented information on each agency’s budget authority for these activities. According to OMB staff, the budget crosscut reports did not report these obligations and expenditures because providing that information is labor-intensive and time-consuming. These staff also said that the information would be outdated and of little value by the time it would be released.

Atmospheric deposition 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. Hazardous waste is most often a by-product of manufacturing and can threaten human and ecosystem health when released into the air, water, or land. congressional decision makers. Without this information in OMB’s budget crosscut reports, which is required to be included by law, it is not possible for decision makers to view GLRI funding in the context of the funding of overall Great Lakes restoration activities, because information on such activities would only be available from each agency, making less information readily available for congressional oversight.

Five Task Force Agencies Funded 1,696 GLRI Projects, with Work Conducted by Agency Staff and a Variety of GLRI Funding Recipients

Of the $1.66 billion EPA allocated to all Task Force agencies, as of January 2015, the five Task Force agencies we reviewed were allocated $1.43 billion. These agencies had obligated $1.38 billion and expended $993 million, or about 69 percent of their allocations (see fig. 4), on 1,696 GLRI projects.

Using information from EPA’s GLAS database as of July 2014 for GLRI funds made available in fiscal years 2010 through 2013, we found that the five Task Force agencies we reviewed funded a total of 1,558 GLRI projects using GLRI funds as of July 2014. As shown in table 2, EPA and the Fish and Wildlife Service funded the most projects as of July 2014.

To use GLRI funds on restoration activities, the Task Force agencies conduct the work themselves or enter into financial agreements with other entities to conduct the work, primarily through grants, cooperative agreements, or contracts. The different types of financial agreements have different purposes. For example, EPA officials noted that the distinguishing factor between a grant and a cooperative agreement is the degree of federal involvement in project activities. A single GLRI project in GLAS can involve agency-conducted work, one or more of the types of financial agreements, or a combination of these. Using data we obtained from the five agencies reviewed, we found that the extent to which the agencies used each type of financial agreement in obligating their GLRI funds made available in fiscal years 2010 through 2013 varies by agency (see fig. 5). For example, the Corps primarily used contracts, and NOAA primarily used grants and cooperative agreements. NRCS used financial assistance contracts with agricultural producers to carry out conservation practices on their land.

GLRI projects in GLAS can have multiple recipients that received GLRI funds directly from the Task Force agencies. These recipients include federal entities; state, local, or tribal entities; nongovernmental organizations; academic institutions; and others, such as agricultural producers and private landowners. In addition, a recipient may award a portion of its funds to subrecipients, such as universities, to help carry out the work, which means that a single GLRI project may also have multiple subrecipients. Figure 6 shows an example of the distribution of funds for a 2011 GLRI project with multiple funding recipients and subrecipients.

Table 3 shows the number of GLRI projects funded with GLRI funds made available in fiscal years 2010 through 2013 by the five agencies by type of recipient as of July 2014. The type of GLRI recipients vary depending on the agency and financial agreements involved. For example, NOAA has entered into agreements with all of these recipient types, with the exception of private landowners and agricultural producers, and the Corps has conducted all of its work itself or through contracts.

Task Force Process for Identifying GLRI Work and Funding Has Evolved to Emphasize Interagency Discussion

The Task Force process for identifying GLRI work and funding generally includes four steps and has evolved from an agency-by-agency process to one that emphasizes interagency discussion. This evolution began in fiscal year 2012 when the Task Force created subgroups to identify and fund work to address three priority issues: (1) cleaning up and delisting Areas of Concern, (2) preventing and controlling invasive species, and (3) reducing phosphorus runoff that contributes to harmful algal blooms. For fiscal year 2015, the Task Force created additional subgroups to discuss and agree on work for other areas. EPA officials told us that funding work for the three priority issues has led to some accelerated restoration results.

Selected Task Force Agencies Identified GLRI Work and Funding Using Four General Steps

EPA officials described four steps that Task Force agencies generally followed to identify GLRI work and funding, and the five agencies we reviewed followed these steps. The steps are: (1) agency identification of GLRI work; (2) Task Force agreement on scope and funding for agencies’ work; (3) solicitation of proposals for projects designed to carry out agencies’ GLRI work, if the work was to be conducted by entities other than the agencies; and (4) selection of projects.

EPA officials told us that the first step generally occurred 2 years before the fiscal year in which the work was to be carried out, in order to coincide with the federal budget cycle. During that step, the officials told us that the agencies each did an internal analysis to identify GLRI work that they wanted to conduct in that fiscal year. For example, FWS officials told us that the agency’s regional officials coordinated to identify new work that the agency planned to do in order to achieve its goals and then compared this work with 2010-2014 Action Plan goals to identify those projects that The Corps’ approach to this step was different; also met the goals.according to Corps officials, they selected projects that were already planned and ready to be conducted, and that were compatible with the 2010-2014 Action Plan. At this point, agency officials also identified the type of financial agreements they were likely to use to conduct the work or whether the agency would conduct the work itself.

For the second step, the five agencies we reviewed held discussions with the Task Force and agreed on the work that would be done in a given fiscal year, as well as the amount of GLRI funds that would be needed to conduct that work. In general, once the agencies made a final determination of the work they would do in a fiscal year, and the GLRI funds that would be made available, each agency entered into an interagency agreement with EPA to transfer GLRI funds from EPA to the appropriate agency. The interagency agreements we reviewed included the following two parts: a form that identified the amount to be transferred from EPA to the agency that was responsible for the work, signed by both agencies;and a scope-of-work organized into discrete topics called templates that typically included a description of the work, the GLRI Action Plan goals, objectives, or measures of progress that the work would achieve, and the amount of GLRI funds to be used.

EPA officials told us that the Task Force agencies were expected to spend their funds as detailed in their interagency agreement, but they could amend it with EPA approval to, for example, increase the amount of funds to be transferred to an agency or revise the scope of work.

GLRI Templates Great Lakes Restoration Initiative (GLRI) templates address Action Plan focus areas, and can describe work that would be conducted through multiple projects, or through a specific, individual project. An example of a template that describes work that would be conducted through multiple projects is a Natural Resources Conservation Service (NRCS) template that addresses the nearshore health and nonpoint source pollution focus area. According to the template, NRCS would provide agricultural producers with GLRI funds and technical assistance to implement conservation practices to contribute to the 2010-2014 Action Plan goal of significantly reducing soil erosion and sediment, nutrients, and pollutants flowing into tributaries. An example of a project-specific template is a U.S. Army Corps of Engineers template to complete the design, and initiate construction, of a facility to manage dredged sediments in Green Bay Harbor, Wisconsin. The project is intended to hold 2.35 million cubic yards of sediments, and restore a chain of islands and more than 1,200 acres of coastal wetland habitat. applications would use to rank applications and select projects.officials told us that applicants may be asked to provide funds to the project.

The fourth step in identifying GLRI work and funding was the selection of specific projects. Generally, officials from the selected agencies described similar processes for evaluating project proposals that were submitted in response to requests for applications. Specifically, they said that agency officials with the appropriate expertise reviewed and ranked the submitted proposals against information in the request for applications and selected the best scoring projects for funding. At the Corps and NOAA, officials said they evaluated contract bids or proposals, and awarded the contract to the vendor with a bid or proposal representing the best value to the government.

