United States EPA 230-01 -91 -002
Environmental Protection February 1991
Agency
&EPA A Review of
ERA'S Great Lakes
Program
Report to the
Committees on
Appropriations
Printed or? Recycled Paper
' ^'A^Xff
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
FEB T 1991
OFFICE OF
THE ADMINISTRATOR
Honorable Bob Traxler
Chairman
Subcommittee on VA, HUD, and Independent Agencies
Committee on Appropriations
House of Representatives
Washington, D.C. 20515-6022
Dear Mr. Chairman:
I am pleased to submit the enclosed report in response to
the requirement of House Report 101-556 for a full review of the
effectiveness and efficiency of the Environmental Protection
Agency's Great Lakes National Program Office and associated
activities. I recognize we are submitting this Report somewhat
behind schedule, and trust that the quality of the Report will
compensate for its delayed arrival.
As you may know, the Administrator and I are placing very
high priority on revitalizing the Great Lakes program using a
cooperative, integrated effort to direct a critical mass of
resources to address problems on a holistic, ecosystem basis.
The hallmark of our effort will feature pollution prevention as
the preferred option for reducing risk. This will be buttressed
by the Agency's traditional regulatory activities, which will be
integrated across program lines to craft specific solutions
tailored to local circumstances. In addition, EPA will make use
of a much broader array of tools, including market incentives,
education, and information. In putting the pieces together, we
will seek the support and involvement of the States and the
national governments and citizens of the United States and
Canada.
As you might imagine, this is an ambitious undertaking—the
first of its kind for EPA, and a model for many of EPA's programs
in the future. The Congressional requirement to conduct a full
review of the effectiveness and efficiency of our activities in
the Great Lakes offered us an opportunity to conduct a probing
review of the current program, and, based on the findings, to
take appropriate actions to improve and strengthen the foundation
of the program from which we will mount our new multi-media
attack on all sources of pollution to the Great Lakes ecosystem.
U.S. Environmental Protection Agency
GLNPO Library Collection (PL-12J)
77 West Jackson Boulevard,
Chicago, IL 60604-3590
-------
I think you will find that this report contains a critical
analysis of key issues and weaknesses that may have impeded our
progress in the Great Lakes, as well as actions we currently have
underway to improve our performance. Clearly, we are still in
the early stages of this very ambitious effort, and there is much
more work to be done. However, we believe the findings of this
report have already been extremely helpful in shaping our
thinking about future work in the Great Lakes.
We will keep you fully apprised of our efforts as we proceed
with implementation of our integrated approach to protecting and
restoring the Great Lakes ecosystem. In the meantime, if there
are particular aspects of this report that are of special
interest to you, please let us know and we will try to respond to
your questions or concerns.
Henry Habicht II
Deputy Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
FEB T 1991 OFFICEOF
THE ADMINISTRATOR
Honorable Barbara A. Mikulski
Chair
Subcommittee on VA, HUD, and Independent Agencies
United States Senate
Washington, D.C. 20510-6032
Dear Madam Chair:
I am pleased to submit the enclosed report in response to
the requirement of House Report 101-556 for a full review of the
effectiveness and efficiency of the Environmental Protection
Agency's Great Lakes National Program Office and associated
activities. I recognize we are submitting this report somewhat
behind schedule, and trust that the quality of the report will
compensate for its delayed arrival.
As you may know, the Administrator and I are placing very
high priority on revitalizing the Great Lakes program using a
cooperative, integrated effort to direct a critical mass of
resources to address problems on a holistic, ecosystem basis.
The hallmark of our effort will feature pollution prevention as
the preferred option for reducing risk. This will be buttressed
by the Agency's traditional regulatory activities, which will be
integrated across program lines to craft specific solutions
tailored to local circumstances. In addition, EPA will make use
of a much broader array of tools, including market incentives,
education, and information. In putting the pieces together, we
will seek the support and involvement of the States and the
national governments and citizens of the United States and
Canada.
As you might imagine, this j.s an ambitious undertaking—the
first of its kind for EPA, and a model for many of EPA's programs
in the future. The Congressional requirement to conduct a full
review of the effectiveness and efficiency of our activities in
the Great Lakes offered us an opportunity to conduct a probing
review of the current program, and, based on the findings, to
take appropriate actions to improve and strengthen the foundation
of the program from which we will mount our new multi-media
attack on all sources of pollution to the Great Lakes ecosystem.
-------
I think you will find that this report contains a critical
analysis of key issues and weaknesses that may have impeded our
progress in the Great Lakes, as well as actions we currently have
underway to improve our performance. Clearly, we are still in
the early stages of this very ambitious effort, and there is much
more work to be done. However, we believe the findings of this
report have already been extremely helpful in shaping our
thinking about future work in the Great Lakes.
I trust you will find this report fully responds to your
requirements and needs. If there are particular aspects of this
report that are of special interest to you, please let us know
and we will try to respond to your questions or concerns.
Si
F. Henry Habicht II
Deputy Administrator
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A REVIEW OF
EPA'S GREAT LAKES
PROGRAM
REPORT TO THE
COMMITTEES ON
APPROPRIATIONS
February 6, 1991
Program Evaluation Division
Office of Regulatory Management and Evaluation
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
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EXECUTIVE SUMMARY
Considerable progress has been made toward improving water
quality in the Great Lakes Basin under the Clean Water Act and other
environmental statutes EPA and the States administer. Yet, the Nation
still faces many challenges in restoring the chemical, physical and biological
integrity of the Great Lakes, a goal which is embodied in the United
States-Canada Great Lakes Water Quality Agreement. If EPA and the
States are to succeed in restoring the Great Lakes, they will need to adjust
their traditional media-by-media orientation in favor of a more integrated
environmental management approach that emphasizes pollution
prevention as the preferred alternative.
EPA faces many management challenges in shifting from a
traditional media-by-media approach to a more integrated, pollution
prevention orientation. This report, prompted by a direction in the Fiscal
Year 1991 House Appropriations Committee report that EPA conduct a
full review of the effectiveness and efficiency of the current Great Lakes
office and associated activities, identifies those management challenges.
SUMMARY:
STUDY RESULTS
AND CURRENT AGENCY ACTION
GOALS AND PRIORITIES
Results
The Agency has not fully succeeded in setting clear environmental
goals and priorities for its Great Lakes activities; without clearly articulated
environmental goals and priorities to drive the Agency's decisions and
actions, its efforts have lacked a focus. In addition, the Agency has set
expectations too high for what the United States can accomplish on the
Great Lakes, and the Agency historically has been unwilling to say that it
and the States cannot do everything. This has lead to fragmentation of
resources and efforts.
The Agency must establish environmental risk-based goals and
priorities for its Great Lakes effort, and let them drive EPA and State
Great Lakes decisions and activities. Activities that do not support the
Agency's ability to meet these goals and priorities should not be
undertaken.
A Review of EPA's Great Lakes Program in
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Current Agency Action
The Agency has already taken a number of steps to implement
many of the recommendations regarding the need to establish risk-based
goals and priorities for protection and restoration of the Great Lakes
ecosystem, with prevention as the preferred alternative. Through the
Great Lakes Advisory Committee, the Agency is developing a Five-Year
Strategy for the Great Lakes, a Fiscal Year 1991 Action Plan, and a Pollution
Prevention Strategy for the Great Lakes, which more clearly define its
operating principles for its Great Lakes effort, and the Agency's goals,
priorities, and strategy for restoring the Great Lakes. The Agency is also
developing measures of environmental progress and success to gauge the
effectiveness of EPA and State Great Lakes efforts. In Fiscal Year 1992,
the Agency plans to launch a coordinated multimedia Great Lakes Basin
Initiative to promote faster and more effective action to improve the water
quality of the Great Lakes.
NEED FOR INTEGRATING RESOURCES
Results
The Great Lakes National Program Office (GLNPO) has not had—
nor will it likely ever have—the authority or resources to remedy single-
handedly all the complex problems of the Great Lakes. Others within
and outside EPA possess this authority, and must be viewed as GLNPO's
partners in the Nation's efforts to address the Great Lakes. In addition,
the Agency has not been fully successful in targeting its limited resources
in an integrated way on those activities that will lead to the greatest
environmental results. If EPA and the States are to succeed in improving
the Great Lakes, each must focus attention on how to creatively target
available resources to the Agency's priorities for the Great Lakes.
Current Agency Action
The Agency is responding aggressively to these concerns. In
developing the Five-Year Strategy and Fiscal Year 1991 Action Plan, the
Agency is emphasizing an integrated approach to environmental
protection and targeting a critical mass of limited resources to reducing
risk on a priority basis. The Great Lakes Advisory Committee has already
proved to be an effective body for creating an EPA partnership and
garnering commitments from various EPA offices for Great Lakes work.
In the near future, the Great Lakes Advisory Committee plans to address
the issue of expanding its efforts to forge partnerships with other Federal
agencies possessing expertise and resources that can contribute to
protection and restoration of the Great Lakes ecosystem.
iv A Review of EPA's Great Lakes Program
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NEED FOR CLEAR EPA LEADERSHIP
Results
There has been ongoing confusion about the role of the Regional
Administrator for Region V—as the Great Lakes National Program
Manager—and his relationship to the Assistant Administrator for Water.
Assistant Administrators, not Regional Administrators, typically serve as
National Program Managers. In addition to the Great Lakes National
Program Manager, the Assistant Administrator for Water, due to her focus
on water issues, is often in the position of speaking for the Agency on
Great Lakes policy and budget issues.
Since a Regional Administrator is by definition a cross-media
manager, the Regional Administrator for Region V should continue to
serve as the Great Lakes National Program Manager, and be responsible
for all functions which GLNPO performs. The GLNPO Director should
continue to report directly to the Great Lakes National Program Manager.
The Great Lakes National Program Manager and the Assistant
Administrator for Water should refine their existing agreement on the
roles of each on Great Lakes issues.
Current Agency Action
To respond to the need for greater leadership, the Agency recently
selected experienced managers to fill positions which will be critical to the
Agency's successful implementation of its Great Lakes strategy. A new
GLNPO Director and Region V Water Division Director were selected in
the last few months. The former Deputy Regional Administrator for EPA's
Region X office was recently chosen to serve in the same capacity for the
Region V office. In April, 1990, the EPA Administrator named the Deputy
Administrator to be the Chairman of Great Lakes Advisory Committee.
Also, the Great Lakes National Program Manager and Assistant
Administrator for Water are now engaged in discussions to refine their
agreement on their roles.
NEED TO DEFINE THE ROLE OF GLNPO
Results
GLNPO's role in the Agency continues to be unclear for several
reasons. First, while GLNPO's primary role in the Agency is to coordinate
the Agency's Great Lakes efforts, GLNPO has favored its role as an
implementor of environmental programs. GLNPO may have a legitimate
role to play in developing and implementing Great Lakes programs; yet,
its mindset has been to perform these activities itself. In some cases,
however, it may make more sense for GLNPO to enlist the assistance of
others to perform these activities. Second, GLNPO has performed activities
that are more typically the responsibility of the Regional Offices, including
negotiating grant agreements with the States and reviewing permits. Third,
GLNPO has not been fully successful in getting other EPA offices to
A Review of EPA's Great Lakes Program v
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undertake Great Lakes activities. This is primarily because it has
minimally participated in Agency systems and processes which are
recognized as being the key mechanisms for getting other EPA offices
and the States to undertake activities in support of EPA priorities. Rather
than focusing on its role as implementor, GLNPO's primary role should
be to serve as a coordinator. In short, GLNPO should assume the role of
orchestra conductor rather than trying to play all of the instruments in
the orchestra itself. In serving as the Agency's coordinator of Great Lakes
activities, GLNPO should use the established Agency systems and
processes to gain commitments from other EPA offices and the States for
Great Lakes work.
Current Agency Action
Changes are already occurring in this area. The roles that Region
V and GLNPO now are playing are consistent with the roles recom-
mended in this report. While GLNPO will continue to implement some
selected activities, the Agency and GLNPO are working to tailor GLNPO's
activities to address specific needs of others within and outside the Agency,
and to rely on other parts of the Agency to assume responsibility for
tasks that they are better equipped to handle (e.g., State grant negotiations).
Finally, GLNPO is beginning to integrate itself more into Agency pro-
cesses and systems (e.g., annual planning process) to make certain that
the Agency's goals and priorities for the Great Lakes are taken into account.
NEED TO IMPROVE
COMMUNICATION AND
COORDINATION
Results
While a number of mechanisms exist to facilitate communication
and coordination between GLNPO and the Regional Offices, there is room
for improvement. Senior management in GLNPO and the Regional Offices
has lacked a full understanding of the various initiatives each is
undertaking and the relationship of those initiatives to the Great Lakes
work in which their offices are engaged. If GLNPO is to succeed as the
chief coordinator, communicator and integrator of the U.S.'s Great Lakes
activities, it must become the Agency's chief advocate for the Great Lakes.
To help it effectively play this role, GLNPO should consider specific
changes to its current approach (e.g., establishment of a GLNPO liaison
office in Washington, D.C., the circulation of weekly or bi-weekly status
reports).
vi A Review of EPA's Great Lakes Program
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Current Agency Action
In the last few months, GLNPO and Region V have made significant
improvements in this area. GLNPO and Region V are effectively
coordinating the development of an integrated, risk-based Five-Year
Strategy, the Fiscal Year 1991 Action Plan, and the Pollution Prevention
Strategy, including providing all other EPA offices and States with an
opportunity for input. In addition, GLNPO and Regions n, IE, and V
have met with the State environmental Directors and representatives of
the various Governors to explain EPA's new approach and to enlist State
support and enthusiasm. In the near future, these outreach efforts will be
expanded to other Federal agencies with a vested interest in the Great
Lakes ecosystem.
NEED TO CONVEY
GREAT LAKES ACCOMPLISHMENTS
Results
EPA needs to do a better job of communicating Agency and State
successes in the Great Lakes, the complexities of the environmental
problems that remain, and the approach of EPA and the States for meeting
those challenges. Communication about EPA's efforts have generally
emphasized accomplishments of GLNPO and what work remains, rather
than on the contributions of other EPA offices, the States, and other Federal
agencies. In addition, the Agency has not been fully successful in keeping
Members of Congress informed of the Agency's progress on the Great
Lakes; the primary vehicle for interacting with Members of Congress has
been Congressional hearings, where EPA's performance in addressing the
Great Lakes has been heavily criticized.
To remedy these problems, EPA should develop an Agency strategy
for communicating its accomplishments on the Great Lakes, the
environmental challenges remaining, and EPA's program for meeting those
challenges. The emphasis of this communication strategy should be on
actions the Agency, not just GLNPO, should take. The Agency also must
put greater emphasis on keeping Members of Congress and their staff
informed through various mechanisms (e.g., meetings and briefings) on
the Agency's progress in restoring the Great Lakes.
Current Agency Action
The Agency is developing a Great Lakes communication strategy
to respond to these concerns. The strategy will focus on presenting the
problems in terms the public can understand, and on enlisting public
support and assistance for activities to restore and protect the Great Lakes.
In addition, the Agency has already taken steps to provide Members of
Congress and their staffs with additional information about the Agency's
Great Lakes activities, and has instituted a system to track progress on
meeting commitments made at hearings and in legislation.
A Review of EPA's Great Lakes Program mi
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NEED TO IMPROVE
ADMINISTRATIVE MANAGEMENT
Results
GLNPO and Region V Planning and Management Division have
made progress in the administrative management of their programs since
the 1989 management review performed by the Office of Administration
and Resources Management (OARM). Improvements have been made in
oversight and tracking of the GLNPO budget to ensure compliance with
Congressional mandates. The Region V Planning and Management
Division has generally implemented the grants-related recommendations
from the 1989 report, including recommendations discussing the need for
upgrading information in the Grant Information Control System. No
major problems were discovered in the contracting area, and significant
improvements have been made in the GLNPO and Planning and
Management Division internal control functions. Lastly, the Planning
and Management Division has continued to effectively deliver to GLNPO
basic information resources management services.
While improvements have been made, some changes are still
needed in GLNPO's administrative management. Overall, the Region V
Planning and Management Division should continue to expand its focus
and provide the leadership and professional management support needed
for GLNPO to succeed in the Agency. The Planning and Management
Division must go beyond providing the requisite support services, and
follow its "Commitment to Quality" approach to continually gauge and
assess GLNPO's service needs.
In addition, the Agency must face the challenge of how to best
tailor a budget process that responds to the multimedia nature of the
program, while comporting with the Agency's overall framework for
budgeting.