Of the 19 projects we reviewed for which funds were made available for the GLRI in fiscal years 2010 through 2012 and that addressed each of the five focus areas in the 2010-2014 Action Plan, 11 were executed through grants, 2 were executed through cooperative agreements, 3 were executed by a Task Force agency, 2 were conducted through contracts, and 1 was executed through a financial assistance contract. One project addressed the toxic substances and Areas of Concern focus area; 5 addressed the invasive species focus area; 3 addressed the nearshore health and nonpoint source pollution focus area; 5 addressed the habitat and wildlife protection and restoration focus area; and 5 addressed the accountability, education, monitoring, evaluation, communication, and partnerships focus area. In addition, the recipients conducting the 19 projects included 8 federal entities; 4 state, local, or tribal entities; 4 academic institutions; and 3 nongovernmental organizations. We found that the solicitations for 11 of the 19 projects reflected the descriptions of work in the related templates. The 8 remaining projects were not solicited because 4 were conducted by the agency, 2 were not competitively awarded, 1 project had been ongoing since before the GLRI, and the recipient was identified in the interagency agreement, and 1 project was conducted by a recipient that had been selected prior to the GLRI as one of a few with the specific skills required for the project. Appendix II shows the relevant templates and solicitations for each of the 19 projects, as well as information from agency officials about why each of the projects was selected.

Process for Identifying Each Agency’s GLRI Work and Share of GLRI Funding Has Evolved to Emphasize Interagency Discussion by Task Force Subgroups

The process for identifying each agency’s GLRI work and share of GLRI funding has evolved over the life of the GLRI. According to EPA officials, for fiscal years 2010 and 2011, the Task Force determined the work an agency would do on an agency-by-agency basis. Beginning with fiscal year 2012, the process began emphasizing interagency discussion as the Task Force created three subgroups with federal agency members, one for each of three priority issues. The three priority issues, which aligned with three of the five focus areas in the 2010-2014 Action Plan, were (1) cleaning up and delisting Areas of Concern located entirely or partially in the United States, (2) preventing and controlling invasive species, and (3) For reducing phosphorus runoff that contributes to harmful algal blooms.fiscal year 2015, EPA officials said that the Task Force agencies had begun creating additional subgroups to discuss and agree on scope and funding for agencies’ GLRI work.

For fiscal years 2010 and 2011, the Task Force and the five agencies agreed on work that each agency would do on an agency-by-agency basis. Officials from the agencies said that they identified work from their existing plans and interacted with the Task Force to determine the work the agencies would do and the funds the agencies’ should receive. Because the program began in fiscal year 2010, this process did not take place 2 years in advance, as it would in subsequent years. EPA officials told us that in 2010 the agencies also began agreeing on work for fiscal year 2011. After Congress made funds available for the GLRI for fiscal year 2010, and again after fiscal year 2011, the Task Force revisited the initial agreements made with each agency to finalize the funding amounts.

In agreeing on GLRI work and funding for fiscal years 2012 through 2014, the Task Force created a subgroup for each of the three priority issues and set aside a total of about $180 million to pay for work to address these issues. The Task Force created subgroups staffed by officials from relevant Task Force agencies to discuss and agree on the scope and funding for agencies’ work to address the three priority issues. Specifically, officials from EPA, FWS, NOAA, the Corps, and the U.S. Geological Survey participated in the cleaning up and delisting of Areas of Concern and the invasive species prevention subgroups. Officials from EPA, NRCS, NOAA, the Corps, and the U.S. Geological Survey participated in the phosphorous reduction priority issue subgroup.

On Concern to be targeted for accelerated cleanup in fiscal year 2012: the Ashtabula River Area of Concern in Ohio, the River Raisin Area of Concern in Michigan, the Sheboygan River Area of Concern in Wisconsin, and the White Lake Area of Concern in Michigan. At the same time, the subgroup identified additional Areas of Concern to be The subgroup addressed in future years using the same approach.determined that nearly $22 million should be set aside for this priority issue in fiscal year 2012 and increased that amount to about $31 million for fiscal years 2013 and 2014.

Invasive species prevention subgroup: Building on work done by the Asian Carp Regional Coordinating Committee that began around the same time as the GLRI, the subgroup originally focused most of its efforts on identifying projects to prevent Asian carp from getting into and becoming established in the Great Lakes. These projects included developing early detection and monitoring, and tools and technology to discover whether Asian carp were already present in the Great Lakes Basin. The subgroup agreed to adopt the amount of funds, $19.5 million, in fiscal year 2012, based on estimates made by the Asian Carp Regional Coordinating Committee. In fiscal year 2013, the Coordinating Committee reduced the amount it estimated was needed for invasive species work in the Great Lakes Basin to $16 million. The subgroup agreed to continue funding this priority issue at $19.5 million in fiscal years 2013 and 2014, but it divided the funds into $16 million for Asian carp work and $3.5 million for other invasive species, such as phragmites and feral hogs. The subgroup used the Asian Carp Control Strategy Framework to guide the amount of GLRI funds that should be provided to each of the Task Force agencies with responsibility for conducting work to address this priority issue.

Phragmites australis, or common reed, is a perennial grass now common in North American wetlands. Invasive phragmites create tall, dense stands that degrade wetlands and coastal areas by crowding out native plants and animals, blocking shoreline views, and reducing access for swimming, fishing, and hunting. Feral hogs are domestic hogs that have either escaped or been released, and they can be found in 39 states including the Great Lakes region. They cause damage to crops and habitat and can cause erosion by digging for food. They also carry diseases that threaten humans and animals. In 2014, the U.S. Department of Agriculture estimated that feral hogs caused $1.5 billion in annual damage and control costs.

Phosphorous reduction subgroup: Using available models and data to identify geographic areas that were contributing more nutrients to the Great Lakes than others, the subgroup determined that priority work should be focused on three watersheds where algal blooms had occurred. The three watersheds were the Lower Fox River in Wisconsin; the Maumee River watershed in Ohio, Michigan, and Indiana; and the Saginaw River in Michigan. The subgroup agreed that $11 million should be set aside for this priority issue for fiscal year 2012, and to increase that amount to $13.1 million for fiscal year 2013, and to $14.4 million for fiscal year 2014. EPA provided the majority of funds for this priority issue to NRCS because it is the federal agency that works with agricultural producers to implement conservation practices to reduce nutrients in runoff, and Task Force agency officials determined NRCS was best suited to address nutrient reduction. EPA provided the remaining funds to the U.S. Geological Survey for monitoring projects because of its experience in monitoring water supply and water quality.

To agree on GLRI work to be conducted in fiscal year 2015 and future fiscal years, EPA officials told us that the Task Force began creating additional subgroups through which Task Force agency officials would work together to identify each agency’s GLRI work and share of GLRI funding in all five of the focus areas in the 2015-2019 Action Plan, not just the three priority issues. According to EPA officials, the use of subgroups to meet and agree on work and funding created a process for conducting GLRI work that all Task Force agencies agreed needed to be done, rather than each agency identifying its own GLRI work. According to EPA officials, for fiscal year 2015, the new subgroups developed strategies for dealing with issues and then identified the work proposed by agencies that helped to achieve the overall strategies. For future fiscal years, EPA officials said that the subgroups would use the 2015-2019 Action Plan.

Focus on Priority Issues Led to Some Accelerated Restoration Results in Targeted Areas

According to EPA officials, the focus on priority issues for fiscal years 2012 through 2014 has accelerated restoration results for one of three issues. Specifically, two of the Areas of Concern targeted for accelerated cleanup by the relevant subgroup were delisted in 2014. EPA announced in October 2014 that the White Lake and Deer Lake Areas of Concern had been delisted—both had been identified by the Areas of Concern subgroup for accelerated cleanup with priority issue funds—and EPA officials told us that they expect cleanup work to be completed at four other Areas of Concern in fiscal year 2015 as a result of receiving priority issues funds. Cleanup work included removing contaminated sediment and diverting water from an underground mine. In the 25 years before the three priority issues were identified, only one Area of Concern located entirely in the United States had been delisted.

EPA officials said that identifying and funding the three priority issues for fiscal years 2012 through 2014 has also allowed for continued success in invasive species prevention and resulted in some progress in reducing phosphorus runoff that contributes to harmful algal blooms. However, restoration results in those priority issues are less clear than in the Areas of Concern priority issue, in large part because the factors contributing to those priority issues persist and are likely to continue into the future. For example, dams, canals, and other structures that were created to support navigation and power production in the Great Lakes Basin also created channels that connect the Great Lakes and Mississippi River Basins. These channels are of serious concern as a potential means for Asian carp or other invasive species to enter the Great Lakes.

EPA funded work on priority issues from the amounts made available for the GLRI in fiscal years 2012 through 2014, shifting funds from other GLRI work to the priority issues. EPA officials described the funds set aside for the priority issues as a realignment of GLRI funds; that is, the funds used for the priority issues were taken from the existing funds that had been made available for the GLRI. Overall, the Task Force set aside a total of $180 million for the priority issues for this period: $52.2 million of the available GLRI amounts for all priority issues in fiscal year 2012, $63.4 million in fiscal year 2013, and $64.7 million in fiscal year 2014. EPA officials told us that money designated for one priority issue would not be spent on a different priority issue or on other GLRI projects.

EPA officials told us that the Task Force did not set aside all of the funds made available for the GLRI in fiscal years 2012 through 2014 for the priority issues for two key reasons. First, they said there is a limit to the amount of work that can be conducted for some restoration efforts. For example, GLRI funds for reducing agricultural runoff can only be given to recipients in the Great Lakes Basin. These recipients are typically landowners, and there is a finite number of landowners in the Great Lakes Basin interested in conducting GLRI work who also have suitable land and ready projects. In addition, EPA officials told us that NRCS is the only Task Force agency equipped to oversee phosphorous reduction work targeted in agricultural areas, and the agency has a fixed number of personnel that it can use to oversee GLRI work. Second, according to these officials, Great Lakes restoration needs to involve topics addressed by the 2010-2014 Action Plan that are not part of the three priority issues, as well as addressing the overall health of the Great Lakes ecosystem.

Information on GLRI Projects Activities and Results Is Available from Individual Agencies, while Project Information in GLAS Was Limited by Some Inaccurate Data

The Task Force has made some information about GLRI projects, including project activities and results, available to Congress and the public in three accomplishment reports and the GLRI website. Specifically, the GLRI accomplishment reports contain information on activities and results for some projects. In addition, the individual Task Force agencies collect information on activities and results from recipients, although this information is not collected and reported by EPA. We obtained information on activities and results for the sample of 19 projects we reviewed. While EPA collected project information in GLAS from 2010 through May 2015, some GLAS data were inaccurate, in part because recipients entered information inconsistently due to issues such as inconsistent interpretation of guidance, unclear guidance, or data entry errors.

Information on GLRI Project Activities and Results Is Available from Individual Task Force Agencies

As part of oversight of the GLRI, the Task Force makes some information on projects available for Congress and the public in two ways, annual accomplishment reports and the GLRI website. EPA and the Task Force published two accomplishment reports in 2013 and one in 2014 that provided overviews of progress under the GLRI for fiscal years 2010 through 2012. These reports included summary accomplishment statements for each of the five focus areas from the 2010-2014 Action Plan, as well as specific performance information for many of the 28 measures of progress in the 2010-2014 Action Plan.

The accomplishment reports included some information about project activities and results. Specifically, our analysis found that GLRI accomplishment report for progress in fiscal year 2011 identified 10 GLRI projects, 2 for each of the five focus areas in the 2010-2014 Action Plan, and it included some information about project activities and results for each project. For example, it noted that the “Milwaukee River (Wisconsin)—restoring fish passage” project removed a dam, opening 14 miles of the river and 13.5 miles of tributaries to allow fish to move more freely, and reconnected the lower reach of the river with 8,300 acres of wetlands, improving water quality. The accomplishment report provided similar information about nine additional projects. The accomplishment reports about GLRI progress in fiscal years 2010 and 2012 also included information about project activities and results, although most were not associated with individual projects.

EPA also made some of the GLRI project information that recipients reported in GLAS available on the GLRI website, including a project’s funding agency, title, funding amount and year, recipient identification, focus area, and description. Project information available on the website does not include GLRI project activities and results, although it is not designed to do so. EPA updated the GLRI project information on the website twice a year by asking the other Task Force agencies to update and verify GLAS information about their projects. To compile project information for the website, EPA provided each Task Force agency with a spreadsheet containing certain GLAS data for each of that agency’s projects so that the agency could update and verify that information before it was posted on the website. The information on the website about projects is limited to basic information for the public, according to an EPA official, and does not contain certain information on projects such as activities and results.

Each of the five Task Force agencies we reviewed collected information on its projects, including project activities and results, and we reviewed the sample of 19 GLRI projects from the five Task Force agencies to identify information on project activities and results for each of the projects. We found that each of the five Task Force agencies collected this and other project information by establishing reporting requirements in grants, cooperative agreements, and contracts for recipients. Specifically, in most cases, EPA, FWS, NOAA, and NRCS required their grant recipients to submit quarterly, semiannual, or annual progress reports, and quarterly or annual financial reports, consistent with the OMB circulars in effect at the time of the agreements. In addition, the Task Force agencies that used contracts—the Corps and NOAA—required their contractors to submit progress reports. The Corps required the contractor to submit daily activity reports, and NOAA required the contractor to provide monthly progress reports. EPA officials told us that this information on project activities and results was not required to be reported in GLAS. In addition, the officials said that GLAS was not designed to collect specific information on project activities and results and was adapted from a system they used to collect information on a different restoration program. Appendix III contains a summary of the detailed information we collected on activities and results for the 19 projects.

Overall, recipients reported a variety of project activities, including applying herbicide, conducting training and workshops, and collecting data. In addition, we found that recipients reported a range of results. For example, recipients from eight projects reported results that can be directly linked to restoration, such as increasing lake trout production, removing acres of invasive plant species, and protecting acres of marshland. For one of these projects, the Buffalo Audubon Society reported results needed to restore critical bird habitat, such as planting 3,204 plants and removing invasive species, among other results. For another project, the Great Lakes Fishery Commission reported results in the form of improved methods for capturing sea lamprey. According to a Great Lakes Fishery Commission official, the results from this project will help to further suppress sea lamprey production in the Great Lakes thereby reducing the damage they cause to native and desirable species.

For example, a single lamprey can kill up to about 40 pounds of fish in its lifetime.