Current Agency Action
In recent months, new leadership in GLNPO and Region V have
taken steps to redirect the administrative management of GLNPO. The
GLNPO Director and Deputy Regional Administrator for Region V have
demonstrated their awareness of the administrative issues facing GLNPO,
and a willingness to share responsibility for resolving those issues. Senior
management is also currently assessing the best way to modify existing
systems and processes in a number of areas, and to clarify accountability
for budget preparation and allocation decisions. The Agency recognizes
the difficulties associated with budgeting for an integrated ecosystem
approach that cuts across traditional media program elements, and will
use the Great Lakes as a pilot for addressing and resolving these complex
issues.
viii A Review of EPA's Great Lakes Program
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TABLE OF CONTENTS
Executive Summary in
Abbreviations xi
I. Introduction 1
n. Scope and Methodology 3
Scope 3
Methodology 4
III. Environmental Accomplishments and Challenges 5
Nutrient Loadings 5
Toxics 6
Remedial Action Plans 13
Lakewide Management Plans 17
TV. Results of Review 19
Goals and Priorities 20
Findings 20
Recommendations 22
Current Agency Action 23
Resources 25
Findings 25
Recommendations 26
Current Agency Action 26
EPA Leadership 27
Findings 27
Recommendations 28
Current Agency Action 30
Roles 30
Findings 30
Recommendations 33
Current Agency Action 37
A Review of EPA's Great Lakes Program ix
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IV. Results of Review Continued
Communication and Coordination 38
Findings 38
Recommendations 39
Current Agency Action 41
Conveying Great Lakes Accomplishments 42
Findings 42
Recommendations 43
Current Agency Action 44
Administrative Management 44
Budget 45
Findings 45
Recommendations 45
Grants Management 46
Findings 46
Recommendations 46
Contracts Management 46
Findings 46
Recommendations 47
Financial Management 47
Findings 47
Recommendations 47
Management Integrity 48
Findings 48
Recommendations 48
Information Resources Management 48
Findings 48
Recommendations 49
Current Agency Action 49
Appendix 51
Studies and Reviews 51
Agency Review Team 52
x A Review of EPA's Great Lakes Program
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ABBREVIATIONS
AA: EPA Assistant Administrator
AOCs: Areas of Concern
ARCS: Assessment and Remediation of
Contaminated Sediments
DRA: EPA Deputy Regional Administrator
EPA: U.S. Environmental Protection Agency
FMFIA: Federal Managers' Financial Integrity Act
GAO: U.S. General Accounting Office
GLNPO: Great Lakes National Program Office
IJC: International Joint Commission
LMPs: Lakewide Management Plans
NPM: National Program Manager
OARM: Office of Administration and Resource Management
OPPE: Office of Policy, Planning and Evaluation
RA: EPA Regional Administrator
RAPs: Remedial Action Plans
STARS: Strategic Targeted Activities for Results System
USFWS: U.S. Fish and Wildlife Service
WQA:
U.S.-Canada Water Quality Agreement
A Review of EPA's Great Lakes Program xi
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I
INTRODUCTION
Considerable progress has been made toward controlling pollution
entering the Great Lakes Basin under the Clean Water Act and other
environmental statutes that the United States Environmental Protection
Agency (EPA) and the States administer. The most notable progress relates
to the cleanup of conventional pollutants in municipal and industrial
discharges to surface waters through EPA and State permitting programs.
These controls have been especially successful in reducing phosphorus
discharges, a problem which once threatened the viability of the Great
Lakes.
Yet, the Nation still faces many challenges in restoring the chemical,
physical and biological integrity of the Great Lakes, a goal which is
embodied in the United States-Canada Great Lakes Water Quality
Agreement (WQA). Toxic pollutants continue to enter the Great Lakes
through various sources, including urban and agricultural runoff, air
deposition, and Superfund sites, among others. In addition, the sediments
of the Great Lakes contain toxic chemicals which, although production
and use of many of them were banned years ago, continue to affect human
health and the quality of the Great Lakes ecosystem.
These environmental problems will be difficult to solve. The Agency
has recognized that to address the multiple loading problems in the Great
Lakes and the interdependent nature of the ecosystem, EPA and the States
will need to adjust their traditional media-by-media orientation in favor
of a more integrated environmental management approach that emphasizes
pollution prevention as the preferred alternative. In addition, the Agency
recognizes that it will need to devote more attention to working with
other Federal agencies and the government of Canada to bring all mecha-
nisms and approaches to bear if an ecosystem approach to the Great Lakes
is to be successful.
This report identifies the management challenges facing EPA and
the States for taking an ecosystem approach to pollution problems in the
Great Lakes. It also identifies ways in which the EPA needs to adjust its
current method of managing its environmental programs to help foster an
Agency-wide ecosystem approach to the Great Lakes. Section II discusses
the scope and methodology of this review. Section in describes in greater
detail the environmental accomplishments and challenges that lie ahead
for EPA, the States, and the Nation. Section IV covers the results from the
review, including findings, recommendations, and current Agency actions
to address the recommendations.
A Review of EPA's Great Lakes Program 1
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II
SCOPE AND
METHODOLOGY
SCOPE
The House Appropriations Committee, in the Fiscal Year 1991
appropriations report, directed EPA to undertake a review of the Great
Lakes National Program Office. More specifically, the report says, ". . .
EPA (shall) conduct a full review of the effectiveness and efficiency of the
current Great Lakes office and associated activities and submit a report to
the Committees on Appropriations by December 31,1990." Further dis-
cussions with the Chairman's staff clarified that the Committee was inter-
ested in having the report provide information on: EPA's accomplish-
ments in restoring water quality in the Great Lakes and in fulfilling the
requirements of the WQA and Section 118 of the Clean Water Act; prob-
lems that the Great Lakes National Program Office (GLNPO) has experi-
enced, including management issues; and an update of a 1989 manage-
ment review undertaken by EPA's Office of Administration and Resources
Management (OARM).
In response to this directive, the Deputy Assistant Administrator
for Water asked the Program Evaluation Division in the Office of Policy,
Planning and Evaluation to coordinate development of the overall report
and develop the findings and recommendations covering the effective-
ness of GLNPO's program management. The Office of Marine and Estua-
rine Protection in the Office of Water prepared the section of the report on
the Agency's environmental accomplishments and remaining environ-
mental challenges. OARM was responsible for developing findings and
recommendations on GLNPO's administrative management.
The Agency's review sought to meet the Congressional mandate
through identifying practical ways to improve the effectiveness and effi-
ciency of GLNPO and to strengthen the participation of other EPA offices
in the Great Lakes program. Toward these ends, the review identified the
principal strengths and weaknesses of the current program and identified
institutional, programmatic, and administrative changes that could be made
to take advantage of the strengths and remedy the weaknesses.
More specifically, the review examined: whether there are
appropriate processes in place for setting the goals of and establishing
priorities for EPA's Great Lakes activities; whether GLNPO and other
EPA offices have appropriate and well-defined roles; the effectiveness of
current Agency mechanisms for facilitating coordination; GLNPO's
effectiveness in taking advantage of the capabilities of other EPA offices
and the States; the effectiveness of GLNPO's administrative management,
including contracts, grants, budgeting, financial management, management
controls, information resources, Congressional relations, and organizational
A Revkw of EPA's Great Lakes Program 3
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issues; and the environmental accomplishments and challenges which lie
ahead. Since the Agency is in the process of implementing many of the
recommendations from the review, this report also discusses the activities
which are underway.
Due to time limitations, this review did not include an examination
of EPA's performance in fulfilling every requirement of Section 118 of the
Clean Water Act or of the WQA. Nor did it include an in-depth analysis
of the effectiveness of EPA's interactions with other Federal agencies, the
International Joint Commission (IJC), or Environment Canada.
METHODOLOGY
The Program Evaluation Division interviewed about 60 EPA and
State officials for this review. OARM interviewed about 30 officials for
its review of GLNPO's administrative management. The Program Evalu-
ation Division and OARM interviewed officials from: GLNPO; Region V,
including the Regional Administrator (RA) and Deputy Regional Admin-
istrator (DRA), and senior managers and staff from the Water, Air, Envi-
ronmental Services, and Policy and Management Divisions; Region II
and m senior managers and staff from the Water, Hazardous Waste, and
Environmental Services Divisions; senior managers from EPA Headquar-
ters; and State environmental Directors and their staffs from Michigan,
Wisconsin, Ohio, Indiana, and New York.
In addition, the Program Evaluation Division and OARM reviewed
numerous documents, including the following: the WQA; Section 118 of
the Clean Water Act; Agency Operating Guidance; transcripts from
Congressional hearings on the Great Lakes; internal memoranda and
budget documents; and GLNPO's strategy for 1988 to 1993.
Finally, studies of GLNPO which have been conducted over the
years were reviewed. These include studies undertaken by the General
Accounting Office (GAO), the Inspector General, and OARM. The
Appendix provides additional information on these studies.
4 A Review of EPA's Great Lakes Program
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Ill
ENVIRONMENTAL
ACCOMPLISHMENTS
AND CHALLENGES
EPA and the States have made significant progress in controlling
pollutants entering the Great Lakes. Yet, many challenges still remain.
The following discusses these accomplishments and challenges in greater
detail.
NUTRIENT LOADINGS
The first signs of eutrophication appeared in nearshore areas of
the Great Lakes during the first half of this century. Problems with
increased algal growth which triggered oxygen depletion and population
reductions of fish and other organisms continued to spread. By I960, a
lakewide eutrophication problem had developed in Lake Erie, which was
especially vulnerable with its shallow basin, highly urbanized shores, and
tributaries that drain extensively farmed soils. During the 1960s, cycles of
algal blooms, decay and oxygen depletion due to enrichment by excess
nutrients became annual events. As a result, the public demanded action.
The Federal government responded by requiring secondary treatment of
sewage, tightening controls on industrial discharges and instituting Federal
enforcement actions on the Great Lakes that resulted in the establishment
of phosphorus limits on all municipal dischargers.
Substantial reductions in phosphorus concentrations and associated
reductions in blue-green algae have been achieved in the Great Lakes
since the U.S. and Canada began a concerted effort to reduce phosphorus
loadings. This effort continued through two vehicles. Congress passed
the Clean Water Act, and the U.S. and Canada entered into the joint WQA
which has served as the framework for cooperative binational efforts to
restore and maintain the Great Lakes system. As the WQA was amended
in 1978,1983, and 1987, more stringent phosphorus load reduction targets
were adopted for Lakes Ontario and Erie and Saginaw Bay in Lake Huron.
Phosphorus loadings from point sources have been reduced by an
estimated 80 to 90 percent through regulation and financial assistance for
environmental controls on point sources. Financial assistance has been
provided primarily for the upgrading of sewage treatment plants. Over
$8 billion in Federal and State support has been invested in the Great
Lakes Basin for construction of municipal sewage treatment facilities.
The WQA mandates that municipal waste water treatment facilities
meet a milligram per liter (mg/1) effluent limit for phosphorus to achieve
lakewide target nutrient load reductions. All major U.S. dischargers as a
group are currently meeting the 1 mg/1 phosphorus goal. Individual
dischargers that are not meeting it are being offset by dischargers that are
releasing effluent with less than 1 mg/1 of phosphorus. The targets for
phosphorus loadings identified in the WQA have been achieved for the
open waters in Lakes Superior, Michigan, and Huron through reduced
A Review of EPA's Great Lakes Program 5
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direct discharges of wastes from industrial and municipal sources and
detergent phosphate bans. Detergent phosphate bans have been adopted
in all of the Great Lakes states.
Further efforts are needed to meet the target phosphorus loadings
for Lakes Ontario and Erie, and Saginaw Bay. More effective programs
to control nonpoint sources of phosphorus are required to attain phos-
phorus load reductions in these areas. A U.S. plan for phosphorus load
reductions to these three areas was submitted to the IJC in June, 1986.
The five-year plan focused on the management of crop residues to pre-
vent nutrient loss by soil erosion, proper management of livestock wastes,
and proper management of commercial fertilizers. In 1988, the Great
Lakes Phosphorus Task Force evaluated progress in reducing phosphorus
loading from nonpoint sources. Substantial progress has been made in
reducing nonpoint phosphorus loads to Lake Ontario and Saginaw Bay.
Over half of the targeted load reduction has been met in Lake Ontario
and more than 85 percent of the allocated load reduction has been attained
in Saginaw Bay. Similar success in limiting phosphorus loadings from
nonpoint sources has not been realized for Lake Erie. Nonpoint phos-
phorus loads have been reduced by no more than 25 percent in Lake Erie.
The challenge remains to sharply reduce phosphorus inputs to Lake Erie,
particularly from agricultural nonpoint sources in Ohio.
The Agency has provided funding for recent projects to track
conservation tillage practices in Indiana, Michigan, and Ohio using remote
sensing techniques and to evaluate conservation tillage practices in Ohio.
Based on the results of these studies, EPA and the States will determine
whether nonpoint source control programs are capable of providing the
level of reduction required to meet the phosphorus objectives of the WQA.
If further reductions are necessary, recommendations for additional
measures will be developed.
In summary, nutrient loadings to the Great Lakes decreased
significantly in the 1980s. Decreased algal growth and increased dissolved
oxygen levels provide clear evidence that accelerated eutrophication
appears to have stopped in the open waters of the Great Lakes. Annual
open lake phosphorus monitoring programs were completed for all five
lakes in 1988. Both the U.S. and Canada are close to achieving their
phosphorus reduction targets. Implementation of nonpoint source control
programs will be key to fully meeting these objectives.
TOXICS
With the problem of eutrophication largely under control, the focus
has shifted to addressing the problem of toxic contaminants in the Great
Lakes ecosystem. Toxic contamination was first recognized as a
widespread problem in the Great Lakes in the 1960s when DDT, PCBs,
and mercury were found to be affecting the reproduction of birds and
animals and posing a threat to human health through fish consumption
and other direct exposure. The number, sources, distribution, and effects
of toxic substances in the Lakes were poorly understood. Since then,
research related to toxic pollution has helped define the magnitude of the
problem.
6 A Review of EPA's Great Lakes Program
-------
It is now known that toxic chemicals enter the waters of the Great
Lakes through industrial and municipal discharges, land runoff, contami-
nated bottom sediments, atmospheric deposition, contaminated ground
water, and accidental spills from vessels. The IJC's Water Quality Board
has identified 362 chemicals of concern in the Great Lakes ecosystem,
including persistent toxics of priority concern (e.g., DDT, PCBs, dieldrin,
dioxin, mirex, lead, mercury).
The largest concentrations of toxic pollutants in the Great Lakes
are located in the 42 Areas of Concern (AOCs) identified in 1981 by the
Water Quality Board of the IJC Toxic pollutants have also been found at
many other locations outside the AOCs, primarily in sediments. At present,
no concentrations of chemicals or heavy metals are found in the lakes at
levels that are known to be acutely toxic to organisms during brief expo-
sure. A major concern is the possible long-term effects of prolonged
exposure to small quantities of toxic substances through bioaccumulation
and biomagnification and through synergistic actions. Figure 1 illustrates
the impact of bioaccumulation and biomagnification of DDT through the
food chain. Effects of toxic pollutants that have been measured in the
Great Lakes include health risks to humans along with deformities, tumors,
and reproductive disorders in all types of wildlife.
Figure 1
Accumulation and Amplification of Organic Contaminants
in an Aquatic System
DDT in Fish-Eating Birds
25 ppm
DDT in Large Fish
2 ppm
DDT in Small Fish
0.5 ppm
DDT in Zooplankton
0.04 ppm
DDT in Water
0.000003 ppm
or
3ppt
Source: Science Applications International Corporation, "Green Bay/Fox River Mass Balance
Study, Executive Summary," November, 1988.
A Review of EPA's Great Lakes Program 7
-------
United States EPA 230-01 -91 -002
Environmental Protection February 1991
Agency
&EPA A Review of
ERA'S Great Lakes
Program
Report to the
Committees on
Appropriations
Printed or? Recycled Paper
' ^'A^Xff
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
FEB T 1991
OFFICE OF
THE ADMINISTRATOR
Honorable Bob Traxler
Chairman
Subcommittee on VA, HUD, and Independent Agencies
Committee on Appropriations
House of Representatives
Washington, D.C. 20515-6022
Dear Mr. Chairman:
I am pleased to submit the enclosed report in response to
the requirement of House Report 101-556 for a full review of the
effectiveness and efficiency of the Environmental Protection
Agency's Great Lakes National Program Office and associated
activities. I recognize we are submitting this Report somewhat
behind schedule, and trust that the quality of the Report will
compensate for its delayed arrival.
As you may know, the Administrator and I are placing very
high priority on revitalizing the Great Lakes program using a
cooperative, integrated effort to direct a critical mass of
resources to address problems on a holistic, ecosystem basis.
The hallmark of our effort will feature pollution prevention as
the preferred option for reducing risk. This will be buttressed
by the Agency's traditional regulatory activities, which will be
integrated across program lines to craft specific solutions
tailored to local circumstances. In addition, EPA will make use
of a much broader array of tools, including market incentives,
education, and information. In putting the pieces together, we
will seek the support and involvement of the States and the
national governments and citizens of the United States and
Canada.
As you might imagine, this is an ambitious undertaking—the
first of its kind for EPA, and a model for many of EPA's programs
in the future. The Congressional requirement to conduct a full
review of the effectiveness and efficiency of our activities in
the Great Lakes offered us an opportunity to conduct a probing
review of the current program, and, based on the findings, to
take appropriate actions to improve and strengthen the foundation
of the program from which we will mount our new multi-media
attack on all sources of pollution to the Great Lakes ecosystem.
U.S. Environmental Protection Agency
GLNPO Library Collection (PL-12J)
77 West Jackson Boulevard,
Chicago, IL 60604-3590
-------
I think you will find that this report contains a critical
analysis of key issues and weaknesses that may have impeded our
progress in the Great Lakes, as well as actions we currently have
underway to improve our performance. Clearly, we are still in
the early stages of this very ambitious effort, and there is much
more work to be done. However, we believe the findings of this
report have already been extremely helpful in shaping our
thinking about future work in the Great Lakes.
We will keep you fully apprised of our efforts as we proceed
with implementation of our integrated approach to protecting and
restoring the Great Lakes ecosystem. In the meantime, if there
are particular aspects of this report that are of special
interest to you, please let us know and we will try to respond to
your questions or concerns.
Henry Habicht II
Deputy Administrator
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
FEB T 1991 OFFICEOF
THE ADMINISTRATOR
Honorable Barbara A. Mikulski
Chair
Subcommittee on VA, HUD, and Independent Agencies
United States Senate
Washington, D.C. 20510-6032
Dear Madam Chair:
I am pleased to submit the enclosed report in response to
the requirement of House Report 101-556 for a full review of the
effectiveness and efficiency of the Environmental Protection
Agency's Great Lakes National Program Office and associated
activities. I recognize we are submitting this report somewhat
behind schedule, and trust that the quality of the report will
compensate for its delayed arrival.
As you may know, the Administrator and I are placing very
high priority on revitalizing the Great Lakes program using a
cooperative, integrated effort to direct a critical mass of
resources to address problems on a holistic, ecosystem basis.
The hallmark of our effort will feature pollution prevention as
the preferred option for reducing risk. This will be buttressed
by the Agency's traditional regulatory activities, which will be
integrated across program lines to craft specific solutions
tailored to local circumstances. In addition, EPA will make use
of a much broader array of tools, including market incentives,
education, and information. In putting the pieces together, we
will seek the support and involvement of the States and the
national governments and citizens of the United States and
Canada.