Recipients for the 11 remaining projects reported results that can be indirectly linked to restoration; that is, the results may contribute to restoration over time. These included results such as simulations and data for helping decision makers make better restoration decisions in light of climate change, and education and outreach tools to increase awareness of invasive species. In addition, a University of Wisconsin- Madison representative told us that the University’s project to improve applied environmental literacy, outreach, and action in Great Lakes schools and communities, has already contributed to restoration. Some of the University’s progress reports noted that the project has already resulted in more than 110 school teams that guided students in restoration, service-learning, inquiry, and citizen science monitoring during the 2013-2014 school year, among other things. The representative told us that this contributed to restoration because participating students have built rain gardens and implemented other conservation practices. Similarly, the Corps used GLRI funds to complete a feasibility study in Highland Park, Illinois, and the study led to a restoration project that is expected to restore and enhance 4 acres of coastal habitat along the Lake Michigan shoreline, among other things. Figure 7 is a photograph of the Corps restoration project to restore and enhance coastal habitat that began with the feasibility study. See appendix III for examples of activities and results from each of the 19 projects we reviewed.

Some GLAS Data Were Inaccurate

EPA collected some project information in GLAS, which the agency created to collect information to monitor and report on GLRI progress in response to the conference report accompanying the fiscal year 2010 appropriation act that made funds available for the GLRI. However, our review found that some of the data collected in GLAS were inaccurate and therefore may not be sufficiently reliable to monitor and report project progress. For example, GLAS collected project information in more than 20 data fields, including the project’s title, funding amount, funding year, funding agency, recipient, focus area, state, end date, status, and related Area of Concern and watershed. We selected six data fields that could contribute to our understanding of projects and assessed their reliability. Specifically, we reviewed the GLAS data fields for funding year, funding agency, recipient, status, end date, and funding amount. For each of the six fields, we reviewed field definitions and data entry procedures, and we manually checked data entries. We found that the funding year and funding agency data fields were sufficiently reliable, that is, accurate and complete, for the purposes of monitoring and reporting on the progress of GLRI projects. However, we found that the other four data fields were not sufficiently reliable for that purpose. The results of our analysis are as follows:

Recipients. GLAS data on project funding recipients, which EPA’s GLAS User Guide defined as the organizations that actually conducted the work, were inconsistent. For the 1,558 projects funded by the five agencies we reviewed, we compared the recipients that were identified in GLAS with data obtained from the agencies on recipients that had received GLRI funds for these projects directly from the agencies. We found that GLAS users did not identify recipients in GLAS consistently. Specifically, three of the agencies sometimes or always identified only the agency as the recipient in GLAS, even if the agency awarded the funds for that project to other entities that conducted the work. For example, one agency identified itself as the funding recipient for 118 projects in GLAS, but data we obtained from the agency identified other entities as the recipients for most, or 95, of those projects. Similarly, another agency identified itself as the funding recipient for 311 projects in GLAS, but data we obtained from the agency identified other entities as the recipients for almost half, or 151, of those projects. In addition, a third agency identified itself as the recipient for all 26 of the agency’s GLRI projects in GLAS. While it is the case that some of the agency’s recipients are private citizens, whose identities the agency does not want to release, the agency awarded funds to recipients other than private citizens for 18 of its projects.

Project status. GLAS users did not define status the same way and therefore may have entered the status of their projects inconsistently. To report a project’s status, GLAS users selected from a drop-down list of options, including started, percentage completed, and completed. We asked officials at four of the five agencies we reviewed how they defined “completed” and found that the agencies did not mean the same thing when selecting completed. For example, one agency official told us that for projects involving construction, completed means that the bulk of the contractor’s effort was completed and that the ecological benefits of the project were at least partially realized, even if additional project activities and final payments may have not been completed. Officials from another agency told us that completed means that all of the funds for the project were obligated and expended, or all contracts were completed, cancelled, or terminated. EPA officials told us that many recipients did not report projects as completed until the grant itself was closed out, which can take as long as a year from the completion of fieldwork. With agencies using different definitions, it is not clear what the GLAS data represented for those projects identified as completed. For example, GLAS users could have selected completed for their projects when the project work was finished, when all the funds had been expended, or when the financial agreement was closed out. As a result, GLAS data cannot be used to reliably determine how many GLRI projects have been completed.

Project end date. Although not a required data field in GLAS, most projects (more than 75 percent) in GLAS had an end date listed. However, some GLAS data on the project end dates were inconsistent with project status reported in GLAS. We analyzed the end dates in GLAS for 1,890 projects as of July 2014 by checking for errors and by comparing the end dates with the projects’ status.Through this analysis, we found that of the 799 projects identified in GLAS as completed, 14 percent (112) had end dates that had not yet been reached. In addition, 698 projects had end dates that had already passed, but 28 percent of those (194) had not been identified in GLAS as completed. As a result, GLAS data on the end dates of projects are unreliable and cannot be used to determine the number of projects that were completed or are expected to be completed by a certain date.

GLRI funding amounts. Some GLAS data on the GLRI funding amounts for projects were inaccurate. Specifically, after reviewing the GLAS data we provided on funding amounts for 1,558 projects, four of the five agencies identified inaccuracies in the GLRI funding amounts that the agencies or their recipients had reported in GLAS. For example, the funding amount for one project in GLAS was $8.3 million less than the actual funding amount, which agency officials attributed to a data entry error. Similarly, officials from a second agency identified a project for which the funding amount in GLAS was about $219,000 more than the actual funding amount and told us that the reason for the error was unknown. Officials from a third agency also identified projects for which they said the agency had entered incorrect funding amounts, including 11 projects for which the GLAS data overreported the funding by $523,000. And, officials from a fourth agency identified 19 projects for which the funding amounts the agency had reported in GLAS were incorrect in part because of data entry errors, but they did not identify the dollar amount of the errors. Although we cannot extrapolate these examples of errors in GLAS on project funding to the 11 other Task Force agencies, the amount of these errors raises concerns about the accuracy of GLAS data on GLRI funds.

Some of the errors we found in GLAS data may have been the result of agencies’ different interpretations of guidance or unclear guidance. Specifically, EPA’s GLAS User Guide was the formal guidance document that defined GLAS data fields, such as recipients, project status, and end dates, but EPA left it up to the Task Force agencies to decide how to enter the data. For example, according to an EPA official, the GLAS data identifying recipients used the lead organizations entered by GLAS users. The GLAS User Guide defined lead organization as the organization that actually conducted the project. However, in practice, the Task Force agencies varied regarding which entity they identified as the recipient, the funding agency or the organization conducting the project. In addition, the GLAS User Guide did not provide clear guidance. For example, EPA required that GLAS users report project status in GLAS, but the GLAS User Guide did not specify how users should choose a project’s status from the drop-down menu and did not define available options. Under the federal standards for internal control, agencies are to clearly document internal controls, and the documentation is to appear in management directives, administrative policies, or operating manuals.

Similarly, although it was not required, the guide did not specify how users should determine what the end date is when they did enter it. Without specifying this, GLAS users may have entered information in the end date field inconsistently. For example, we found that some projects had a completed status but had not reached their reported end dates, and others had end dates that had already passed but did not have a completed status. Specifying in the guide how to determine the end date would have been consistent with federal standards for internal control that call for clearly documenting internal controls. According to EPA officials, the GLAS User Guide did not specify how GLAS users should determine a project’s end date because the officials thought this data field was intuitive. Because the GLAS User guide did not require GLAS users to enter end dates for all projects, however, EPA may not have complete information on GLRI projects in GLAS. According to our February 2009 guide on assessing the reliability of computer-processed data,reliable when they are accurate and complete.

In May 2015, when EPA stopped using GLAS and began using the Environmental Accomplishments in the Great Lakes (EAGL) information system to collect GLRI project information, the agency issued initial guidance that included definitions of the data fields in the system. For example, the guidance defines recipient name as the organization actually doing the work, and project end date as the date that the project ended or is planned to end; the data field lead organization is no longer included. We reviewed the guidance and determined that the definitions provided were clear and could be used to enter data consistently. In addition, we found that the guidance clearly identifies those data fields that are required, including project end date. However, while the guidance specifies that users should select one project status option from the drop down list in the system, it does not identify or define the available options.

Other errors that agencies identified in their GLAS data, such as in the GLRI funding amounts data, arose from data entry errors or lags in data updates, according to officials from some of the Task Force agencies we reviewed. Some of these inaccuracies could have been caught through data quality controls or other edit checks, but our analysis found that EPA did not have controls for GLAS to prevent such errors. Under the federal standards for internal control, agencies are to implement control activities, such as verifications and reconciliations, which can be computerized or manual, and document internal controls, such as documenting procedures on how such verifications are to be implemented (e.g., who is to conduct periodic reviews of the completeness and accuracy—that is, reliability—of data). Of the five agencies we reviewed, EPA officials told us that they reviewed their own agency data and relied on the four other Task Force agencies to use their own processes to ensure that the data they or their recipients entered in GLAS are reliable. Of the four other agencies, three did not identify processes they used to ensure the reliability of data that they or their recipients entered in GLAS. Officials from the fourth agency told us that their agency reviewed its GLAS entries annually by comparing a spreadsheet of GLAS data provided by EPA with its own programmatic reports and reports from its financial system. Even with its review process, in January 2015, that agency identified errors in its GLAS data for nearly 20 percent of its fiscal year 2010 through fiscal year 2012 GLRI projects. Most were errors in the funding amounts entered by the agency, which agency officials attributed to data entry errors and changes that had not been updated in GLAS. Similarly, officials from one of the other agencies noted that, even when they found errors, certain data fields, including GLRI funding amounts, could not be edited by the agencies and that the agencies had to contact EPA to make corrections.

Without control activities, such as some form of verification, data errors are likely to continue, making the data collected into the system used to collect GLRI project information insufficiently reliable to ensure monitoring and reporting on GLRI progress as directed in the conference report. In commenting on a draft of this report, EPA stated that it plans to establish data control activities, such as verifications and documented procedures, for ensuring the reliability of the EAGL information system. In discussing these comments, EPA officials told us that the most important difference between GLAS and EAGL is that EAGL limits data entry to Task Force agency officials. The officials did not have a time frame for establishing data control activities, and told us that they wanted the Task Force agencies to become comfortable using the new system first. Until EPA and the Task Force agencies make a decision about the data system and the agency fully implements the actions needed to address the reliability of GLRI project data, EPA and the Task Force agencies cannot have confidence that EAGL can provide consistent, accurate, and complete information. Thus, we urge EPA to implement these actions as quickly as possible.

EPA officials told us that, in 2012, they began to review GLAS and to consider whether to upgrade GLAS to improve it or develop a new system. This review included identifying potential improvements and considering whether GLAS is the right tool for monitoring and reporting on the GLRI. The Task Force also convened a subgroup of Task Force agency officials to determine what the next version of GLAS should be. One concern EPA officials expressed about this decision was the cost to create a new system to collect detailed data, and they noted that they are hesitant to make that investment in the face of uncertainty over whether the GLRI will continue to be funded from year to year. EPA officials told us that the agency created EAGL in February 2015 and, after consulting with the Task Force agencies, conducted pilot tests of the system for a few months, while we were completing our work. After this testing, in May 2015, EPA officials decided to use EAGL to collect information to monitor and report on GLRI progress, and they made the system available to Task Force agencies for an initial period of data entry. Specifically, EPA officials transferred key project information from GLAS into EAGL and asked the Task Force agencies to enter new project information and update existing information. According to EPA officials, EAGL will improve the consistency and completeness of information about GLRI projects. EPA officials told us that the agency plans to use this initial period of data entry to get feedback from the Task Force agencies and to make changes to EAGL and the draft data entry guidance to address any problems and refine definitions. The EPA officials said their goal is to have EAGL ready for data entry at the beginning of fiscal year 2016.

Conclusions

The United States has committed enormous resources to help restore the health of the Great Lakes ecosystem, a region that is vital to the United States both economically and socially, with some progress. Nonetheless, Great Lakes restoration remains an ongoing, long-term effort. To gauge progress toward restoration, EPA and the Task Force agencies have established measures of progress for the GLRI and collected information in GLAS to report on progress. EPA and the Task Force agencies have proceeded carefully over the last 2 years as they have evaluated how best to collect and report GLRI data. In May 2015, while we were completing our work, EPA replaced GLAS with a new system to collect GLRI project information and issued guidance that included definitions of data fields and identified which data fields are required. This is a good first step to resolving the data inconsistencies that we identified in GLAS, which resulted, in part, because of unclear or undocumented definitions, data requirements, and guidance about entering important data. However, EPA has not yet established data control activities or other edit checks, although in commenting on a draft of this report, EPA stated that it plans to establish data control activities, such as verifications and documented procedures, for ensuring the reliability of the EAGL information system. Fully implementing the actions needed to address the reliability of GLRI project data should ensure that EPA and the Task Force agencies can have confidence that EAGL can provide complete and accurate information.

Federal agencies have expended funds for Great Lakes restoration activities other than what has been made available for the GLRI. However, OMB has not reported on all federal obligations and expenditures for these activities as required by law. Without this information, the information available for congressional oversight and decisions on future funding levels has been limited to funds made available.

Recommendation for Executive Action

To better ensure that complete information is available to Congress and the public about federal funding and spending for Great Lakes restoration over time, we recommend that the Director of OMB ensure that OMB includes all federal expenditures for Great Lakes restoration activities for each of the 5 prior fiscal years and obligations during the current and previous fiscal years in its budget crosscut reports, as required by Pub. L. No. 113-76 (2014).

Agency Comments and Our Evaluation

We provided a draft of this report to EPA, the Departments of Agriculture, Commerce, Defense, and the Interior, and OMB for review and comment. In written comments from the EPA Region 5 Administrator, which are reproduced in appendix VI, EPA generally agreed with the recommendations in our draft report and noted that the agency had already taken action consistent with the recommendations. In particular, for a recommendation in our draft report that EPA determine whether the agency should continue using GLAS or acquire a different system to collect information to monitor and report on GLRI progress, EPA stated in its written comments that GLAS is no longer in use and has been replaced by EAGL. We interviewed EPA officials about EAGL and its status, as well as plans for implementing it, and determined that the agency has made a final decision and taken appropriate actions to adopt it. As a result, we removed the recommendation from the report. We also added information about EAGL in the report.

In addition to replacing GLAS with EAGL, EPA noted that the agency has taken action to address three recommendations we made about ensuring data reliability in our draft report. First, for a recommendation that EPA should ensure that GLAS or another system requires important data to be entered, according to EPA, EAGL will require important information, including project end date, to be entered by the Task Force agencies. Second, for a recommendation that GLAS or another system documents definitions and guidance for entering data into the system, the agency in its written comments stated that it has developed an initial guidance document for data entry that it is revising based on the initial round of data entry into EAGL. We reviewed the initial guidance and determined that it clearly identifies those data fields that are required and that the definitions provided were clear and could be used to enter data consistently. As a result, we removed these recommendations from our report. Third, for a recommendation that EPA should ensure that GLAS or another system establishes data quality control activities, such as verifications and documented procedures for ensuring system reliability, EPA stated that it will establish data quality control activities such as verifications and documented procedures for ensuring the reliability of the EAGL information system. Although EPA officials did not have a timeframe for establishing data quality control activities, the agency has limited data entry to Task Force agency officials, and we believe the actions already taken constitute important steps toward enhancing GLRI oversight. As a result, we removed the recommendation from the report. We look forward to seeing the agency take this final action. However, until it is fully implemented, the agency cannot have confidence that the data produced by EAGL will address the inconsistencies that we identified in GLAS or that they are complete and accurate. Thus, we urge EPA to finish implementing these actions as quickly as possible.