As you might imagine, this j.s an ambitious undertaking—the
first of its kind for EPA, and a model for many of EPA's programs
in the future. The Congressional requirement to conduct a full
review of the effectiveness and efficiency of our activities in
the Great Lakes offered us an opportunity to conduct a probing
review of the current program, and, based on the findings, to
take appropriate actions to improve and strengthen the foundation
of the program from which we will mount our new multi-media
attack on all sources of pollution to the Great Lakes ecosystem.
-------
I think you will find that this report contains a critical
analysis of key issues and weaknesses that may have impeded our
progress in the Great Lakes, as well as actions we currently have
underway to improve our performance. Clearly, we are still in
the early stages of this very ambitious effort, and there is much
more work to be done. However, we believe the findings of this
report have already been extremely helpful in shaping our
thinking about future work in the Great Lakes.
I trust you will find this report fully responds to your
requirements and needs. If there are particular aspects of this
report that are of special interest to you, please let us know
and we will try to respond to your questions or concerns.
Si
F. Henry Habicht II
Deputy Administrator
-------
A REVIEW OF
EPA'S GREAT LAKES
PROGRAM
REPORT TO THE
COMMITTEES ON
APPROPRIATIONS
February 6, 1991
Program Evaluation Division
Office of Regulatory Management and Evaluation
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
-------
EXECUTIVE SUMMARY
Considerable progress has been made toward improving water
quality in the Great Lakes Basin under the Clean Water Act and other
environmental statutes EPA and the States administer. Yet, the Nation
still faces many challenges in restoring the chemical, physical and biological
integrity of the Great Lakes, a goal which is embodied in the United
States-Canada Great Lakes Water Quality Agreement. If EPA and the
States are to succeed in restoring the Great Lakes, they will need to adjust
their traditional media-by-media orientation in favor of a more integrated
environmental management approach that emphasizes pollution
prevention as the preferred alternative.
EPA faces many management challenges in shifting from a
traditional media-by-media approach to a more integrated, pollution
prevention orientation. This report, prompted by a direction in the Fiscal
Year 1991 House Appropriations Committee report that EPA conduct a
full review of the effectiveness and efficiency of the current Great Lakes
office and associated activities, identifies those management challenges.
SUMMARY:
STUDY RESULTS
AND CURRENT AGENCY ACTION
GOALS AND PRIORITIES
Results
The Agency has not fully succeeded in setting clear environmental
goals and priorities for its Great Lakes activities; without clearly articulated
environmental goals and priorities to drive the Agency's decisions and
actions, its efforts have lacked a focus. In addition, the Agency has set
expectations too high for what the United States can accomplish on the
Great Lakes, and the Agency historically has been unwilling to say that it
and the States cannot do everything. This has lead to fragmentation of
resources and efforts.
The Agency must establish environmental risk-based goals and
priorities for its Great Lakes effort, and let them drive EPA and State
Great Lakes decisions and activities. Activities that do not support the
Agency's ability to meet these goals and priorities should not be
undertaken.
A Review of EPA's Great Lakes Program in
-------
Current Agency Action
The Agency has already taken a number of steps to implement
many of the recommendations regarding the need to establish risk-based
goals and priorities for protection and restoration of the Great Lakes
ecosystem, with prevention as the preferred alternative. Through the
Great Lakes Advisory Committee, the Agency is developing a Five-Year
Strategy for the Great Lakes, a Fiscal Year 1991 Action Plan, and a Pollution
Prevention Strategy for the Great Lakes, which more clearly define its
operating principles for its Great Lakes effort, and the Agency's goals,
priorities, and strategy for restoring the Great Lakes. The Agency is also
developing measures of environmental progress and success to gauge the
effectiveness of EPA and State Great Lakes efforts. In Fiscal Year 1992,
the Agency plans to launch a coordinated multimedia Great Lakes Basin
Initiative to promote faster and more effective action to improve the water
quality of the Great Lakes.
NEED FOR INTEGRATING RESOURCES
Results
The Great Lakes National Program Office (GLNPO) has not had—
nor will it likely ever have—the authority or resources to remedy single-
handedly all the complex problems of the Great Lakes. Others within
and outside EPA possess this authority, and must be viewed as GLNPO's
partners in the Nation's efforts to address the Great Lakes. In addition,
the Agency has not been fully successful in targeting its limited resources
in an integrated way on those activities that will lead to the greatest
environmental results. If EPA and the States are to succeed in improving
the Great Lakes, each must focus attention on how to creatively target
available resources to the Agency's priorities for the Great Lakes.
Current Agency Action
The Agency is responding aggressively to these concerns. In
developing the Five-Year Strategy and Fiscal Year 1991 Action Plan, the
Agency is emphasizing an integrated approach to environmental
protection and targeting a critical mass of limited resources to reducing
risk on a priority basis. The Great Lakes Advisory Committee has already
proved to be an effective body for creating an EPA partnership and
garnering commitments from various EPA offices for Great Lakes work.
In the near future, the Great Lakes Advisory Committee plans to address
the issue of expanding its efforts to forge partnerships with other Federal
agencies possessing expertise and resources that can contribute to
protection and restoration of the Great Lakes ecosystem.
iv A Review of EPA's Great Lakes Program
-------
NEED FOR CLEAR EPA LEADERSHIP
Results
There has been ongoing confusion about the role of the Regional
Administrator for Region V—as the Great Lakes National Program
Manager—and his relationship to the Assistant Administrator for Water.
Assistant Administrators, not Regional Administrators, typically serve as
National Program Managers. In addition to the Great Lakes National
Program Manager, the Assistant Administrator for Water, due to her focus
on water issues, is often in the position of speaking for the Agency on
Great Lakes policy and budget issues.
Since a Regional Administrator is by definition a cross-media
manager, the Regional Administrator for Region V should continue to
serve as the Great Lakes National Program Manager, and be responsible
for all functions which GLNPO performs. The GLNPO Director should
continue to report directly to the Great Lakes National Program Manager.
The Great Lakes National Program Manager and the Assistant
Administrator for Water should refine their existing agreement on the
roles of each on Great Lakes issues.
Current Agency Action
To respond to the need for greater leadership, the Agency recently
selected experienced managers to fill positions which will be critical to the
Agency's successful implementation of its Great Lakes strategy. A new
GLNPO Director and Region V Water Division Director were selected in
the last few months. The former Deputy Regional Administrator for EPA's
Region X office was recently chosen to serve in the same capacity for the
Region V office. In April, 1990, the EPA Administrator named the Deputy
Administrator to be the Chairman of Great Lakes Advisory Committee.
Also, the Great Lakes National Program Manager and Assistant
Administrator for Water are now engaged in discussions to refine their
agreement on their roles.
NEED TO DEFINE THE ROLE OF GLNPO
Results
GLNPO's role in the Agency continues to be unclear for several
reasons. First, while GLNPO's primary role in the Agency is to coordinate
the Agency's Great Lakes efforts, GLNPO has favored its role as an
implementor of environmental programs. GLNPO may have a legitimate
role to play in developing and implementing Great Lakes programs; yet,
its mindset has been to perform these activities itself. In some cases,
however, it may make more sense for GLNPO to enlist the assistance of
others to perform these activities. Second, GLNPO has performed activities
that are more typically the responsibility of the Regional Offices, including
negotiating grant agreements with the States and reviewing permits. Third,
GLNPO has not been fully successful in getting other EPA offices to
A Review of EPA's Great Lakes Program v
-------
undertake Great Lakes activities. This is primarily because it has
minimally participated in Agency systems and processes which are
recognized as being the key mechanisms for getting other EPA offices
and the States to undertake activities in support of EPA priorities. Rather
than focusing on its role as implementor, GLNPO's primary role should
be to serve as a coordinator. In short, GLNPO should assume the role of
orchestra conductor rather than trying to play all of the instruments in
the orchestra itself. In serving as the Agency's coordinator of Great Lakes
activities, GLNPO should use the established Agency systems and
processes to gain commitments from other EPA offices and the States for
Great Lakes work.
Current Agency Action
Changes are already occurring in this area. The roles that Region
V and GLNPO now are playing are consistent with the roles recom-
mended in this report. While GLNPO will continue to implement some
selected activities, the Agency and GLNPO are working to tailor GLNPO's
activities to address specific needs of others within and outside the Agency,
and to rely on other parts of the Agency to assume responsibility for
tasks that they are better equipped to handle (e.g., State grant negotiations).
Finally, GLNPO is beginning to integrate itself more into Agency pro-
cesses and systems (e.g., annual planning process) to make certain that
the Agency's goals and priorities for the Great Lakes are taken into account.
NEED TO IMPROVE
COMMUNICATION AND
COORDINATION
Results
While a number of mechanisms exist to facilitate communication
and coordination between GLNPO and the Regional Offices, there is room
for improvement. Senior management in GLNPO and the Regional Offices
has lacked a full understanding of the various initiatives each is
undertaking and the relationship of those initiatives to the Great Lakes
work in which their offices are engaged. If GLNPO is to succeed as the
chief coordinator, communicator and integrator of the U.S.'s Great Lakes
activities, it must become the Agency's chief advocate for the Great Lakes.
To help it effectively play this role, GLNPO should consider specific
changes to its current approach (e.g., establishment of a GLNPO liaison
office in Washington, D.C., the circulation of weekly or bi-weekly status
reports).
vi A Review of EPA's Great Lakes Program
-------
Current Agency Action
In the last few months, GLNPO and Region V have made significant
improvements in this area. GLNPO and Region V are effectively
coordinating the development of an integrated, risk-based Five-Year
Strategy, the Fiscal Year 1991 Action Plan, and the Pollution Prevention
Strategy, including providing all other EPA offices and States with an
opportunity for input. In addition, GLNPO and Regions n, IE, and V
have met with the State environmental Directors and representatives of
the various Governors to explain EPA's new approach and to enlist State
support and enthusiasm. In the near future, these outreach efforts will be
expanded to other Federal agencies with a vested interest in the Great
Lakes ecosystem.
NEED TO CONVEY
GREAT LAKES ACCOMPLISHMENTS
Results
EPA needs to do a better job of communicating Agency and State
successes in the Great Lakes, the complexities of the environmental
problems that remain, and the approach of EPA and the States for meeting
those challenges. Communication about EPA's efforts have generally
emphasized accomplishments of GLNPO and what work remains, rather
than on the contributions of other EPA offices, the States, and other Federal
agencies. In addition, the Agency has not been fully successful in keeping
Members of Congress informed of the Agency's progress on the Great
Lakes; the primary vehicle for interacting with Members of Congress has
been Congressional hearings, where EPA's performance in addressing the
Great Lakes has been heavily criticized.
To remedy these problems, EPA should develop an Agency strategy
for communicating its accomplishments on the Great Lakes, the
environmental challenges remaining, and EPA's program for meeting those
challenges. The emphasis of this communication strategy should be on
actions the Agency, not just GLNPO, should take. The Agency also must
put greater emphasis on keeping Members of Congress and their staff
informed through various mechanisms (e.g., meetings and briefings) on
the Agency's progress in restoring the Great Lakes.
Current Agency Action
The Agency is developing a Great Lakes communication strategy
to respond to these concerns. The strategy will focus on presenting the
problems in terms the public can understand, and on enlisting public
support and assistance for activities to restore and protect the Great Lakes.
In addition, the Agency has already taken steps to provide Members of
Congress and their staffs with additional information about the Agency's
Great Lakes activities, and has instituted a system to track progress on
meeting commitments made at hearings and in legislation.
A Review of EPA's Great Lakes Program mi
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NEED TO IMPROVE
ADMINISTRATIVE MANAGEMENT
Results
GLNPO and Region V Planning and Management Division have
made progress in the administrative management of their programs since
the 1989 management review performed by the Office of Administration
and Resources Management (OARM). Improvements have been made in
oversight and tracking of the GLNPO budget to ensure compliance with
Congressional mandates. The Region V Planning and Management
Division has generally implemented the grants-related recommendations
from the 1989 report, including recommendations discussing the need for
upgrading information in the Grant Information Control System. No
major problems were discovered in the contracting area, and significant
improvements have been made in the GLNPO and Planning and
Management Division internal control functions. Lastly, the Planning
and Management Division has continued to effectively deliver to GLNPO
basic information resources management services.
While improvements have been made, some changes are still
needed in GLNPO's administrative management. Overall, the Region V
Planning and Management Division should continue to expand its focus
and provide the leadership and professional management support needed
for GLNPO to succeed in the Agency. The Planning and Management
Division must go beyond providing the requisite support services, and
follow its "Commitment to Quality" approach to continually gauge and
assess GLNPO's service needs.
In addition, the Agency must face the challenge of how to best
tailor a budget process that responds to the multimedia nature of the
program, while comporting with the Agency's overall framework for
budgeting.
Current Agency Action
In recent months, new leadership in GLNPO and Region V have
taken steps to redirect the administrative management of GLNPO. The
GLNPO Director and Deputy Regional Administrator for Region V have
demonstrated their awareness of the administrative issues facing GLNPO,
and a willingness to share responsibility for resolving those issues. Senior
management is also currently assessing the best way to modify existing
systems and processes in a number of areas, and to clarify accountability
for budget preparation and allocation decisions. The Agency recognizes
the difficulties associated with budgeting for an integrated ecosystem
approach that cuts across traditional media program elements, and will
use the Great Lakes as a pilot for addressing and resolving these complex
issues.
viii A Review of EPA's Great Lakes Program
-------
TABLE OF CONTENTS
Executive Summary in
Abbreviations xi
I. Introduction 1
n. Scope and Methodology 3
Scope 3
Methodology 4
III. Environmental Accomplishments and Challenges 5
Nutrient Loadings 5
Toxics 6
Remedial Action Plans 13
Lakewide Management Plans 17
TV. Results of Review 19
Goals and Priorities 20
Findings 20
Recommendations 22
Current Agency Action 23
Resources 25
Findings 25
Recommendations 26
Current Agency Action 26
EPA Leadership 27
Findings 27
Recommendations 28
Current Agency Action 30
Roles 30
Findings 30
Recommendations 33
Current Agency Action 37
A Review of EPA's Great Lakes Program ix
-------
IV. Results of Review Continued
Communication and Coordination 38
Findings 38
Recommendations 39
Current Agency Action 41
Conveying Great Lakes Accomplishments 42
Findings 42
Recommendations 43
Current Agency Action 44
Administrative Management 44
Budget 45
Findings 45
Recommendations 45
Grants Management 46
Findings 46
Recommendations 46
Contracts Management 46
Findings 46
Recommendations 47
Financial Management 47
Findings 47
Recommendations 47
Management Integrity 48
Findings 48
Recommendations 48
Information Resources Management 48
Findings 48
Recommendations 49
Current Agency Action 49
Appendix 51
Studies and Reviews 51
Agency Review Team 52
x A Review of EPA's Great Lakes Program
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ABBREVIATIONS
AA: EPA Assistant Administrator
AOCs: Areas of Concern
ARCS: Assessment and Remediation of
Contaminated Sediments
DRA: EPA Deputy Regional Administrator
EPA: U.S. Environmental Protection Agency
FMFIA: Federal Managers' Financial Integrity Act
GAO: U.S. General Accounting Office
GLNPO: Great Lakes National Program Office
IJC: International Joint Commission
LMPs: Lakewide Management Plans
NPM: National Program Manager
OARM: Office of Administration and Resource Management
OPPE: Office of Policy, Planning and Evaluation
RA: EPA Regional Administrator
RAPs: Remedial Action Plans
STARS: Strategic Targeted Activities for Results System
USFWS: U.S. Fish and Wildlife Service
WQA:
U.S.-Canada Water Quality Agreement
A Review of EPA's Great Lakes Program xi
-------
I
INTRODUCTION
Considerable progress has been made toward controlling pollution
entering the Great Lakes Basin under the Clean Water Act and other
environmental statutes that the United States Environmental Protection
Agency (EPA) and the States administer. The most notable progress relates
to the cleanup of conventional pollutants in municipal and industrial
discharges to surface waters through EPA and State permitting programs.
These controls have been especially successful in reducing phosphorus
discharges, a problem which once threatened the viability of the Great
Lakes.
Yet, the Nation still faces many challenges in restoring the chemical,
physical and biological integrity of the Great Lakes, a goal which is
embodied in the United States-Canada Great Lakes Water Quality
Agreement (WQA). Toxic pollutants continue to enter the Great Lakes
through various sources, including urban and agricultural runoff, air
deposition, and Superfund sites, among others. In addition, the sediments
of the Great Lakes contain toxic chemicals which, although production
and use of many of them were banned years ago, continue to affect human
health and the quality of the Great Lakes ecosystem.
These environmental problems will be difficult to solve. The Agency
has recognized that to address the multiple loading problems in the Great
Lakes and the interdependent nature of the ecosystem, EPA and the States
will need to adjust their traditional media-by-media orientation in favor
of a more integrated environmental management approach that emphasizes
pollution prevention as the preferred alternative. In addition, the Agency
recognizes that it will need to devote more attention to working with
other Federal agencies and the government of Canada to bring all mecha-
nisms and approaches to bear if an ecosystem approach to the Great Lakes
is to be successful.
This report identifies the management challenges facing EPA and
the States for taking an ecosystem approach to pollution problems in the
Great Lakes. It also identifies ways in which the EPA needs to adjust its
current method of managing its environmental programs to help foster an
Agency-wide ecosystem approach to the Great Lakes. Section II discusses
the scope and methodology of this review. Section in describes in greater
detail the environmental accomplishments and challenges that lie ahead
for EPA, the States, and the Nation. Section IV covers the results from the
review, including findings, recommendations, and current Agency actions
to address the recommendations.
A Review of EPA's Great Lakes Program 1
-------
II
SCOPE AND
METHODOLOGY
SCOPE
The House Appropriations Committee, in the Fiscal Year 1991
appropriations report, directed EPA to undertake a review of the Great
Lakes National Program Office. More specifically, the report says, ". . .
EPA (shall) conduct a full review of the effectiveness and efficiency of the
current Great Lakes office and associated activities and submit a report to
the Committees on Appropriations by December 31,1990." Further dis-
cussions with the Chairman's staff clarified that the Committee was inter-
ested in having the report provide information on: EPA's accomplish-
ments in restoring water quality in the Great Lakes and in fulfilling the
requirements of the WQA and Section 118 of the Clean Water Act; prob-
lems that the Great Lakes National Program Office (GLNPO) has experi-
enced, including management issues; and an update of a 1989 manage-
ment review undertaken by EPA's Office of Administration and Resources
Management (OARM).
In response to this directive, the Deputy Assistant Administrator
for Water asked the Program Evaluation Division in the Office of Policy,
Planning and Evaluation to coordinate development of the overall report
and develop the findings and recommendations covering the effective-
ness of GLNPO's program management. The Office of Marine and Estua-
rine Protection in the Office of Water prepared the section of the report on
the Agency's environmental accomplishments and remaining environ-
mental challenges. OARM was responsible for developing findings and
recommendations on GLNPO's administrative management.
The Agency's review sought to meet the Congressional mandate
through identifying practical ways to improve the effectiveness and effi-
ciency of GLNPO and to strengthen the participation of other EPA offices
in the Great Lakes program. Toward these ends, the review identified the
principal strengths and weaknesses of the current program and identified
institutional, programmatic, and administrative changes that could be made
to take advantage of the strengths and remedy the weaknesses.
More specifically, the review examined: whether there are
appropriate processes in place for setting the goals of and establishing
priorities for EPA's Great Lakes activities; whether GLNPO and other
EPA offices have appropriate and well-defined roles; the effectiveness of
current Agency mechanisms for facilitating coordination; GLNPO's
effectiveness in taking advantage of the capabilities of other EPA offices
and the States; the effectiveness of GLNPO's administrative management,
including contracts, grants, budgeting, financial management, management
controls, information resources, Congressional relations, and organizational
A Revkw of EPA's Great Lakes Program 3
-------
issues; and the environmental accomplishments and challenges which lie
ahead. Since the Agency is in the process of implementing many of the
recommendations from the review, this report also discusses the activities
which are underway.
Due to time limitations, this review did not include an examination
of EPA's performance in fulfilling every requirement of Section 118 of the
Clean Water Act or of the WQA. Nor did it include an in-depth analysis
of the effectiveness of EPA's interactions with other Federal agencies, the
International Joint Commission (IJC), or Environment Canada.
METHODOLOGY
The Program Evaluation Division interviewed about 60 EPA and
State officials for this review. OARM interviewed about 30 officials for
its review of GLNPO's administrative management. The Program Evalu-
ation Division and OARM interviewed officials from: GLNPO; Region V,
including the Regional Administrator (RA) and Deputy Regional Admin-
istrator (DRA), and senior managers and staff from the Water, Air, Envi-
ronmental Services, and Policy and Management Divisions; Region II
and m senior managers and staff from the Water, Hazardous Waste, and
Environmental Services Divisions; senior managers from EPA Headquar-
ters; and State environmental Directors and their staffs from Michigan,
Wisconsin, Ohio, Indiana, and New York.
In addition, the Program Evaluation Division and OARM reviewed
numerous documents, including the following: the WQA; Section 118 of
the Clean Water Act; Agency Operating Guidance; transcripts from
Congressional hearings on the Great Lakes; internal memoranda and
budget documents; and GLNPO's strategy for 1988 to 1993.
Finally, studies of GLNPO which have been conducted over the
years were reviewed. These include studies undertaken by the General
Accounting Office (GAO), the Inspector General, and OARM. The
Appendix provides additional information on these studies.
4 A Review of EPA's Great Lakes Program
-------
Ill
ENVIRONMENTAL
ACCOMPLISHMENTS
AND CHALLENGES
EPA and the States have made significant progress in controlling
pollutants entering the Great Lakes. Yet, many challenges still remain.
The following discusses these accomplishments and challenges in greater
detail.
NUTRIENT LOADINGS
The first signs of eutrophication appeared in nearshore areas of
the Great Lakes during the first half of this century. Problems with
increased algal growth which triggered oxygen depletion and population
reductions of fish and other organisms continued to spread. By I960, a
lakewide eutrophication problem had developed in Lake Erie, which was
especially vulnerable with its shallow basin, highly urbanized shores, and
tributaries that drain extensively farmed soils. During the 1960s, cycles of
algal blooms, decay and oxygen depletion due to enrichment by excess
nutrients became annual events. As a result, the public demanded action.
The Federal government responded by requiring secondary treatment of
sewage, tightening controls on industrial discharges and instituting Federal
enforcement actions on the Great Lakes that resulted in the establishment
of phosphorus limits on all municipal dischargers.
Substantial reductions in phosphorus concentrations and associated
reductions in blue-green algae have been achieved in the Great Lakes
since the U.S. and Canada began a concerted effort to reduce phosphorus
loadings. This effort continued through two vehicles. Congress passed
the Clean Water Act, and the U.S. and Canada entered into the joint WQA
which has served as the framework for cooperative binational efforts to
restore and maintain the Great Lakes system. As the WQA was amended
in 1978,1983, and 1987, more stringent phosphorus load reduction targets
were adopted for Lakes Ontario and Erie and Saginaw Bay in Lake Huron.
Phosphorus loadings from point sources have been reduced by an
estimated 80 to 90 percent through regulation and financial assistance for
environmental controls on point sources. Financial assistance has been
provided primarily for the upgrading of sewage treatment plants. Over
$8 billion in Federal and State support has been invested in the Great
Lakes Basin for construction of municipal sewage treatment facilities.
The WQA mandates that municipal waste water treatment facilities
meet a milligram per liter (mg/1) effluent limit for phosphorus to achieve
lakewide target nutrient load reductions. All major U.S. dischargers as a
group are currently meeting the 1 mg/1 phosphorus goal. Individual
dischargers that are not meeting it are being offset by dischargers that are
releasing effluent with less than 1 mg/1 of phosphorus. The targets for
phosphorus loadings identified in the WQA have been achieved for the
open waters in Lakes Superior, Michigan, and Huron through reduced
A Review of EPA's Great Lakes Program 5
-------
direct discharges of wastes from industrial and municipal sources and
detergent phosphate bans. Detergent phosphate bans have been adopted
in all of the Great Lakes states.
Further efforts are needed to meet the target phosphorus loadings
for Lakes Ontario and Erie, and Saginaw Bay. More effective programs
to control nonpoint sources of phosphorus are required to attain phos-
phorus load reductions in these areas. A U.S. plan for phosphorus load
reductions to these three areas was submitted to the IJC in June, 1986.
The five-year plan focused on the management of crop residues to pre-
vent nutrient loss by soil erosion, proper management of livestock wastes,
and proper management of commercial fertilizers. In 1988, the Great
Lakes Phosphorus Task Force evaluated progress in reducing phosphorus
loading from nonpoint sources. Substantial progress has been made in
reducing nonpoint phosphorus loads to Lake Ontario and Saginaw Bay.
Over half of the targeted load reduction has been met in Lake Ontario
and more than 85 percent of the allocated load reduction has been attained
in Saginaw Bay. Similar success in limiting phosphorus loadings from
nonpoint sources has not been realized for Lake Erie. Nonpoint phos-
phorus loads have been reduced by no more than 25 percent in Lake Erie.
The challenge remains to sharply reduce phosphorus inputs to Lake Erie,
particularly from agricultural nonpoint sources in Ohio.
The Agency has provided funding for recent projects to track
conservation tillage practices in Indiana, Michigan, and Ohio using remote
sensing techniques and to evaluate conservation tillage practices in Ohio.
Based on the results of these studies, EPA and the States will determine
whether nonpoint source control programs are capable of providing the
level of reduction required to meet the phosphorus objectives of the WQA.
If further reductions are necessary, recommendations for additional
measures will be developed.
In summary, nutrient loadings to the Great Lakes decreased
significantly in the 1980s. Decreased algal growth and increased dissolved
oxygen levels provide clear evidence that accelerated eutrophication
appears to have stopped in the open waters of the Great Lakes. Annual
open lake phosphorus monitoring programs were completed for all five
lakes in 1988. Both the U.S. and Canada are close to achieving their
phosphorus reduction targets. Implementation of nonpoint source control
programs will be key to fully meeting these objectives.
TOXICS
With the problem of eutrophication largely under control, the focus
has shifted to addressing the problem of toxic contaminants in the Great
Lakes ecosystem. Toxic contamination was first recognized as a
widespread problem in the Great Lakes in the 1960s when DDT, PCBs,
and mercury were found to be affecting the reproduction of birds and
animals and posing a threat to human health through fish consumption
and other direct exposure. The number, sources, distribution, and effects
of toxic substances in the Lakes were poorly understood. Since then,
research related to toxic pollution has helped define the magnitude of the
problem.
6 A Review of EPA's Great Lakes Program
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It is now known that toxic chemicals enter the waters of the Great
Lakes through industrial and municipal discharges, land runoff, contami-
nated bottom sediments, atmospheric deposition, contaminated ground
water, and accidental spills from vessels. The IJC's Water Quality Board
has identified 362 chemicals of concern in the Great Lakes ecosystem,
including persistent toxics of priority concern (e.g., DDT, PCBs, dieldrin,
dioxin, mirex, lead, mercury).
The largest concentrations of toxic pollutants in the Great Lakes
are located in the 42 Areas of Concern (AOCs) identified in 1981 by the
Water Quality Board of the IJC Toxic pollutants have also been found at
many other locations outside the AOCs, primarily in sediments. At present,
no concentrations of chemicals or heavy metals are found in the lakes at
levels that are known to be acutely toxic to organisms during brief expo-
sure. A major concern is the possible long-term effects of prolonged
exposure to small quantities of toxic substances through bioaccumulation
and biomagnification and through synergistic actions. Figure 1 illustrates
the impact of bioaccumulation and biomagnification of DDT through the
food chain. Effects of toxic pollutants that have been measured in the
Great Lakes include health risks to humans along with deformities, tumors,
and reproductive disorders in all types of wildlife.
Figure 1
Accumulation and Amplification of Organic Contaminants
in an Aquatic System
DDT in Fish-Eating Birds
25 ppm
DDT in Large Fish
2 ppm
DDT in Small Fish
0.5 ppm
DDT in Zooplankton
0.04 ppm
DDT in Water
0.000003 ppm
or
3ppt
Source: Science Applications International Corporation, "Green Bay/Fox River Mass Balance
Study, Executive Summary," November, 1988.
A Review of EPA's Great Lakes Program 7
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The WQA addresses the problem of toxic pollutants in the Great
Lakes Basin. The 1972 requirements called for the control of pesticides as
the principal means for controlling toxic pollution. The 1978 amend-
ments to the WQA required the control of all toxic substances that could
endanger the health and well-being of any living organism. A set of
specific water quality objectives were adopted to establish minimum ac-
ceptable conditions for known toxic substances. The 1987 amendments
to the WQA expanded this focus on toxics, thus highlighting the need for
intensified efforts to combat continuing toxic contamination of the Great
Lakes Basin.
Initial actions to control toxic contamination have produced some
measurable results. Point source loadings of virtually all toxic substances
have declined in recent years. Reductions can be attributed to more
stringent discharge permit requirements and to bans or restrictions on
the use of the most persistent pollutants of concern under national pesti-
cide and toxic substances control statutes. The most significant reduc-
tions have been achieved in the levels of mercury and a number of pesti-
cide compounds. Point source controls alone, however, appear to be
inadequate for a number of toxics of priority concern which continue to
persist at levels above WQA objectives either due to extensive sediment
contamination and/or nonpoint source inputs of toxic substances (e.g.,
agricultural runoff, air deposition).
Progress has been made toward the further control of toxic
pollutants in the Great Lakes. Recent accomplishments include the Green
Bay Mass Balance Study, the Niagara River and Lake Ontario Toxics
Management Plans, the Lake Michigan Toxic Pollutant Control/Reduction
Strategy, and the Great Lakes Fish Monitoring Program. Each is discussed
below.
Green Bay Mass Balance Study
The Green Bay Mass Balance Study (the Green Bay Study) is a
pilot project to evaluate the feasibility of mass balance modeling for toxic
substances as a basic planning and management tool in restoring Great
Lakes water quality. The study was initiated in 1986 and is scheduled for
completion in 1991. Both GLNPO and the Office of Research and
Development have been involved in the Green Bay Study.
The goals of the Green Bay Study are: to test models for toxics to
improve EPA and State understanding of the sources, transport, and fate
of toxic compounds; to evaluate the technological capability to measure
multimedia loadings to a system; and ultimately to guide and support
regulatory activity. The Green Bay Study objectives are to:
• Assess the technical and economic feasibility of the mass balance
approach for use in the management of pollutant loading and
impacts on the Great Lakes ecosystem.
• Calibrate the mass balance model for sources, transport routes,
and fates of pollutants in the Great Lakes ecosystem.
8 A Review of EPA's Great Lakes Program
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• Identify the major sources of pollutants entering the Green Bay
ecosystem and rank their relative significance.
• Demonstrate methods and priorities for further studies of toxic
pollutants in the Great Lakes.
Several universities and State and Federal agencies are participating
in the Green Bay Study. GLNPO and the Wisconsin Department of Natural
Resources are responsible for overall coordination of the study.
Mass balance modeling is based on the law of conservation of
mass. In a mass balance, the quantities of contaminants entering the
system minus the quantities stored, transformed, or degraded within the
system, must equal the quantity leaving the system. The basic mass balance
model can be reduced to the following formula:
Input + Generation - Accumulation - Consumption = Output
Mass balance models are being applied to PCBs, dieldrin, cadmium,
and lead for the Green Bay Study. The physical and chemical models are
coupled with a food chain model to estimate accumulations in target fish
species (carp, brown trout, and walleye). The methodologies employed in
the model offer a framework for pollution control and remediation. Once
the mass balance approach is fully developed and successfully tested,
engineers and policy makers will be able to employ lake and basin-wide
simulations to test the costs and benefits of alternative pollution control
and abatement techniques
Niagara River Toxics Management Plan
EPA, Environment Canada, the Ontario Ministry of the
Environment and the New York Department of Environmental
Conservation (the Four Parties) signed a Declaration of Intent on February
4,1987. This Declaration includes a commitment for a 50 percent reduction
in ten persistent toxic chemicals of concern to the Niagara River by 1996.
The Niagara River Toxics Management Plan (the Niagara Plan)
was produced in July, 1987 in response to the toxics commitments. EPA
Region n and the New York Department of Environmental Conservation
have been responsible for developing the Niagara Plan. The goal of the
Niagara Plan is to reduce point and nonpoint source loadings of toxic
chemicals to the Niagara River. It includes detailed Four Party
commitments to achieve reductions by accomplishing four related
objectives: sorting chemicals as a basis for action; implementing programs
to reduce the loadings of toxics entering the Niagara River; assessing the
success of programs to reduce the loadings of toxics, ensuring a continuing
focus on critical inputs; and coordinating Niagara Plan activities with
Remedial Action Plan (RAP) activities (see discussion on RAPs starting on
page 13).
Ten toxic chemicals have been identified as problem chemicals
with significant Niagara River sources; these are the chemicals subject to
the 50 percent reduction requirement under the Declaration.
A Review of EPA's Great Lakes Program 9
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Several tasks have been accomplished under the Niagara Plan
toward achieving the goal of a 50 percent reduction. The Four Parties
quantified the base-year loadings of the ten chemicals and estimated the
loadings from nonpoint sources. From this data, specific target load
reductions from point and nonpoint sources have been established by
EPA Region n and New York Department of Environmental Conservation
to meet the 1996 reduction requirement. Twenty U.S. hazardous waste
sites have been identified that contribute an estimated 99 percent of the
toxic chemical loadings from all hazardous waste sites in the U.S. to the
Niagara River. Target reductions for toxics are focused on these sites.
The schedule developed to meet target reductions of toxic chemical
loadings to the Niagara River is ambitious. It will require increased
resources from EPA and State hazardous waste programs.
Lake Ontario Toxics Management Plan
The Four Parties initiated development of the Lake Ontario Toxics
Management Plan (the Ontario Plan) in 1987. It has several goals: a lake
that provides safe drinking water; a lake with fish that are safe for unlim-
ited human consumption; and a lake that allows for the natural repro-
duction within the ecosystem of the most sensitive native species, includ-
ing bald eagles, osprey, mink and otters. EPA Region II and the New
York Department of Environmental Conservation have been responsible
for developing the Ontario Plan.
The Ontario Plan outlines a sequence of four stages of remedial
measures to achieve this broad goal: reductions in toxic inputs driven by
existing and developing programs; further reductions in toxic inputs
driven by special efforts in geographic AOCs; further reduction in toxic
inputs driven by lakewide analyses of pollutant fates; and zero discharge.
The Ontario Plan was completed in February, 1989. It calls for
three principal actions:
• Full implementation of current programs, such as the State
Pollutant Discharge Elimination System program in New York
State and the Municipal Industrial Strategy for Abatement program
in Ontario.
• The development and implementation of RAPs to address the
eight AOCs within Lake Ontario.
• The development and implementation of chemical-specific
management plans to reduce the levels of problem toxics below
protective ambient standards. As a check on the effectiveness of
chemical-specific management plans, ecosystem objectives and
indicators will be developed and monitored.
Accomplishments to date include development of a preliminary
mass balance for toxic pollutants and draft ecosystem objectives for the
lake. The Ontario Plan meets many of the requirements for Lakewide
Management Plans (LMPs) outlined in the 1987 amendments to the WQA.
10 A Review of EPA's Great Lakes Program
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Lake Michigan Toxic Pollutant Control/Reduction Strategy
EPA and the States of Illinois, Indiana, Michigan and Wisconsin
prepared the Lake Michigan Toxic Pollutant Control/ Reduction Strategy
(the Michigan Toxics Strategy) in 1986. The objectives of the Michigan
Toxics Strategy are to restore multiple human uses of Lake Michigan and
to protect human health and the Lake Michigan ecosystem by achieving a
significant reduction in the loading rates of toxic pollutants.