In oral comments, OMB staff disagreed with the recommendation that OMB include all federal expenditures for Great Lakes restoration activities for each of the 5 prior fiscal years and obligations during the current and previous fiscal years in its budget crosscut reports, as required by Pub. L. No. 113-76 (2014). OMB staff restated the position that including the required expenditures and obligations information in the budget crosscut reports would not yield sufficient information to justify the cost of including that information. They added that there is no evidence that this information would be used for congressional oversight. Nevertheless, the law requires OMB to identify, among other things, all funds received and obligated by all federal agencies for Great Lakes restoration activities during the current and previous fiscal years and all federal government expenditures in each of the 5 prior fiscal years for these activities, and OMB should comply with the law.

The Departments of Defense and the Interior responded that they did not have comments on the draft report. In addition to these written and oral comments, EPA, NOAA, and NRCS provided technical comments that we incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 9 days from the report date. At that time, we will send copies to the appropriate congressional committees, the Director of OMB; the Administrator of EPA; the Secretaries of Agriculture, Commerce, Defense, and the Interior; 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 key contributions to this report are listed in appendix VI.

Appendix I: Objectives, Scope, and Methodology

This appendix provides information on the objectives, scope, and methodology for the report. We examined the (1) amount of federal funds made available for the Great Lakes Restoration Initiative (GLRI) and expended for projects; (2) process the Great Lakes Interagency Task Force (Task Force) used to identify GLRI work and funding; and (3) information available about GLRI project activities and results.

To examine the amount of federal funds made available and expended for GLRI projects, we analyzed the Environmental Protection Agency’s (EPA) January 2015 GLRI financial management update reports for GLRI funds made available in fiscal years 2010 through 2014. We reviewed relevant EPA documents and interviewed EPA officials about the data input and review for the GLRI financial management update and, based on this work, determined that it was reliable for our purposes. In addition, to provide context for how funds for GLRI projects compared with funds made available for other federal Great Lakes restoration activities, we analyzed the Office of Management and Budget’s (OMB) Great Lakes Restoration Crosscut Reports to Congress for 2008 through 2012 and 2014 and the applicable appropriations laws requiring OMB to produce these reports. We also interviewed OMB staff to obtain information about the crosscut reports.

We then selected five Task Force agencies to review in greater detail because they had received the majority (about 85 percent) of GLRI funds The five agencies we made available in fiscal years 2010 through 2014.selected were: EPA, U.S. Army Corps of Engineers (Corps), Fish and Wildlife Service (FWS), Natural Resources Conservation Service (NRCS), and National Oceanic and Atmospheric Administration (NOAA). We obtained data from EPA’s Great Lakes Accountability System (GLAS) as of July 2014 to identify the projects funded by the five Task Force agencies with amounts made available for the GLRI in fiscal years 2010 through 2013. We did not include fiscal year 2014 projects because most of the amount made available in that year had not been obligated as of July 2014. We assessed the reliability of the GLAS data on funding agency and funding year by asking the agencies to verify their projects in the system, and we believe that the data are sufficiently reliable for identifying a list and total number of projects funded by the five agencies.

GLAS data included recipient but, as described below under objective 3, we do not find that this or certain other GLAS data fields are reliable for other purposes of reporting. Therefore, to identify the recipients of GLAS funding, we obtained a list of the recipients from each of the five agencies, for each of the projects in the GLAS data we obtained. We used information we obtained from the recipients, their websites, or the funding agencies to categorize each of the recipients by recipient type, using the definitions in table 4, and summarized that information.

In addition, we obtained data from each of the five agencies about the types of financial agreements they used—grants, cooperative agreements, and contracts—to determine the percentage of obligations per financial agreement of amounts made available for the GLRI in fiscal years 2010 through 2013. We obtained an updated version of GLAS data, from January 2015, to identify the total number of projects reported by all Task Force agencies in GLAS.

To examine the process the Task Force used to identify GLRI work and funding, we first interviewed officials from the five Task Force agencies. We used this information, in addition to our previous work on grants management, to describe the four steps that the Task Force and agencies generally use to identify GLRI work and funding. We then analyzed relevant documents to corroborate and obtain information about each of these steps. Specifically, we analyzed interagency agreements between EPA and the other Task Force agencies, including the associated scopes of work; requests for applications; project selection summaries; and agencies’ policies and guidance on managing grants, cooperative agreements, and contracts. We also reviewed EPA data on the amount of GLRI funds in fiscal years 2012 through 2014 that the agency set aside for issues identified by the Task Force as GLRI priorities to understand how the Task Force process has evolved. We then interviewed EPA officials about the process for identifying priority issue work and funding for fiscal year 2012 through fiscal year 2015. We reviewed a sample of 19 GLRI projects to understand how the process was applied to specific cases. For each project, we analyzed documents from the funding agencies and funding recipients to determine the origin of each project and why it was selected. The documents we reviewed included project solicitations, such as announcements of funding opportunities, requests for applications, or other solicitations; project proposals and applications; agency documents on why projects were selected for funding; and project financial agreements such as grant and cooperative agreement documents.

We took the following steps to select the sample of 19 GLRI projects. First, we identified all projects funded by the five Task Force agencies we reviewed. To do this, we used data from GLAS to create a list of GLRI projects funded by each of the five agencies we reviewed with amounts made available for the GLRI in fiscal years 2010 through 2012. We did not review projects funded with funds made available for the GLRI in fiscal year 2013 or 2014 because those projects were likely to be in the early stages of implementation, or not yet started, at the time we began our review. Second, we categorized these projects by recipient type, using the process described above. Third, we ranked projects by agency, recipient type, and funding amount. Finally, we selected the median project for each agency and recipient type (see table 5 for those projects selected). We did this to ensure that we include projects that illustrate typical GLRI funding amounts. We selected at least one project from each of the following recipient types: federal entities; state, local, or tribal entities; nongovernmental organizations; and academic institutions.

Fourth, we also selected the project with the largest amount of GLRI funds for each agency (see table 6). In the instances where the project with the largest funding amount was associated with a recipient that we had already selected, we moved to the project with the next largest funding amount with a recipient that had not already been selected. This sample of 19 projects is not representative of all GLRI projects; however, it captures both projects with typical and large funding amounts from a range of recipients.

To examine the information available about GLRI project activities and results, we first analyzed the three accomplishment reports the Task Force issued to provide an overview of progress under the GLRI in each of fiscal years 2010 through 2012. We also reviewed information on projects available at the GLRI website, http://glri.us, and discussed its purpose and design with EPA officials. In addition, we obtained information on the 19 projects we selected for review to identify information available on project activities and results. We used agency documents to identify the purpose of the projects and project activities and results. Specifically, we analyzed project progress reports, and interviewed, or obtained written responses from, relevant agency officials and recipient representatives. We also interviewed recipient representatives about how the projects will contribute to the restoration of the health of the Great Lakes ecosystem, and we visited the recipients or locations for 3 of the 19 projects. We visited (1) the “Sheboygan River Area of Concern: pathway to delisting beneficial use impairments” project; (2) the “Great Lakes earth partnership” project; and (3) the “Rosewood Park, IL” project and interviewed the relevant funding agency officials and funding recipient representatives. We selected these three projects in order to observe work conducted by different recipient types that were within driving distance of the EPA Region 5 office in Chicago where the EPA officials that oversee the GLRI are located.