The development of water quality standards for toxic substances
and anti-degradation procedures were begun under the Michigan Toxics
Strategy prior to the 1987 amendments to the Clean Water Act which
required national adoption of standards. As a result, water quality stan-
dards for toxics were adopted by all four States. These actions provide a
regulatory basis for more stringent permit limits and nonpoint source
controls, where necessary, to meet the objectives of the Strategy. The
Strategy anticipates using a whole-lake mass balance approach to model-
ing toxic pollutants and evaluating potential future regulatory controls
and is serving as the basis for the full-scale LMP development.
Great Lakes Fish Monitoring Program
The first fish contaminant monitoring effort began in the Great
Lakes in the mid-1960s when the U.S. Fish and Wildlife Service (USFWS)
initiated a program to measure the contamination of lake trout. The Great
Lakes Fish Monitoring Program (the Fish Monitoring Program) has evolved
from this initial effort to a program under the joint sponsorship of the
USFWS and GLNPO.
The Fish Monitoring Program is designed to support decisions on
potential human exposure to pollutants and to provide indicators of the
health of the Great Lakes ecosystem. It consists of the following elements:
open lakes trend monitoring; monitoring for emerging problems in harbors
and tributaries; game fish fillet monitoring; and fish tumor and ecosystem
health monitoring.
State and Federal agencies conduct sampling and analysis for each
of the program elements, with GLNPO providing overall coordination. In
addition, the Office of Research and Development is involved in the pro-
gram. Participating agencies are using standard sampling and analysis
techniques developed by the Fish Monitoring Program. The program
elements are generating a variety of information including trend data on
toxic compounds in fish, identification of new toxic pollutants and pollut-
ant sources, short-term measures of the impact of remediation efforts, and
estimates of human exposure to toxic pollutants.
The Program is a flexible, low-cost method for monitoring water
quality. It can be applied as a planning and assessment tool to measure
the success of bans, restrictions, and other remedial actions to control
toxic pollution in the Great Lakes and to provide public policy makers
with the scientific information necessary to responsibly manage the Great
Lakes environment.
A Review of EPA's Great Lakes Program 11
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Contaminated Sediments
Contaminated sediments are a significant source of toxic pollutants
to the Great Lakes. Substantial amounts of toxic compounds were
deposited in sediments before regulatory controls were in effect, but the
accumulation of many toxics in sediments is continuing. Toxic
contaminants tend to accumulate below direct discharges of effluents
with a high solid content. They can be resuspended in the water column
by biological activity or by physical disturbances from storms, vessels or
dredging activities.
Annex 14 of the WQA focuses on contaminated sediments. It
calls for identification of the nature and extent of sediment pollution in
the Great Lakes ecosystem, for the development of methods to evaluate
the impact of contaminated sediments, and for development and
demonstration of remedial technologies.
All of the U.S. AOCs are known to have problems with
contaminated sediments. In many AOCs, toxic contaminants are
concentrated in sediments in "toxic hotspots;" in others, contaminated
sediments are dispersed over wide areas in embayments or tributaries.
Work is continuing to define the scope of the sediment pollution problem
in the Great Lakes outside the AOCs.
The 1987 amendments to the WQA and the Clean Water Act
require a demonstration program addressing remedial technologies for
cleanup of toxic pollutants with an emphasis on their removal from bottom
sediments. Under the Clean Water Act, GLNPO is charged with the
responsibility for conducting the five-year program, and five sites are
designated for priority consideration for the demonstrations: Saginaw
Bay, Michigan; Sheboygan Harbor, Wisconsin; Grand Calumet River,
Indiana; the Ashtabula River, Ohio; and the Buffalo River, New York.
The demonstration projects will include substantial participation by the
Office of Research and Development, the U.S. Corps of Engineers, the
National Oceanic and Atmospheric Administration, USFWS, the Great
Lakes States, and other organizations (e.g., public interest groups).
hi Fiscal Year 1988, GLNPO established the Assessment and Re-
mediation of Contaminated Sediments (ARCS) program to lay the foun-
dation for the demonstration projects. The objectives of the ARCS pro-
gram are: to assess the nature and extent of contaminated sediments
within the Great Lakes; to evaluate remedial options; and to provide
guidance to other agencies in assessment and remedial treatments for
contaminated sediments. ARCS is a "laboratory" study, not a cleanup
program. It will produce public and management guides on contami-
nated sediments, technical documents analyzing techniques for assessing
contaminated sediments and remediation alternatives, a comprehensive
program report, and case studies of each of the five demonstration sites.
hi addition to the ARCS program, remedial actions are underway
at Waukegan Harbor, Illinois, an AOC with high PCB levels in the water
and sediments. Advanced cleanup of the harbor and surrounding area of
Lake Michigan has begun through a consent decree with the Outboard
Marine Corporation to clean up PCB contamination. The harbor is a
12 A Review of EPA's Great Lakes Program
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Superfund site and the only AOC in the State of Illinois. The consent
decree between EPA and the Corporation is court-approved and legally
enforceable.
EPA is advancing the use of enforcement actions to address
contaminated sediment problems at other AOCs in the Great Lakes Basin.
Region V, in conjunction with the Office of Water and the Office of
Enforcement, has initiated multimedia pilot enforcement projects in AOCs
in the Great Lakes Basin. These pilot projects will use existing authorities
to enhance contaminated sediment enforcement actions.
Critical challenges remain in addressing the problem of
contaminated sediments in the Great Lakes. In identified problem areas,
the volume of contaminated sediments is so large that the cost of removal
or other remedial actions will be a major issue. Other issues that present
future challenges include development of treatment and disposal methods
to assure safe disposal of contaminated sediments after removal and
determination of whether the environmental impact is greater from removal
of contaminated sediments or from leaving them in place.
REMEDIAL ACTION PLANS
The 1987 amendments to the WQA require that Remedial Action
Plans (RAPs) be developed to address impairments of beneficial uses within
42 AOCs identified in 1981 by the Water Quality Board of the IJC. The
U.S. is fully responsible for 25 of these AOCs, and jointly responsible with
Canada for five. Figure 2 identifies the names and locations of the 42
areas of concern.
More specifically, the 1987 amendments required that RAPs be
developed which contain the following components:
1. A definition and detailed description of the environmental problem
in the AOC, including a definition of the beneficial uses that are
impaired, the degree of impairment, and the geographic extent of
such impairment.
2. A definition of the causes of the use impairment, including a
description of all known sources of pollutants involved and an
evaluation of other possible sources.
3. An evaluation of remedial measures in place.
4. An evaluation of alternative additional measures to restore the
beneficial uses.
5. A selection of additional remedial measures to restore the beneficial
uses and a schedule for their implementation.
6. An identification of the persons or agencies responsible for
implementation of remedial measures.
7. A process for evaluating remedial measure implementation and
effectiveness.
8. A description of surveillance and monitoring processes to track
the effectiveness of remedial measures and the eventual
confirmation of the restoration of uses.
A Review of EPA's Great Lakes Program 13
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Figure 2
Areas of Concern in the Great Lakes Basin
Nipigon Bay Jackfish Bay
Thunder Bay.
1 Peninsula Harbor
St. Louis River
St. Lawrence River
Deer Lake
Manistique River
Penetang Bay
to Sturgeon Bay
Collmgwood
Harbor
Fox River and
Southern Green Bay
White Lake „ . „. „
Montague Saglnaw River System
and Saginaw Bay
Muskegon Lake
Clinton River
• Detroit River
Kalamazoo Rwge Rlver
River
Oswego River
Sheboygan
Milwaukee Estuary
Waukegan Harbor
Eighteen Mile Creek
>
Niagara River
Buffalo River
Grand Calumet River and
Indiana Harbor Ship Canal
Raisin River i
Maumee River
Ashtabula River
Cuyahoga River
Black River
Adapted from: U.S. General Accounting Office, "Improved Coordination Needed to Clean Up the
Great Lakes" (GAO RCED-90-197) September 1990.
The States have the primary responsibility for preparing RAPs.
EPA provides technical assistance and guidance to the States on RAP
development. The WQA requires that a number of general principles
guide RAP development. RAPs must embody a comprehensive ecosystem
approach. They must clearly identify problems to be addressed, proposed
remedial steps, and specific monitoring requirements for tracking progress
and restoring beneficial uses. They must build on existing management
plans. Finally, they must ensure that the public is consulted.
Table 1 identifies the water quality problem;} identified in each
area of concern.
States must submit each RAP to EPA and the IJC at three stages.
It must first be submitted when the definition of the problem has been
completed according to RAP components one and two (listed on page
13). The next submission occurs when remedial and regulatory measures
are selected under RAP components three through six. The final submis-
sion occurs when monitoring indicates that identified beneficial uses have
been restored under components seven and eight.
14 A Review of EPA's Great Lakes Program
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Table 1
Summary of Water Quality Problems
Identified in Areas of Concern
Area of Concern Toxics in
Water
_o
s.
3
in
§
be
•s
§
§
X
QJ
S
_o
rt
8
5*3
fce
B «
u°
Penninsula Harbor •
Jackfish Bay •
Nipigon Bay •
Thunder Bay •
St. Louis River/Bay •
Torch Lake •
Deer Lake-Carp Ck/R. X
Manistique River •
Menominee River •
Fox River/S.Green Bay •
Sheboygan Harbor •
Milwaukee Estuary •
Waukegan Harbor •
Gr. Calumet/Indiana H. •
Kalamazoo River •
Muskegon Lake •
White Lake •
Saginaw River /Bay •
Collingwood Harbor X
Penetang-Sturgeon Bay X
Spanish River X
Clinton River X
Rouge River •
Raisin River •
Maumee River •
Black River •
Cuyahoga River •
Ashtabula River •
Wheatley Harbor X
Buffalo River •
18-Mile Ck/Olcott Hbr. •
Rochester Embayment •
Oswego River •
Bay of Quinte •
Port Hope •
Toronto Waterfront •
Hamilton Harbor •
St. Mary's River •
St. Clair River •
Detroit River •
Niagara River •
St. Lawrence River •
Toxics in Health Fish
Sediments Advisories Tumors
on Fish
• • ND
ND
• • ND
...
• • ND
. . .
ND
ND
.
.
• • ND
• ND
• ND
• • ND
ND
• ND
ND
• • X
• • ND
X • ND
ND
X ND
.
. . .
• X ND
...
X
X
ND
.
ND
• • ND
ND
• • X
X
...
.
.
X
.
.
• • X
Impacted Elevated Elevated Dissolved
Biological Bacteria Phosphorus Oxygen
Community Levels Levels Depletion
X • X
X
X X
....
XXX
XXX
• X •
XXX
• X X X
.
• X X X
.
XXX
.
.
• X •
• X X X
.
x
X • X
X • X
.
.
....
....
.
.
.
.
.
XXX
X
• X
.
X
X
.
. . X
... x
X
X
X
Problem Exists
X Problem Not Evident
ND No Data Available
Adapted from: U.S. EPA, "Five Year Program Strategy
for the Great Lakes National Program Office,
FY1989-1993," December 1988.
A Review of EPA's Great Lakes Program 15
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The States are moving forward in developing RAPs. In October,
1990, the Stage 1 RAP for Sheboygan Harbor on Lake Michigan was
submitted to the IJC. This followed closely on the heels of: New York's
submission of Stage 1 RAPs for the Oswego and Buffalo Rivers on Lakes
Ontario and Erie; Michigan's submissions in 1987 and 1988 of seven com-
bined Stage 1 and 2 RAPs; and Wisconsin's completion in 1988 of the
Stage 2 RAP for Fox River/Green Bay.
By the end of 1990, Stage 1 RAPs are to be submitted to EPA and
the IJC for the Milwaukee Estuary and the Menominee River on Lake
Michigan. By the end of fiscal year 1991, the States anticipate submitting
Stage 1 RAPs for the following AOCs: Waukegan Harbor and Indiana
Harbor/Grand Calumet River on Lake Michigan; the St. Louis Bay/River
on Lake Superior; Rochester Embayment on Lake Ontario; the Ashtabula,
Black, Maumee and Cuyahoga Rivers on Lake Erie; and the St. Lawrence
and Detroit Rivers. By the end of fiscal year 1991, the States also expect
to submit Stage 2 RAPs for Waukegan Harbor and for the Maumee,
Oswego, and St. Lawrence Rivers.
To facilitate the RAP review process in Fiscal Year 1990, EPA's
Region V initiated in Fiscal Year 1990 a multiprogram review for all RAP
documents produced by the States prior to submission to the IJC. The
purpose of the review is to ensure technical merit and an integrated
approach to remedial measures that is consistent with the ecosystem
approach the Agency and States are pursuing. RAPs which the States
previously submitted to the IJC, but were not accepted because Stage I
requirements were not fully met, are included in the review process.
This review should resolve questions of RAP adequacy before the IJC
considers them.
As an incentive to encourage State RAP efforts, Stage I RAP
completion will be a performance-based condition for Clean Water Act
Section 106 funding of State Fiscal Year 1991 program plans. Section 106
of the Clean Water Act supports State pollution control programs. States
were required to submit a list of RAP-related activities for 1991 and to
commit to completing those activities.
The EPA Regional Offices are continuing to work with the States
to complete RAPs for the 30 AOCs in the U.S. Difficulty in obtaining
consensus among concerned units of government, interest groups, and
the public on problem definition has delayed early efforts to develop
several RAPs. To address this problem, the Region V Water Division is
working with the Office of Marine and Estuarine Protection to facilitate
the process of developing RAPs. Some groups involved in RAP develop-
ment are continuing to strive to meet this challenge and reach Stage 1
review. A future challenge for EPA and the States will be to fully and
effectively implement RAPs to restore full beneficial uses.
16 A Review of EPA's Great Lakes Program
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LAKEWIDE MANAGEMENT PLANS
The 1987 amendments to the WQA require that LMPs be developed
to address critical pollutants impairing beneficial uses in water of the
open lakes. The general principles guiding the development of RAPs also
apply to the development of LMPs. LMPs are intended to be cooperative
strategies for reducing loadings of critical pollutants to the open waters of
each of the lakes. Coordination among jurisdictions and selection of the
appropriate combination of remedial actions will require complex
integration of Federal, State, and local programs to achieve specific
environmental objectives.
The WQA assigns responsibility for completing LMPs to the Federal
government. EPA has been charged with developing the plans in
cooperation with other Federal agencies and the States. The review process
for LMPs is similar to that for RAPs; LMPs must be submitted to the IJC
for review at four stages of development: when a definition of the problem
is complete; when the schedule of contaminant load reductions has been
determined; when remedial measures are selected; and when monitoring
indicates that potential hazards from the critical pollutants have been
eliminated.
The LMP process for Lake Michigan was initiated in Fiscal Year
1990. This included the development of a work plan designed to achieve
Stage I LMP completion and submittal to the IJC by September 30,1991,
and identification of resources required to support LMP development and
implementation during fiscal years 1991 and 1992. The four States
bordering Lake Michigan are participating in the LMP process. EPA
identified the Lake Michigan LMP as a high priority activity in program
guidance to the States. (The Lake Michigan LMP is discussed in greater
detail on page 10.)
A Review of EPA's Great Lakes Program 17
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IV
RESULTS OF REVIEW
While EPA and the States have made significant progress in
reducing conventional pollutants entering the Great Lakes, much remains
to be done to address the continued discharge of toxics into the Great
Lakes and the persistence of toxics in the sediments. This will be difficult
to do. Many of the sources of pollutants entering the Great Lakes are still
unknown and/or are difficult to address. Never before has the Agency
faced such a large-scale challenge in terms of remediating in situ
contaminants, particularly given technological limits. Never before has
EPA attempted on such a large scale to go beyond a single-media focus to
one that integrates all media. Never before has the Agency faced such a
significant challenge in terms of bringing together the large number of
diverse governments and other groups which have jurisdiction over or
concerns about the Great Lakes. This includes other Federal agencies, the
eight Great Lakes States, local governments, the Congress, the government
of Canada, and various public interest and business groups.
The Agency has recognized that if it is to meet the challenges the
Great Lakes pose, significant improvements are needed in the Agency's
management of its Great Lakes activities. The Agency will need to inte-
grate the activities of its various programs rather than approaching the
Great Lakes from primarily a water perspective. In addition, the Agency
must assume the burden for the success or failure of the Agency's efforts,
rather than placing this responsibility almost completely on GLNPO.
In short, changes in the Agency's management of its Great Lakes
activities are needed and are already being made to help ensure the
Agency's success in taking an ecosystem approach to the Great Lakes.
The following discussion identifies the management problems which his-
torically have limited the Agency's success in implementing its Great Lakes
program. It also recommends various ways in which the Agency can
improve its operation and management to help achieve the Agency's overall
mission for the Great Lakes. Finally, this section discusses activities the
Agency currently has underway to implement the recommendations.
A Review of EPA's Great Lakes Program 19
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GOALS AND PRIORITIES
Findings
GLNPO's primary mission is to coordinate the United States' efforts to
restore and maintain the chemical, physical, and biological integrity of
the Great Lakes.
The United States and Canada entered into the joint Great Lakes
Water Quality Agreement (WQA) with the overall goal of restoring and
maintaining the chemical, physical, and biological integrity of the Great
Lakes. Section 118 of the Clean Water Act supports this overall mission
through formally establishing GLNPO and giving it, in cooperation with
Federal, State and international agencies, responsibility for developing
and implementing plans to carry out the WQA. It also gives GLNPO
authority to coordinate EPA actions with the actions of other Federal
agencies, and State and local authorities. The WQ'A, the Clean Water
Act, and the various other statutes and regulations which EPA, the States,
and other Federal agencies implement are the primary vehicles for the
U.S. to fulfill this overall mission.
Section 118 of the Clean Water Act gives GLNPO additional
responsibilities, including: establishing a system-wide surveillance
network to monitor water quality, particularly toxic pollutants; carrying
out five-year demonstration projects relating to the control and removal
of toxic pollutants from the bottom sediments; developing a five-year
plan for reducing nutrients introduced into the Great Lakes; and providing
information to the IJC and Environment Canada.
Expectations for what the U.S. can accomplish on the Great Lakes have
been set too high, particularly given resource limitations; there has
been an unwillingness to say that EPA and the States cannot do
everything.
The WQA has extensive requirements, while EPA and State
resources for implementing them are limited. Yet, EPA has not laid out a
realistic schedule for what can be accomplished when. GLNPO's Five-
Year Strategy for 1989 to 1993*—which has been distributed widely—
reinforces the view that EPA will do everything. In addition, EPA has
committed at Congressional hearings to complete activities by specific
times, and yet missed meeting its own schedule. Clearly, EPA has set
unrealistic expectations, and has not done enough to explain that technical
complexities associated with addressing the Great Lakes could significantly
slow progress. As one GLNPO staff member indicated, "(EPA) managers
won't say no to whoever is asking for things—the IJC, Congress. They
keep pushing for more, pushing the deadlines; someone says we should
be doing something about zebra mussels. The command is to go do it.
But no one thinks about this in the context of what our priorities are
supposed to be. Every time we try to set priorities, we're given ten more
things to do."
* GLNPO, "Five Year Program Strategy for the Great Lakes National Program
Office, FY1989-1993" (Report No. 1-89), December, 1988.
20 A Review of EPA's Great Lakes Program
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Historically, EPA has not established clear environmental goals and
priorities for fulfilling its overall mission for the Great Lakes or a
reasonable schedule for completing various tasks.
EPA's goals have been expressed in such general terms that no
one can discern the limits of those commitments. For example, GLNPO's
Five-Year Strategy for 1989 to 1993 states that one goal is to "support the
completion and implementation of RAPs to restore beneficial uses in all
geographic Areas of Concern." Yet, given the large number of AOCs, each
of which has unique sources of contaminants requiring the development
and implementation of unique plans to meet the large number of Specific
Objectives identified in the WQA, it is not surprising that EPA and State
performance in developing and implementing RAPs has been slow.
In addition, EPA has not established environmental measures for
determining the success of the U.S. efforts to address the problems of the
Great Lakes. This is not unique to EPA's Great Lakes efforts; EPA has
had difficulties developing measures of environmental progress for most
of its programs. Like other EPA programs, progress on the Great Lakes
has been evaluated based on programmatic measures (e.g., completion of
Stage I, n RAPs), rather than on environmental measures (e.g., percent
reduction in toxics entering the Great Lakes, whether fish can be con-
sumed). Without such measures, it has been difficult to determine whether
EPA and State efforts on the Great Lakes have had the intended effects.
Without an overall strategic plan driving the Agency's decisions on
what Great Lakes activities it undertakes, the Agency's efforts have
lacked a clear focus; the relationship of ongoing activities to each other
has not been clear.
One of the most significant manifestations of this problem is
GLNPO's monitoring activities. GLNPO is responsible for overseeing
and implementing key aspects of the U.S. efforts to monitor the Great
Lakes. This monitoring program is focusing primarily on nutrients, a
problem that many people knowledgeable about progress on the Great
Lakes believe has been largely solved. In contrast, in developing RAPs
and Lake Management Plans (LMPs), the Regional Offices and States are
focusing on toxic pollutants, a much more serious problem, and are in
need of data on the presence of toxics. As one Regional Office program
manager indicated, "My plan lays out all of the problems (in the geographic
area), and yet GLNPO has never called me and asked what my monitoring
needs are. They call and say they'll be there with their (research) ship, but
I don't know what they are doing."
Many other of the Agency's Great Lakes activities have lacked a
clear focus.
Example: While there is general agreement that much of GLNPO
and Office of Research and Development research efforts are
worthwhile, how the results will be applied to the efforts of the
Regional Offices and States on LMPs and RAPs has not been clear
to those responsible for implementing and overseeing LMP and
RAP development.
A Review of EPA's Great Lakes Program 21
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Example: The Water Quality Initiative was undertaken to
encourage consistent water quality standards among the Great
Lakes States and ultimately renegotiate the Specific Objectives of
the WQA to make them consistent with the U.S. standards. Yet,
while the Water Quality Initiative was ongoing, GLNPO became
heavily involved in negotiations to add several Specific Objectives
to the WQA, even though they may ultimately need to be changed.
Example: Last year, GLNPO, on direction from senior Regional
Office management, circulated an inch-thick workplan outlining
all of the requirements of the WQA and asked the Regional Offices
to indicate what they would be doing to fulfill the requirements.
The message the Regional Offices received from this exercise was
that everything is a priority (so therefore, nothing is a priority).
Recommendations
The Agency must establish environmental goals and priorities for EPA
and State efforts to restore and maintain the environmental health of
the Great Lakes. A realistic schedule for the completion of activities in
support of the goals and priorities must also be developed.
GLNPO should take the lead in coordinating this effort and ensure
that all relevant organizations have input into its development. This
includes other offices in EPA Headquarters and the Regional Offices, the
Great Lakes States, other Federal agencies, external interest groups, the
IJC and Environment Canada. GLNPO should use the Great Lakes
Advisory Committee and the U.S. Policy Committee as mechanisms for
gaining input from these various groups, in addition to other mechanisms
(e.g., one-on-one meetings, distributing drafts for comment).
These goals and priorities must drive EPA and State Great Lakes
decisions and activities.
EPA should reevaluate its current activities to make certain that
those activities are in support of the goals and priorities. Where activities
are found to have no direct relationship, those activities should be cur-
tailed. The following should be reevaluated: the monitoring program,
the research program, the use of GLNPO's research vessel, and the extent
of EPA participation in IJC activities. EPA should take on no additional
activities unless they are in support of the goals and priorities.
To the extent practicable, EPA should establish environmental measures
for determining the effectiveness of the EPA and State activities on the
Great Lakes.
These measures should help EPA and the States determine the
extent to which environmental controls and prevention activities are
resulting in real improvements in the environment. Examples of the
measures which could be used include: percent reduction in discharge of
specified chemicals into the Great Lakes ecosystem; reductions in the
number of fish advisories; pounds of persistent toxics removed from
sediments per year; and reestablishment of rare species populations.
22 A Review of EPA's Great Lakes Program
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In addition, the EPA and the States should continue to use
programmatic measures to the extent that these measures help to support
EPA's goals for the Great Lakes. Examples of programmatic measures
include: submission of Stage I and II RAPs and LMPs to the IJC; required
reports submitted to requestor on time; and completion of a strategic
plan.
Current Agency Action
The Agency has taken a number of steps to define its operating
principles for approaching environmental protection to the Great Lakes,
as well as the Agency's goals, priorities, and strategy for restoring and
maintaining the chemical, physical, and biological integrity of the Great
Lakes.
Through the Great Lakes Advisory Committee, the Agency is
piloting an integrated, ecosystem approach to addressing the environmental
problems of the Great Lakes. For example, rather than focusing on single
media to restore and maintain the environmental quality of the Great
Lakes, the Agency will use an integrated approach to environmental
protection. In addition, pollution prevention will be the preferred
approach, followed by more traditional "end-of-pipe" controls under
existing statutes. The Agency will also focus its resources on problems
posing the greatest environmental risk. Finally, the Agency will work to
develop measures of environmental progress and success to gauge the
effectiveness of EPA and State efforts.
Using these operating principles, the Agency through the Great
Lakes Advisory Committee is developing a Five-Year Strategy which
defines goals and priorities, identifying the available tools for
implementation and measures of success. The Strategy presents a plan
for what can realistically be accomplished in the next five years, focusing
on the most significant environmental problems in the Great Lakes
(consistent with the recommendations of a recent EPA Science Advisory
Board report on Agency strategies for reducing risk*).
The overall environmental goals of the Five-Year Strategy (in or-
der of priority) are to:
• Reduce toxic loadings.
• Protect and restore habitat and species diversity.
• Achieve target loadings for nutrients.
The Strategy also will identify institutional goals and priorities to help
ensure effective implementation, as well as measures of environmental
progress and success to gauge the effectiveness of EPA and State Great
Lakes efforts.
* EPA Science Advisory Board, "Reducing Risk: Setting Priorities and Strategies
for Environmental Protection" (SAB-EC-90-021), September 26,1990.
A Review of EPA's Great Lakes Program 23
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The Agency already has met with the States to explain EPA's new
approach. Shortly, the Agency will meet with public interest groups,
Congress, and Environment Canada, among others, to obtain their views
about the Strategy, and make certain that the Agency and other important
groups involved in Great Lakes activities are working in concert.
The Agency also is in the process of completing and implementing
its Fiscal Year 1991 Action Plan, which identifies the various activities the
Agency, States, and others will be involved in for the year. This Action
Plan lays out the activities needed for the Agency to begin meeting the
commitments outlined in the Five-Year Strategy. The specific activities
the Agency commits to for Fiscal Year 1991 include:
• LMPs Submitting to the IJC Phase I LMPs for Lakes Michigan
and Ontario; establishing management structures for both LMPs,
including lakewide advisory councils; developing baseline toxics
loadings to the Lake Michigan system; developing for Lake Michi-
gan a stage 1 mass balance model and a stage 2 model for Lake
Ontario; and developing and/or improving monitoring plans for
Lakes Michigan and Ontario.
• RAPs—Completing ten additional Phase I RAPs and three Phase
n RAPs.
• Water Quality Initiative—Developing in Fiscal Year 1991 criteria
for aquatic life, human health, and wildlife as well as application
procedures; and continuing antidegradation work in Fiscal Year
1991 for completion in early Fiscal Year 1992.
• Contaminated Sediments—Initiating additional sediment
enforcement actions in several AOCs; developing sediment
assessment and classification guidance for dredging projects
initiated or permitted by the U.S. Corps of Engineers; developing
guidance and technical specifications to define disposal alternatives
for contaminated sediments; and completing an inventory of
sediments in Region V as a pilot for the National Sediment Strategy.
• Special Geographic Initiatives—For the Niagara River Toxics
Management Plan: Refining loading estimates; reducing loading
of toxic substances from waste sites; developing methods to reduce
detection limits in effluent; increasing public involvement; and
verifying non-point source load estimates.
For the Northwest Indiana Initiative: Developing and
implementing multimedia enforcement cases with pollution
prevention and remediation components; and assisting the U.S.
Corps of Engineers in dredging 1.2 million cubic yards of
contaminated sediments.
• Wetland Protection and Restoration—Developing a Great Lakes
wetland strategy; increasing wetlands enforcement; initiating
advanced identification programs in several Great Lakes sub-
basins; and developing public education materials.
In addition, EPA and Environment Canada are currently
developing a joint pollution prevention strategy for the Great Lakes,
asserting their mutual commitment to a pollution prevention approach to
24 A Review of EPA's Great Lakes Program
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the Great Lakes and their agreement on the principles which will underlie
each country's pollution prevention activities. The draft strategy:
• Identifies specific pollutants which will be targeted through
pollution prevention activities.
• Sets goals for reducing those pollutants and identifies ways of
measuring progress.
• Focuses institutions and programs on achieving identified
environmental goals through implementing a national voluntary
effort, implementing a public information campaign, incorporating
national goals into LMPs and working with the States to sponsor
pollution prevention workshops and conferences.
• Weaves prevention into the fabric of environmental protection
through incorporating pollution prevention into Grand Calumet
enforcement, implementing bilateral initiatives, incorporating
pollution prevention into LMPs and on-going regulatory programs,
and through other efforts.
• Ensures stakeholder involvement through the 1991 International
Great Lakes Pollution Prevention Symposium and emphasizing
voluntary efforts, among other efforts.
RESOURCES
Findings
GLNPO has not had—nor will it likely ever have—the authority or
resources to solve the complex environmental problems of the Great
Lakes by itself.
Other EPA offices, other Federal agencies, the States and local
governments possess this authority, and therefore, must be viewed as
GLNPO's partners in the Nation's efforts to address the Great Lakes. In
addition, cleanup of the Great Lakes will take many billions of dollars.
Clearly, the success of the Nation in cleaning up the Great Lakes will
depend on the commitment of resources from all levels of government,
not just from GLNPO.
EPA has not been fully successful in focusing limited resources on those
activities that will lead to the greatest environmental results.
In the past, the Agency has viewed EPA and State permitting,
enforcement, and compliance activities as separate from GLNPO's efforts
to improve the Great Lakes. As one State Director noted, "If they (GLNPO)
involved the States in a partnership role, they could be using our resources
as matching funds for their program. Their general attitude, however, is
to ignore the States and then pass their money off to contractors." In
addition, GLNPO's activities have not been well integrated into Regional
Office efforts on RAPs and LMPs. For example, GLNPO's monitoring
program focuses on nutrients, while the Regional Offices and States are
focusing on toxics in developing RAPs and LMPs.
A Review of EPA's Great Lakes Program 25
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Yet, staff from GLNPO, other EPA offices, and the States agree
that greater progress on the Great Lakes could be achieved through taking
more of an integrated approach to EPA's regular program responsibilities.
They indicated that GLNPO has a role to play in encouraging a more
integrated approach.
Statutorily mandated spending floors have limited GLNPO's flexibility
in how it uses its resources.
While many other factors (discussed in this report) have played a
significant role in limiting the ability of EPA and the States to maximize
progress on RAPs and LMPs, spending floors for the GLNPO budget
mandated under Section 118 of the Clean Water Act also have been a
factor. Only about five percent of GLNPO's extramural funds for Fiscal
Year 1989 went directly for RAPs and LMPs. This is in stark contrast to
similar programs, such as the National Estuarine Program which distrib-
utes about 90 percent of its extramural funds to the Region Offices and
States for development of plans to remediate estuaries. Many of the
States interviewed for this study indicated that the lack of Federal dollars
to support the development of RAPs has significantly hindered progress
on the plans at the State level.
Recommendations
GLNPO, the Regional Offices, States, and Headquarters should focus
attention on how to creatively apply available resources to the Agency's
priorities for the Great Lakes.
The focus should not be on who got what resources and why. For
example, if an office is devoting some of its resources to a particular
activity, GLNPO should consider contributing funding as an incentive
for that office to direct some of its work to the Great Lakes. Or, if
adjustments are made in GLNPO's budget, GLNPO should work with
other EPA offices through the Great Lakes Advisory Committee or other
less formal mechanisms to determine which activities should be increased
or decreased.
Current Agency Action
In developing the Agency's Five-Year Strategy for the Great Lakes,
the emphasis is on taking an integrated approach to environmental
protection and targeting a critical mass of limited resources to reducing
risk on a priority basis. The Great Lakes Advisory Committee has already
proved to be an effective body for creating an EPA partnership and
garnering commitments from various EPA offices to focus their attention
in a more integrated way on the Great Lakes. The Fiscal Year 1991
Action Plan further demonstrates that the Agency's limited resources
will be targeted to specific environmental and programmatic areas.
The Five-Year Strategy will be a subject for discussion at the
Agency's annual senior management planning session in February and
will become an integral part of the Agency's agenda. It will be during
these annual meetings that the Great Lakes NPM^ will be in the best
26 A Review of EPA's Great Lakes Program
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position to gain commitments from other EPA offices to undertake Great
Lakes activities. In addition, GLNPO—working in conjunction with the
Regional Offices—will be in an excellent position to negotiate commitments
from the States through the annual grant negotiation process.
EPA
LEADERSHIP
Findings
The roles of the Regional Administrator for Region V as the Great Lakes
National Program Manager (NFM) and the Assistant Administrator (AA)
for Water in providing overall leadership and direction to EPA's Great
Lakes efforts have been unclear.
The Agency generally considers an NPM as one who provides
overall leadership for and direction to a major Agency program. This
includes setting program policy, developing program priorities, and pre-
paring and defending the budget for the program. In addition, an NPM is
held accountable by the Administrator and Congress for the performance
of that program. In nearly all EPA programs, AAs serve as NPMs.
In the case of the Agency's Great Lakes efforts, however, the
distinction between the role of the Great Lakes NPM and the AA for
Water on Great Lakes issues is unclear. Having an RA serve as an NPM is
a unique situation in EPA; typically AAs, not RAs, serve as NPMs. And,
given that so much of what GLNPO does is water-related, the distinction
between the Great Lakes NPM and AA for Water becomes blurred. Both
the AA for Water and the Great Lakes NPM are involved in formulating
policy which affects the Agency's Great Lakes activities, and budget
decisions. Both are expected to be able to discuss Great Lakes issues in
meetings with the Administrator, Deputy Administrator, and other AAs.
Both are expected to discuss the Agency's position on Great Lakes issues
with Congress, other Federal agencies, and the public.
It would be difficult to designate one or the other as having
complete responsibility for these functions.
Example: The AA for Water is responsible for EPA's permit issu-
ance and non-point source water programs which control discharges
into the Nation's lakes and tributaries. The policies and priorities
established nationally affect the Great Lakes, and must be coordi-
nated closely with the Great Lakes NPM, among others.
Example: The Great Lakes NPM is often more accessible than the
AA for Water to Regions II and HI, the Great Lakes States, and the
government of Canada. It would be difficult to transfer all respon-
sibility for interacting with these groups to the AA for Water.
Likewise, the AA for Water is often more accessible than the Great
Lakes NPM to the Administrator, Deputy Administrator, and
Members of Congress for discussing pressing issues. It would be
difficult to transfer all of this responsibility to the NPM.
A Review of EPA's Great Lakes Program 27
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The AA for Water and Great Lakes NPM mutually agreed to the
role of each in terms of developing policy, coordination within and out-
side EPA, and budget preparation.* The agreement describes very broadly
the division of labor between them; it will need to be refined further in
order to clarify the role of each in specific situations, and to remove
doubts about who has decision-making authority for GLNPO's activities
and who speaks for the Agency on Great Lakes issues. For example,
further clarification is needed to define the specific role of each in budget
formulation versus budget allocation decisions.
Historically, some managers and staff in GLNPO and the Regional
Office programs have hindered rather than promoted action needed for
fulfillment of the Agency's commitments on the Great Lakes. In large
part, they have responded to their organization's own priorities, rather
than to the Agency's overall commitment to environmental progress on
the Great Lakes.
This problem has been a symptom of a fundamental problem
with EPA's entire Great Lakes program. EPA is not used to taking a
cross-program approach to a geographic area. The statutes EPA must
implement are structured along media lines, and the organization of EPA
follows from that. The jump from a programmatic focus to an ecosystem
approach has been difficult.