In addition, we examined project information available for projects identified in EPA’s database, GLAS, as of July 2014. We selected 6 data fields that we could use to describe projects and that we wanted to summarize and include in our report: funding year, funding agency, status, end date, recipient, and GLRI funding amount. We selected these 6 fields out of the more than 20 data fields in GLAS because they provided basic information about how GLRI funds have been used for projects (funding agency, year, GLRI funding amount, and recipient) and information on the progress of those projects (status and end date). For example, these data fields can be used to determine first how much funding an agency provided to a recipient in a fiscal year for a project, and then the extent to which the project was completed (status) and when the project would be completed (end date). We assessed the reliability of these data using three sources of information: EPA’s GLAS User Guide to identify data field definitions and guidance for entering data; information we obtained from the five agencies to identify inaccuracies in the data, such as funding amounts, for their projects in GLAS; and the agencies’ responses to our questions about GLAS data, including their procedures for ensuring the reliability of the data and the known or potential reasons for data errors they identified. In addition, we conducted electronic testing of the GLAS data to identify missing end dates and obvious end date errors, such as a date of 1900; compared projects’ end dates to their status; and compared the recipients identified in GLAS with the recipient data we obtained from the agencies. On the basis of this work we determined that the GLAS data on status, end date, recipient, and GLRI funding amounts were not sufficiently reliable for reporting on the progress of GLRI projects. In response to EPA’s written comments on a draft of this report, we interviewed EPA officials about the Environmental Accomplishments in the Great Lakes (EAGL) information system and reviewed EAGL guidance.

As part of our review of GLRI projects, we assessed how the five agencies we reviewed oversaw projects and ensured accountability for GLRI funds. First, we identified key internal controls by reviewing the Standards for Internal Control in the Federal Government (the federal standards for internal control), relevant OMB circulars in effect during the first 4 years of the GLRI, and the Federal Acquisition Regulation (FAR). We then used the following controls to analyze the agencies’ management of GLRI projects: (1) methods to assess the risks of entities applying for GLRI funds; (2) training required of officials responsible for managing financial agreements such as grants, cooperative agreements, and contracts; (3) policies governing site visits; (4) and requirements for GLRI recipients to submit financial and progress reports. Specifically, we analyzed the agencies’ policies and guidance for managing grants, cooperative agreements, and contracts, and project progress and financial reports. We also interviewed, or obtained written responses from, relevant officials for the 19 selected projects, such as agency officials or recipient representatives. In addition, we analyzed the financial reports or other information for the 19 selected projects to determine how much GLRI funds the recipients received to pay for indirect costs.

We conducted this performance audit from January 2014 to July 2015 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Agencies’ Selection Process for 19 Great Lakes Restoration Initiative Projects

We analyzed the interagency agreements and project solicitations (such as requests for applications or proposals) for each of the 19 Great Lakes Restoration Initiative (GLRI) projects we reviewed, and we interviewed relevant Great Lakes Interagency Task Force (Task Force) agency officials to determine the origin of each project and why it was selected. The following tables reflect this analysis for the 19 projects we reviewed that were funded by five Task Force agencies: the Environmental Protection Agency (EPA; see table 7), Fish and Wildlife Service (FWS; see table 8), National Oceanic and Atmospheric Administration (NOAA; see table 9), Natural Resources Conservation Service (NRCS; see table 10), and U.S. Army Corps of Engineers (Corps; see table 11).

EPA officials told us that reviewers consider and score the applicants’ approach on the basis of how they will achieve the desired outputs and outcomes identified in the request for application. Reviewers evaluate reasonableness, necessity, and allowability of costs when they score the budget for each application. Table 7 shows information on EPA’s selection of five GLRI projects.

FWS officials told us that they assess project proposals against the request for application, which is tied to specific GLRI priorities and objectives. Table 8 shows information on FWS’s selection of five GLRI projects.

For grants and cooperative agreements, NOAA assesses proposed projects through the agency’s standard merit review process. The agency’s technical and scientific merit criteria assess whether the proposed approach is technically sound or innovative, among other things. NOAA conducts a review by panel, and NOAA officials said that the agency may also conduct a secondary review through an interagency panel. Officials from the Grants Management Division told us that they work with the program offices to ensure that proposed costs are allowable, reasonable, and necessary.

For contracts, NOAA uses a team of evaluators that are to assign proposals one of five ratings that consider the combined technical merits and risk of the proposal, according to the agency’s acquisition guidance. The team also evaluates the proposal’s cost or price to the government to determine if it is fair and reasonable but does not assign a rating. Table 9 shows information on NOAA’s selection of five GLRI projects.

For cooperative agreements, NRCS officials said that the agency does not issue requests for applications for GLRI funding.the cooperative agreements the agency funds are typically joint efforts between NRCS and the recipient, and the technical aspects of the agreement are worked out between NRCS and the applicant prior to awarding funds. Engineers in the agency’s state offices review the technical and financial aspects of applications for funding, according to NRCS officials.

For financial assistance contracts, NRCS assesses projects through its conservation planning process. Upon eligibility, a conservation planner works with individuals to identify their resource concerns and develop a conservation plan. Applications from producers for GLRI funding are then scored and ranked using what agency officials said is the same process that NRCS uses for all programs. GLRI has specific ranking questions, which the officials said are used by each state in the GLRI. According to NRCS officials, only GLRI–approved core conservation practices and supporting practices can be funded by GLRI. Table 10 shows information on NRCS’s selection of two GLRI projects.

Corps

The technical features of the projects were planned and designed by the Corps. The contract for construction was awarded using plans and specifications developed by the Corps. The Rosewood Park project is under a program to develop projects meeting the objectives of existing strategic plans within the GLRI Action Plan.

Appendix III: Activities and Results of 19 Great Lakes Restoration Initiative Projects

We examined 19 projects paid for with Great Lakes Restoration Initiative (GLRI) funds and carried out by government agencies, nongovernmental organizations, and academic institutions to identify the activities GLRI funds were spent on and the results that were achieved. To do this, we analyzed project agreements and proposals to identify the purpose of the project, progress reports to determine the activities conducted and results achieved, and financial reports and interviews to determine the amount expended for each project. We also interviewed representatives of the recipient organizations to obtain their views on how the projects will contribute to the restoration of the Great Lakes ecosystem. Table 12 reflects these topics, along with whether the project is completed or ongoing. We also included the amount of funding expended on the project, as well as the funding year to identify the specific fiscal year in which the project’s funding was made available because some projects received GLRI funding in multiple years.

Appendix IV: Examples of Internal Controls Used By Selected Great Lakes Interagency Task Force Agencies

We examined key internal controls used by five Great Lakes Interagency Task Force (Task Force) agencies to oversee 19 projects that were conducted using Great Lakes Restoration Initiative (GLRI) funds to better understand how the agencies ensure accountability for the funds. Specifically, we reviewed relevant documents and interviewed agency officials to determine the methods the agencies used to assess the risks of organizations applying to receive GLRI funds; the training the agencies’ required of officials responsible for managing financial agreements such as grants, cooperative agreements, or contracts; the policies governing agency site visits and the number of site visits for the 19 projects; and the types of reports each agency required the funding recipients to submit. In addition, we collected at least one of each type of the required reports, when possible, to confirm that recipients had submitted these documents. The Task Force agencies we reviewed are the Environmental Protection Agency (EPA; see table 13), the Fish and Wildlife Service (FWS; see table 14), the National Oceanic and Atmospheric Administration (NOAA; see table 15), the Natural Resources Conservation Service (NRCS; see table 16), and the U.S. Army Corps of Engineers (Corps; see table 17).