While these problems are not insurmountable, senior management
in the Regional Offices and GLNPO historically has had a high tolerance
for uncooperative behavior among their staffs. For example, even in casual
conversations about each other, GLNPO and the Regional Office staff have
been highly critical of each other. Unfortunately, this problem has
undermined EPA's effectiveness in accomplishing its overall mission for
the Great Lakes. For example, in meetings with the States, GLNPO and
Regional Office staff have often contradicted each other, making it difficult
for the States to know which group to listen to.
Recommendations
The RA for Region V should continue to serve as the Great Lakes
NPM, and be responsible for all functions which GLNPO performs.
The GLNPO Director should continue to report directly to the NPM.
An RA, responsible for multiple programs, can bring a cross-media
perspective to environmental problems in the Great Lakes that cannot be
obtained through a single-media program office. In addition, the majority
of EPA's resources devoted to Great Lakes activities are under the control
of the RA for Region V. The majority of Great Lakes States are in Region
V, and the RA for Region V is in the best position—through established
mechanisms—to gain commitments at the State and local levels for Great
Lakes activities.
Although there are some concerns that the RA for Region V is
"wearing too many hats," those involved in Great Lakes activities in
Regions n, HI, V and GLNPO must recognize that balancing the role of
* An August 23, 1990 memo from the AA for Water to the RA for Region V
reflects this agreement.
28 A Review of EPA's Great Lakes Program
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RA for Region V and NPM is a difficult one. But, ultimately, the issue is
not who the NPM is, but what can they do to help advance the Agency's
efforts on the Great Lakes, given the decisions that the NPM/RA makes.
The Great Lakes NPM and the AA for Water should refine their
agreement on the roles of each on Great Lakes issues.
The Great Lakes NPM should work with the AA for Water to
develop a more detailed proposal for the role he plays in relation to her
on Great Lakes issues. They should then share the proposal with the
Administrator and Deputy Administrator. The proposal also should be
shared with others in the Agency, including the RAs for Regions II and HI
and the other AAs. The final agreement that is reached on the specific
roles of the Great Lakes NPM and the AA for Water should be made
formal through the Agency's directives system. The agreement should
cover the following issues:
• The role of each in formulating Agency policies affecting the Great
Lakes. The agreement should identify who should have ultimate
decision-making authority and for which types of policy issues.
• The role of each in budget formulation and budget allocation
decisions. The AA for OARM should also be involved in the
discussions about the role of the Great Lakes NPM and AA for
Water on budget allocation decisions. All three should seriously
consider distributing GLNPO resources directly to the Great Lakes
NPM, rather than through the AA for Water.
• The role of each in communicating with the Administrator, Deputy
Administrator, other AAs, the EPA Regional Offices, States, other
Federal agencies at the Headquarters and Regional levels, Members
of Congress, and other external organizations.
There are several other rules of thumb that the NPM and AA for
Water should follow on Great Lakes issues:
• Close communication and coordination will be necessary to insure
that the Agency is unified in its approach to achieving its goals
and priorities for the Great Lakes. The AA for Water and NPM
should consider talking regularly (e.g., once every two-to-four
weeks) on Great Lakes issues.
• Each must support the Agency's goals and priorities for the
program by helping to deflect requests that do not advance the
accomplishment of the goals and priorities.
EPA's Administrator and Deputy Administrator must continue to support
strongly the Great Lakes as an Agency priority.
In addition, their strong support for the NPM, GLNPO Director,
and the Great Lakes activities of the AAs and RAs for Regions II, III and V
will be critical in the NPM's efforts to obtain Agency commitments for
Great Lakes activities. Mechanisms for doing this include: the Great
Lakes Advisory Committee, periodic meetings with the AAs, questions
focused on Great Lakes issues during budget reviews, and clear account-
ability in reviewing the performance of the AAs and RAs for Regions II,
HI, and V.
A Review of EPA's Great Lakes Program 29
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Senior management in the Regional Offices and GLNPO must set the
tone for cooperation and coordination among their staffs.
Senior managers should encourage an atmosphere where
discussions among their staffs focus on how to accomplish the tasks at
hand—within the statutes EPA, the States, and other Federal agencies
implement, and through other more innovative mechanisms. In addition,
management should continue to encourage details between GLNPO, the
various Regional and Headquarters offices, and State offices involved in
Great Lakes work.
Current Agency Action
Recognizing that strong leadership will be critical to the successful
implementation of the Great Lakes Five-Year Strategy, the Agency has
recently selected experienced Agency managers to fill key positions. A
new GLNPO Director and Region V Water Division Director were selected
in the last few months. The former DRA for EPA's Region X office was
recently chosen to serve in the same capacity for the Region V office. In
April, 1990, the EPA Administrator named the Deputy Administrator to
be the Chairman of the Great Lakes Advisory Committee, and the
membership of the Great Lakes Advisory Committee has been expanded
to include all EPA AAs, in addition to the RAs for Regions II, III, and V.
Through the leadership of these managers, as well as the Great
Lakes NPM and AA for Water, the Agency has made significant progress
in defining its goals and priorities and developing a strategy for the
Agency's Great Lakes activities.
Recognizing the need for further clarification in their relationship,
the Great Lakes NPM and the AA for Water are continuing discussions to
refine their agreement on their respective roles on Great Lakes issues and
activities. More specifically, they are focusing on their roles in: policy
formulation; budget formulation and allocation; and communication
within and outside the Agency.
ROLES
Findings
GLNPO has made progress in defining its role in relation to others in
EPA involved in Great Lakes work.
In response to direction from the Great Lakes NPM, GLNPO
defined its role in relation to others in EPA and the States, and transmitted
it through a March 22,1990 memo.* It described GLNPO's role in general
terms to serve as overall coordinator of the U.S. efforts to protect and
enhance Great Lakes water quality and to conduct monitoring, cooperative
* Memo from Carol Finch to Addressees, "Matrix of Responsibilities for Programs
Affecting the Great Lakes," March 22,1990.
30 A Review of EPA's Great Lakes Program
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studies, and demonstration projects. The Regional Offices and States are
designated as the chief implementors of the Agency's environmental
statutes and operational responsibility for RAP and LMP development
and implementation.
While the role described for GLNPO in the March 22nd memo is
generally on target, GLNPO's role continues to be unclear due to several
factors. These factors include: organizational issues, GLNPO's primary
role as an implementor, and GLNPO's limited success in serving as the
Agency's coordinator for the Great Lakes.
Organizationally, it is not easy to tell whether GLNPO is a Regional
Office program, a Headquarters program, or a combination of the two.
The distinction between GLNPO and Region V is blurred. GLNPO
is unique in that it coordinates the activities of multiple EPA Region Offices
and yet is collocated with an EPA Regional Office. GLNPO is unique
within the Agency in that it coordinates the activities of multiple Regional
offices and yet an RA serves as the NPM. The Region V Planning and
Management Division provides administrative support to GLNPO on such
areas as contracts, grants, financial management, personnel, and FMFIA
compliance—again a relationship that is unique in EPA.
hi addition, the Office of Water is heavily involved with GLNPO
activities. For example, the AA for Water has been responsible for aspects
of GLNPO budget formulation and allocation decisions; the Great Lakes
NPM has not been assigned this responsibility, despite that NPMs for
major programs are traditionally given this responsibility. The Office of
Marine and Estuarine Protection has provided support to GLNPO in de-
velopment and defense of its budget requests; most offices work through
their NPM's office for budget support. Lastly, the Agency as a whole has
had until recently little interest in the Great Lakes as a national problem; it
has generally viewed contamination of the Great Lakes as a Region V
problem, contributing to the view that GLNPO is a Region V program.
While the March 22nd memo gives GLNPO primary responsibility for
coordinating the Agency's Great Lakes efforts, in reality, other EPA
offices and the States view GLNPO more as an implementor of
environmental programs than as a coordinator of the Agency's Great
Lakes activities.
About half of GLNPO's staff is involved in developing and
implementing Great Lakes programs. The Surveillance and Research Staff
has lead responsibility for open lake monitoring of the Great Lakes and
operating GLNPO's research vessel. The Remedial Programs Staff has
lead responsibility for developing and implementing the contaminated
sediments program.
While GLNPO may have a legitimate role to play in developing
and implementing Great Lakes programs, its mindset has been to perform
these activities itself rather than asking the Regional Offices and States for
assistance in performing them. Yet, in some cases, it may make more
sense for GLNPO to enlist the involvement of other groups in performing
these activities. For example, to make the monitoring program most
A Review of EPA's Great Lakes Program 31
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responsive to the monitoring needs of the Regional Offices and States, it
may make more sense for GLNPO to play an overall coordinator role
(e.g., manage the contract for the research vessel, schedule Regional Office
use of the vessel), and for the Regional Offices to collect monitoring data
through the GLNPO contractor. The same may be true for other GLNPO
activities (e.g., the ARCS program, the research program).
In addition, GLNPO performs certain activities that are more typi-
cally performed by Regional Offices.
Example: In distributing resources to the States, GLNPO has ne-
gotiated directly with the States rather than working through the
Regional Offices during the regular grant negotiation process.
Example: In addition to the regular Regional Office program re-
view of permits, GLNPO historically reviewed some of them.
GLNPO has not been fully successful in getting other EPA offices to
undertake Great Lakes activities.
GLNPO has had limited success in playing the role of coordinator
in part because it has minimally participated in Agency systems and
processes which are recognized as being the key mechanisms for getting
other EPA offices and the States to undertake activities in support of EPA
priorities.
Example: While GLNPO provides overall guidance to the Re-
gional Offices through the Agency Operating Guidance, and has
worked with other offices in the Office of Water to get a Great
Lakes perspective into their guidance, the emphasis on the Great
Lakes in those other offices' guidance has been minimal. For
instance, in the Fiscal Year 1991 guidance, no mention is made of
the Great Lakes in the discussion of water enforcement priorities.
Example: GLNPO participated in the Strategic Targeted Activi-
ties for Results System (STARS) for the first time in Fiscal Year
1991. It has one measure in STARS which is for "the achievement
of the various goals/objectives of the WQA." This measure will
need to be defined in greater detail to help set priorities and guar-
antee action. As one Regional Office program staff member indi-
cated, "GLNPO tells us to go do something, but they don't realize
that we have plenty of other things to do which are required
under STARS and which are driving our managers' decisions on
what we'll be doing."
Example: GLNPO's discussions with the Regional Offices about
State grant negotiations have occurred after the Regional Offices
have reached agreements with the States on their activities for the
year; GLNPO's agenda becomes an afterthought.
Example: GLNPO has not instituted predictable, standing meet-
ings with the three Regional Offices for clarifying priorities and
formulating measures of progress. Such meetings are standard
for nearly all EPA national programs.
Example: GLNPO has not participated in the Agency's regula-
tory development process. As a result, GLNPO has lost opportu-
nities to bring a Great Lakes perspective to Agency regulations.
32 A Review of EPA's Great Lakes Program
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For instance, the Agency is currently developing regulations for
the control of emissions from municipal incinerators. GLNPO has
not participated on the working group, although emissions from
municipal incinerators are a significant source of contamination of
the Great Lakes.
Recommendations
The Great Lakes NPM should continue to be responsible for the
functions GLNPO performs in the Agency.
Therefore, where the following recommendations refer to the role
and functions GLNPO should perform, it should be clear that the Great
Lakes NPM is ultimately responsible for playing this role and performing
these functions in the Agency. (See the EPA Leadership section for rec-
ommendations on the role of the Great Lakes NPM in relation to the AA
for Water.)
The Agency should further clarify GLNPO's role in the Agency's efforts
to fulfill its overall mission for the Great Lakes.
In clarifying that role, the Agency should define GLNPO as the
Agency's chief coordinator, integrator, and catalyst for bringing together
EPA Headquarters and Regional Offices, the States, and other Federal
agencies to develop and implement approaches for addressing the Great
Lakes. GLNPO should be the Agency's lead strategist for the Great Lakes,
and assume more the role of the orchestra conductor, rather than that of
trying to play all of the instruments in the orchestra itself.
While it may be appropriate for GLNPO to continue to serve as
the Agency's chief implementor of the Great Lakes monitoring and research
programs, the Agency and GLNPO should review these programs to make
certain they are most responsive to the needs GLNPO is serving. For
example, the Agency should review its Great Lakes monitoring program
and develop an integrated monitoring plan that incorporates the data
needs of the Regional Offices and States and defines the role of the various
EPA offices and States in data gathering. This should help to ensure that
the data being collected best helps decision-makers and measures progress
in restoring the Great Lakes.
The Great Lakes Advisory Committee and the U.S. Policy
Committee are key mechanisms for clarifying GLNPO's role in relation to
others in the Agency and the States. In addition, the Agency should
consider establishing special research and monitoring advisory groups—
either separate from or as subcommittees of the Great Lakes Advisory
Committee—to reexamine EPA's Great Lakes monitoring and research
programs.
While EPA is in the process of defining the Agency's goals and priorities
for the Great Lakes which will ultimately have an impact on the functions
GLNPO should perform, there are some general statements which can
be made about what GLNPO's role should be. It should:
• Coordinate and integrate the Agency's efforts to develop and
implement the goals and priorities for its Great Lakes program.
A Review of EPA's Great Lakes Program 33
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Once the goals and priorities are set, negotiate commitments and
schedules from the various EPA programs for assistance in
achieving those goals and priorities. Then, GLNPO should use
the established processes for getting those goals and priorities
incorporated into the Agency's overall agenda. More specifically,
the Great Lakes NPM should attend the Agency's annual senior
management planning meeting as an advocate for the Great Lakes,
and should negotiate with senior managers to get activities in
support of the Great Lakes incorporated into the Agency Annual
Operating Guidance.
Example: If a program office plans to undertake a number of
initiatives for dealing with an environmental problem, GLNPO
should negotiate with that office provisions in the guidance for
focusing those initiatives on the Great Lakes.
Example: If a program office requires a certain percent of existing
facilities to be inspected per year, GLNPO could negotiate a more
ambitious inspection target for facilities discharging into the Great
Lakes, and get that incorporated into that program's operating
guidance.
As a part of these negotiations, GLNPO should oversee decisions
on investments and disinvestments to insure consistency, avoid
duplication of effort, insure the appropriate mix of activities, and
stay abreast of changes in direction in the field.
Where the Agency lacks the authority to perform specific activities
in support of its goals and priorities for the Great Lakes, negotiate—
in conjunction with other EPA offices and the States—commitments
from other Federal agencies or external groups.
Example: If it is determined that EPA and the States cannot take
action to correct a problem due to statutory limits or a lack of
resources, but another Agency has that authority and resources,
GLNPO should—with the EPA and State programs—work with
the other Agency to ensure its support.
Example: If statutory authority is necessary but EPA and/or other
Federal agencies lack it, GLNPO, in cooperation with other EPA
offices, should work with Congress to get the needed changes.
Work with the Regional Offices to negotiate commitments from
the States for Great Lakes activities. GLNPO should not be
involved in direct negotiations with the States, but should rely on
the Regional Offices, during the regular grant negotiation process,
to enter into agreements with the States.
Participate in Agency processes to focus Agency activities on the
Great Lakes. For example, GLNPO should participate in STARS,
the regulatory development process on selected regulations, and
a limited number of the Agency's regulatory cluster groups to
ensure that an appropriate level of attention and resources are
going toward Great Lakes activities.
Example: If a more aggressive inspection effort for facilities dis-
charging into the Great Lakes will facilitate achieving an Agency
34 A Review of EPA's Great Lakes Program
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priority for the Great Lakes, GLNPO should work with the EPA
program which establishes STARS commitments to make certain
that facilities affecting the Great Lakes are especially targeted.
Example: Where the Agency develops regulations to control a
national problem, which also contributes significantly to degrada-
tion of the Great Lakes, GLNPO should serve on the working group,
or work through other members (e.g., ones from the Office of Water
or OPPE), to bring a Great Lakes perspective.
Where necessary, develop, in cooperation with Headquarters and
Regional Offices, integrated technical guidance for use in
implementing key elements of the Great Lakes program. GLNPO
could prepare the integrated guidance itself or provide input into
technical guidance that other EPA offices are developing.
Review the effectiveness of the U.S. efforts to restore the Great
Lakes, and, where progress has been slow, encourage better
performance. GLNPO has a number of mechanisms which can be
used to do this. The U.S. Policy Committee and the Great Lakes
Advisory Committee are open fora for discussing progress on the
Great Lakes. In addition, GLNPO should meet annually with the
Deputy Administrator to discuss EPA and State progress.
Use its limited resources to provide incentives to other EPA offices,
the States, and other Federal agencies to direct their resources
toward EPA priorities in the Great Lakes.
Example: If an EPA office is undertaking an initiative to examine
a national problem which particularly affects the Great Lakes and
is consistent with its priorities, GLNPO should consider contributing
some of its funds as an incentive for getting that office to focus its
initiative on the Great Lakes. EPA's Chesapeake Bay Program has
used this approach in fulfilling its mission.
Serve as the catalyst for helping EPA and the States identify research
needs for the Great Lakes consistent with the Agency's goals and
priorities, and insure that the appropriate level of Agency resources
are applied to meeting those needs. The Agency should consider
establishing a special research advisory group, either separate from
or as a sub-committee of the Great Lakes Advisory Committee.
The Agency's Science Advisory Board could provide advice to this
committee on an as-needed basis. In addition, GLNPO should use
its participation in the Agency's Research Committee Process to
ensure that the Agency is taking the Great Lakes into account in its
decisions on the Office of Research and Development's research
agenda, particularly in media other than water (e.g., air, hazardous
waste).
Serve as the focal point for developing an integrated Agency
monitoring strategy for the Great Lakes. More specifically, GLNPO
should serve as the catalyst and coordinator for bringing other
EPA offices and the States together to: identify monitoring needs
within the context of the Agency's overall goals and priorities for
the Great Lakes; identify the most appropriate parties—whether it
be GLNPO, the States, Regional Offices or the Office of Research
A Review of EPA's Great Lakes Program 35
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and Development—to fill those gaps; insure coordination and
sharing of monitoring data among those in need of it; and insure
that consistent analytical methods are developed and employed
by all groups collecting data. The Agency should consider
establishing a senior level monitoring advisory group, possibly as
a sub-committee of the Great Lakes Advisory Committee or the
U.S. Policy Committee. This advisory group should be responsible
for: ensuring that a strategic monitoring program is developed
that supports the Agency's goals and priorities; and coordinating
EPA's program with the data collection activities of other Federal
agencies.