Based on our analysis of agency documents and interviews with agency officials, we found that, to assess applicant risk, EPA required each applicant to certify it has the legal authority to apply for federal assistance and the institutional, managerial, and financial capability (including funds to pay the nonfederal share of the project cost) to ensure proper planning, management, and completion of the project described in the relevant application. EPA officials also told us that the agency searched the names of applicants in the System for Award Management to identify any applicant debarments or suspension, performed a credit check on all applicants applying for funds, and checked for Single Audit Act findings.

Single audits focus on recipients’ internal controls over financial reporting and compliance with laws and regulations governing U.S. federal awardees. They also provide key information about the federal grantee’s financial management and reporting. EPA required project officers to complete grant training to be eligible to manage an EPA grant and to take a refresher course every 3 years. For its site visits, EPA targeted a minimum of 10 percent of GLRI funding recipients for advanced monitoring—an in-depth review of the recipient’s project—which officials told us is the same percentage for all EPA grants and not just GLRI. EPA required each of its recipients to submit very similar types of reports (see table 13).

Based on our analysis of agency documents and interviews with agency officials, we found that, to assess applicant risk, FWS officials interviewed organizations with which they are less familiar to understand their financial viability and management processes. FWS officials also searched the names of all applicants in the System for Award Management to identify any applicant debarments or suspension. FWS required 24 hours of training for those staff with authority to approve awards, but it required no training for project officers overseeing awards, or reviewing and ranking applications, according to FWS officials. FWS does not have a requirement for a certain number of site visits. However, agency officials told us that site visits are conducted more often for complex and expensive projects. FWS officials also told us that the agency has an on-the-ground presence through 34 field offices that is more extensive than any other Task Force agency. FWS reporting requirements varied by project (see table 14).

Based on our analysis of agency documents and interviews with agency officials, we found that NOAA used different oversight processes depending on the type of financial agreement involved; i.e., grants, cooperative agreements, or contracts. To assess applicant risk for grants and cooperative agreements, NOAA officials said that they perform a credit check for organizations applying for funds, check the System for Award Management for exclusions from procurement or nonprocurement activities for those applicants, check the agency’s “do not pay” list for delinquent debts, and they also check for Single Audit Act findings. In addition, NOAA reviews applicants’ past performance. If an organization is deemed high risk, NOAA will impose a special award condition, such as requiring the recipient to submit financial or progress reports more frequently, according to agency officials. The imposed special award condition remains on the award until the recipient demonstrates compliance. For awards that are made competitively, NOAA evaluates applications using criteria set forth in the applicable program regulations and announcement of federal funding opportunity. According to NOAA officials, training for officials who managed grants and cooperative agreements was specific to each of NOAA’s program offices. Within the National Ocean Service, which has responsibility for the five NOAA GLRI projects we reviewed, program officers and grant coordinators were required to complete a certification program, which required completion of a 3-day course on grants and cooperative agreements and annual training on grants. The National Ocean Service also required training on NOAA’s Grants Online system. NOAA did not require site visits for all projects funded through grants and cooperative agreements. According to NOAA officials, the decision to conduct a site visit is based on need and the availability of funds, and high-risk recipients are a priority. Officials noted that, as a matter of standard practice, agency staff conduct site visits and work closely with cooperative agreement recipients for all habitat restoration projects in Areas of Concern.

To assess contractor risk, a NOAA team evaluates proposals and assigns a rating, using criteria outlined in the request for proposals for the relevant project. The team considers the past performance of the entities offering proposals and assigns them each one of five possible ratings for past performance. NOAA’s contract management staff are to be certified through the Federal Acquisition Certification Contracting Officer Representative Certification Program, which requires a minimum of 40 hours of training and includes additional training requirements for staff managing contracts valued at more than $150,000. Site visits are not required for NOAA contracts, according to NOAA officials. NOAA program offices may determine the need for site visits based on the type of work funded. NOAA reporting requirements varied by project (see table 15).

Based on our analysis of agency documents and interviews with agency officials, we found that NRCS provided most of its GLRI funds through financial assistance contracts to agricultural producers who carry out different conservation practices on their land using NRCS GLRI funding.According to NRCS officials, the agency does not assess applicants’ risk because it cannot deny program funds to a producer based on perceived financial or performance capabilities. Instead, the agency informally assesses applicants’ performance capabilities as part of the conservation planning process and provides technical assistance to producers. NRCS officials told us that the agency conducts training in contract management, usually annually, but did not provide us with documentation of this training. Agency officials said that NRCS conducts site visits several times a year for financial assistance contracts.

NRCS also provided GLRI funding through cooperative agreements. According to agency officials, the majority of the agreements are with entities that have previously partnered with the agency, such as state programs or local conservation districts. For new applicants, NRCS officials said that they conduct assessments using Single Audit Act findings, among other things. The officials told us that there is no formal process for reviewing applicants that have worked with the agency before. An NRCS official told us that the agency required annual program management training of its program managers, but did not provide us with documentation of this training. NRCS officials also told us that the agency did not have specific requirements for conducting site visits to projects funded through cooperative agreements, which they said NRCS generally used for capacity building and not for site-specific projects. NRCS reporting requirements varied by project (see table 16).

Corps

Based on our analysis of agency documents and interviews with agency officials, we found that the Corps primarily used contracts to accomplish its GLRI work. In addition, Corps officials told us that the technical features of their projects were planned and designed by Corps staff, and contracts for projects were awarded using plans and specifications developed by the agency. To assess contractor risk, according to Corps officials, the contractor must provide proof of financial capability to do the work prior to receiving the award. Corps officials told us that contracting officers must undergo training including, but not limited to, 40-hour blocks of quality assurance/quality control classes. The Corps did not perform site visits because Corps officials worked at each project site, and other Corps officials visited the sites on a regular basis (see table 17).

Appendix V: Indirect Costs for 19 Great Lakes Restoration Initiative Projects

We analyzed indirect cost information for the 19 Great Lakes Restoration Initiative (GLRI) projects that we reviewed and compared the amount of GLRI funds expended on indirect costs for each project with the overall amount of GLRI funds that had been expended on the project. To do this, we reviewed the Federal Financial Reports or other information provided by the recipients of GLRI funds that conducted the 19 projects we Indirect costs are those that cannot be identified with a reviewed.program objective. That is, they represent the expenses of doing business that are not readily identified with a particular grant or contract, but are necessary for the general operation of the organization. These include, for example, building utilities and administrative staff salaries. In comparison, direct costs can include salaries, equipment, and travel, among other things, that can be specifically identified with the objective of a particular grant or contract. Table 18 shows the GLRI funds expended on indirect costs by the recipients for the 19 projects we reviewed.

Appendix VI: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, Susan Iott (Assistant Director), Krista Breen Anderson, Cheryl Arvidson, Mark Braza, Peter Del Toro, Armetha Liles, Kimberly McGatlin, Sonia Saini, Jerry Sandau, Jeanette Soares, Kiki Theodoropoulos, and Michelle K. Treistman made significant contributions to this report.