• Serve as the catalyst for bringing together the U.S. position on
issues and then serve as the U-S.'s chief representative in discus-
sions with the IJC and Environment Canada. The U.S. Policy
Committee was established to facilitate this. To enhance the
Committee's effectiveness as a coordinating body, GLNPO should
make a concerted effort to transmit background materials early
and allow adequate time for the Committee to formulate the U.S.
position.
GLNPO should also follow several rules of thumb in performing its
functions:
Work to build the capability of the Regional Offices and States to
take a Great Lakes perspective in performing their functions. Thus, rather
than GLNPO reviewing permits for a Great Lakes perspective, GLNPO
generally should work with the office responsible for EPA's permit training
program to make certain that a Great Lakes perspective is a part of the
curriculum, particularly where the course is offered in Regions II, III and
V.
Rely as much as possible on the skills and expertise of the Regional
Offices and States in implementing specific activities. Rather than GLNPO
trying to implement specific program elements itself, it should negotiate
with the Regional Offices commitments to place priority on Great Lakes
work and emphasize the need for program integration in all of these
activities. GLNPO should then rely on the Regional Offices to negotiate
commitments from the States.
GLNPO should rely on the Regional Offices for direct contact
with a State. If such contact occurs through fora where the Regional
Offices are absent (e.g., IJC meetings), GLNPO should inform the relevant
Regional Offices shortly after the contact.
Once key offices within and outside the Agency agree upon the goals
and priorities for the Agency's Great Lakes effort and GLNPO's role in
that effort, a workforce planning analysis of GLNPO's staffing structure
and composition should be undertaken.
This analysis should examine GLNPO's current organization, staff
skills, and expertise in light of its primary role as the coordinator of
Agency's Great Lakes activities. In addition, this analysis could be used
as the basis for identifying the workforce needs of the Agency for other
cross-media initiatives. GLNPO should request support for this analysis
from OARM.
36 A Review of EPA's Great Lakes Program
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Current Agency Action
The Agency has recognized that if it is to succeed in fulfilling its
overall mission for the Great Lakes, it must look to the Great Lakes NPM
and GLNPO to serve as overall coordinator, catalyst, and integrator for
making certain the Agency undertakes activities in support of its overall
mission. The roles that GLNPO and Region V are currently playing in
coordinating the Agency's efforts to define its goals, priorities, and strat-
egy for the Great Lakes are consistent with the roles recommended in this
report. The Administrator and Deputy Administrator have provided the
overall leadership and support needed for the Great Lakes NPM and
GLNPO Director to play this role, and the various EPA Headquarters and
Regional offices have responded enthusiastically by identifying specific
activities their offices will undertake to further the Agency's progress on
the Great Lakes.
While GLNPO will continue to implement some selected activities
(e.g., aspects of the monitoring and research programs) which are required
under Section 118 of the Clean Water Act, the Agency and GLNPO are
currently working to tailor GLNPO's activities to address specific needs
of others inside and outside the Agency involved in Great Lakes work
and to rely on other parts of the Agency to assume responsibilities for
tasks that they are better equipped to handle. For example, GLNPO is in
the process of establishing a Great Lakes Surveillance, Research and
Monitoring working group which will review the Agency's Great Lakes
monitoring program and develop an integrated monitoring plan that
incorporates the data needs of the Regional Offices and States and defines
the role of the various offices in data gathering.
Finally, GLNPO is beginning to integrate itself more into the Agency
processes and systems to make certain that goals and priorities for the
Great Lakes are taken into account.
Example: At the annual senior management planning meeting in
February, the Five-Year Strategy for the Great Lakes will be dis-
cussed and taken into account in negotiations on the Agency's
agenda.
Example: GLNPO is currently engaged in discussions with OPPE
to expand its participation in STARS, and to provide a Great Lakes
focus to other EPA offices' measures.
Example: GLNPO will also be working through the Regional Of-
fices to negotiate commitments from the States during the annual
planning process.
A Review of EPA's Great Lakes Program 37
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COMMUNICATION
AND COORDINATION
Findings
While a number of mechanisms exist to facilitate communication and
coordination between GLNPO and the Regional Offices, there is room
for improvement.
Numerous staff level coordinating committees have been created
for specific GLNPO initiatives (e.g., Green Bay Mass Balance Study, ARCS
program) which meet to discuss the progress of the efforts, review prod-
ucts, and provide input into decisions. Senior level coordinating commit-
tees, including the Great Lakes Advisory Committee and the U.S. Policy
Committee, were created to enhance communication at senior manage-
ment levels. A recent GAO study* points to these various senior level
coordinating committees as a sign that significant progress has been made
in improving communication and coordination.
These committees, however, have not been enough to insure ef-
fective communication and coordination. Poor communication and coor-
dination within EPA have limited the extent to which senior manage-
ment in GLNPO and the Regional Offices fully understand the various
initiatives each is undertaking and the relationship of those initiatives to
the Great Lakes work in which their offices are engaged. For example,
some senior Regional Office managers indicated that the connection be-
tween the GLNPO's monitoring program, the ARCS program, and RAPs/
LMPs is unclear. As one GLNPO staff member indicated, "We've done a
great job collecting data, but a poor job selling it. The players don't know
what we've done." In some cases, this lack of understanding is due to
the fact that some senior Regional Office and GLNPO managers do not
ask their own staff who are participating on various coordinating com-
mittees about the status of activities. Or, their staffs are not communicat-
ing this information upward. Or, it may be because the connection be-
tween these various activities is weak.
While GLNPO has focused a great deal of attention on fulfilling many
important functions, it historically has put too little attention on its
role as coordinator, communicator, and integrator.
Historically, GLNPO has favored its role as an implementor of
environmental programs rather than as the chief communicator, coordi-
nator, and integrator of the U.S/s Great Lakes activities. (See the second
full finding on page 31 for a more detailed discussion of this issue.)
In addition, where GLNPO has served as a communicator and
coordinator, it has not been fully effective. Rather than trying to commu-
nicate and coordinate through various mechanisms to ensure the most
effective transmittal of information, GLNPO has often relied on a single
mechanism for conveying important information (primarily memoranda).
* U.S. General Accounting Office, "Improved Coordination Needed to Clean Up
the Great Lakes" (GAO RCED-90-187), September, 1990.
38 A Review of EPA's Great Lakes Program
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For example, a GLNPO staff member reminded a Region V staff member
that everyone should have known that zebra mussels were going to be a
problem because GLNPO wrote a memo about it two years earlier. In
another case, a memo was written defining the role of GLNPO in relation
to others. GLNPO staff point to this memo as an example of where they
have effectively communicated their roles. Yet, a number of staff from
Region V are confused by the memo and believe it has made GLNPO's
role less clear.
Finally, Region V and GLNPO historically have not always
coordinated with Regions II and HI or with the Great Lakes States in a
timely fashion. For example, Regions n and in and the States often learned
about important meetings at the last minute, and could not attend, even
though they would have had they been given earlier notice. Monthly
RAP and LMP meetings, however, have been helpful in keeping the
Regional Offices and States current in those areas.
Communication between Congress and Agency offices involved in Great
Lakes activities has been fragmented and has lacked coordination.
Communication between EPA and Congress on Great Lakes issues
occurs through many Agency offices, including the Administrator's Office,
GLNPO, Regions II, III, and V, the Office of Water, the Office of
International Activities, the Office of Congressional and Legislative Affairs,
OARM, and occasionally through other EPA offices.
With such diffuse activity, there is a great risk of not being
adequately responsive to Congress. This could occur through offices
referring inquiries to another office, providing too narrow or broad a
response, or providing outdated or inconsistent information. Differing
answers may create the perception that the Agency does not speak with
one voice.
It would be difficult to confine inquiries from Members of Congress
and their staff to one office. For instance, if an Agency official receives a
call from a Member of Congress, the official must make an immediate
judgement as to whether it makes more sense to give an immediate answer,
and possibly provide incomplete information, or refer the caller to someone
who is more knowledgeable. Despite this difficulty, ground rules could
be established to help manage such contacts and ensure a higher level of
coordination than currently exists.
Recommendations
If GLNPO is to succeed as the chief coordinator, communicator, and
integrator of the U.S/s Great Lakes activities, it must become the
Agency's chief advocate for the Great Lakes.
GLNPO must bring together those groups within and outside the
Agency to define goals and priorities for the Great Lakes, and the activities
which should be undertaken to meet those goals and priorities. GLNPO
should work with these various groups to develop a schedule for activities,
and make certain commitments are fulfilled. (See the second
recommendation on page 33 for a more detailed discussion of the role
GLNPO should be playing.)
A Review of EPA's Great Lakes Program 39
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In serving as the chief coordinator, communicator, and integrator for
the Agency's Great Lakes activities, GLNPO should examine—before
deciding on an approach—the broad spectrum of options it has open to
it for making certain its message is effectively conveyed and adequately
responded to.
While formal coordinating committees are useful for insuring
communication, coordination, and integration, they should be considered
one mechanism among many which are available to GLNPO, the Regional
Offices, Headquarters, and the States.
GLNPO should consider working through various Agency
processes and systems to make certain that the Agency's goals and
priorities for the Great Lakes are taken into account in decisions about
the Agency's agenda. This includes participating in the annual senior
management planning meeting and STARS, and negotiating commitments
from the States through the Regional Offices, etc. (See the fourth bullet
on page 34 for more details.)
GLNPO should also consider using other mechanisms for ensuring
effective communication and coordination: frequent senior level staff
meetings between GLNPO, the Regional Offices and the States; the
circulation of weekly or bi-weekly status reports covering the Regional
Offices' and GLNPO's activities to date and upcoming events; a "lead-
State" system (similar to EPA's lead-Region concept) for Great Lakes
issues, relying on that State to garner the views and comments of the
other Great Lakes States on key issues (certainly, GLNPO should consult
with the States before adopting this approach); and workshops on
management and technical issues.
GLNPO should follow these rules of thumb in its efforts to
communicate and coordinate within and outside EPA: involve relevant
EPA offices and States early in discussions about various Great Lakes
issues, and transmit material in a timely manner to allow adequate review
time; rely as much as possible on the Regional Offices for direct contact
with States; and develop policies with others within and outside EPA
through heavy up-front consultation. This could be through informal
working groups or one-on-one meetings.
Finally, to the extent that other offices have the lead responsibility
for coordinating Great Lakes activities, they should use the above-
described mechanisms for communicating and coordinating with others
within and outside the Agency.
To enhance GLNPO's efforts to communicate and coordinate with those
at Headquarters, GLNPO should establish a Headquarters liaison office
in Washington, D.C.
This office should be supported by the GLNPO budget and be
responsible directly to the GLNPO Director. This position should be
housed in the Office of Water. (In establishing a liaison office, GLNPO
should examine as a model the D.C. liaison office for EPA's Office of Air
Quality Planning and Standards which is located in Research Triangle
Park, N.C.)
40 A Review of EPA's Great Lakes Program
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Some ground rules for interacting with Members of Congress and their
staff should be adopted.
Contact from and with Members of Congress and their staff should
be encouraged. To ensure effective coordination of such contact within
the Agency, a system should be instituted with the GLNPO Director as
the focus. In Headquarters, the Executive Secretariat should continue to
direct Congressional correspondence primarily to the GLNPO Director,
and should assure that the GLNPO Director, via the Region V Congres-
sional Liaison, receives a copy of all Great Lakes program correspondence
directed elsewhere. The Congressional Liaisons for Regions n and HI
should do the same.
All telephone communications with Members of Congress or then-
staff should be coordinated through a formal system. Each phone conver-
sation should be briefly documented and communicated electronically to
key Agency officials. The Region V Congressional Liaison should de-
velop and maintain the system for GLNPO. The Region V Congressional
Liaison should assure coordination between the Great Lakes NPM and
the GLNPO Director, and maintain a complete record of all contacts with
Members of Congress.
Current Agency Action
The efforts of the DRA for Region V, GLNPO Director, and Region
V Water Division Director to coordinate the development of the Five-Year
Strategy, the Fiscal Year 1991 Action Plan, and the Pollution Prevention
Strategy have effectively brought together all offices within the Agency to
define the Agency's goals, priorities, activities, and measures of success
for its Great Lakes work. Extensive efforts have been made, using the
Great Lakes Advisory Committee forum, to make certain that all EPA
offices have been fully aware of upcoming events and have had input into
the strategies, policies and approaches. These senior managers have been
effective in coordinating development of integrated plans that bring various
EPA statutes, regulations, skills and expertise together toward common
goals and priorities.
In addition, GLNPO and Regions II, III, and V have met with State
environmental Directors and representatives of the various Governors to
explain EPA's new approach and to enlist State support and enthusiasm.
In the near future, these outreach efforts will be expanded to other Federal
agencies with a vested interest in the Great Lakes ecosystem.
GLNPO and Region V have also instituted an informal system to
make certain that all interactions with Members of Congress and their
staffs are well-coordinated. GLNPO expects to work over the coming
months with other EPA offices to institute an Agency-wide system of
coordination for such interactions.
GLNPO is also in the process of establishing a D.C. liaison office.
GLNPO has already engaged in discussions with representatives from the
Office of Air Quality Planning and Standards to learn more about their
liaison office. GLNPO expects that its liaison office will be in place in the
near future.
A Review of EPA's Great Lakes Program 41
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CONVEYING
GREAT LAKES ACCOMPLISHMENTS
Findings
EPA needs to do a better job of communicating Agency and State
successes in the Great Lakes, the complexities of the environmental
problems that remain, and the approach of EPA and the States for
meeting those challenges.
Communication about EPA's efforts have generally emphasized
accomplishments of GLNPO and what work remains, rather than on the
contributions of other EPA offices, the States, and other Federal agencies.
This problem, however, is not unique to EPA's Great Lakes efforts. The
same is true for EPA's efforts in this area for many other Agency programs.
There are several examples where EPA could have communicated
more fully all of its accomplishments on the Great Lakes.
Example: The focus of a written statement at a recent Senate
Oversight Subcommittee hearing was on the ARCS program, RAPs,
LMPs, the Water Quality Initiative, and the Spill Program. Hardly
any mention was made of the other program activities that EPA
has been implementing for years to control waste discharges, or the
program's successes (e.g., the control of eutrophication).
Example: Reports that have been written on EPA and State ac-
complishments on the Great Lakes do not discuss in any detail
enforcement activities.
(Section III of this report discusses the environmental
accomplishments of Federal and State governments in addressing the
Great Lakes, as well as the environmental challenges which lie ahead.)
The recent creation of a GLNPO public affairs liaison to conduct
community outreach and promote public awareness has been a step in
the right direction.
The Great Lakes public affairs specialist has been in her position
for about seven months. Prior to that time, Great Lakes public affairs
was handled on an ad hoc basis; the responsibility was rotated among
Region V public affairs specialists, and no long-range workplan was in
place for Great Lakes outreach.
The new public affairs specialist is currently making formal her
Great Lakes outreach responsibilities by developing a public affairs
strategy and workplan which lays out both short and long-term priorities.
In addition, the specialist was instrumental in developing and promoting
a contest among school children to name the new research vessel, and in
publishing a brochure entitled, "Great Minds? Great Lakes!"
The Agency has not been fully successful in keeping Members of
Congress informed of the Agency's progress on the Great Lakes.
For the most part, the Agency has made limited attempts to meet
with Members of Congress and their staff. The primary vehicle for
42 A Review of EPA's Great Lakes Program
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interacting with Members of Congress has been Congressional hearings,
where EPA's performance in addressing the Great Lakes has been heavily
criticized.
In addition, the Agency has been slow in submitting its annual
report to Congress, undermining the Agency's credibility with Congress.
Section 118 of the Clean Water Act requires that a report be submitted to
Congress by December 31st of each year. The Fiscal Year 1988 report,
however, was completed in April, 1990,16 months after it was due. The
Fiscal Year 1989 report has not yet been submitted, and is being prepared
together with the 1990 report.
Recommendations
Once the Agency has determined its goals and priorities for the Great
Lakes, GLNPO—in conjunction with communications experts within
the Agency—should develop a strategy for communicating its
accomplishments to-date on the Great Lakes, the environmental
challenges remaining, and EPA's program for meeting those challenges.
This communication strategy should build on the one being
currently developed by the Great Lakes public affairs specialist. It should
focus on how to convey the Agency's full Great Lakes accomplishments,
including those activities in support of the WQA and those to fulfill
requirements of EPA's various statutes. It should identify vehicles for
enhancing communication with Members of Congress, environmental
interest groups, the IJC, and Environment Canada. Lastly, the strategy
should identify procedures for the development and review of EPA-
generated documents which discuss the Nation's progress on the Great
Lakes.
The Agency must put greater emphasis on keeping Members of Congress
and their staff informed of the Agency's progress in restoring the Great
Lakes.
The Agency should view Congressional hearings as one mechanism
among many for interacting with Members and their staff. Other
mechanisms which could be used: meetings with key Members as issues
arise; telephone conversations with Congressional staff; briefing Members
and their staffs on the programs accomplishments and challenges.
In addition, the Agency must make concerted efforts to submit the
annual report to Congress on schedule. Drawing on experience gained
during the current efforts to develop the report, GLNPO should systematize
and institutionalize a process for identifying sources of data for the report,
and the timing of each report element. More specifically, GLNPO should
work with other offices within and outside the Agency to make certain
the data is available and can be released to GLNPO, and that it can be
provided in the needed format. GLNPO should work through the Great
Lakes Advisory Committee and the U.S. Policy Committee to solicit the
cooperation of the various offices, in addition to using more traditional
approaches for soliciting data (e.g., letter from NPM to State environmental
directors).
A Review of EPA's Great Lakes Program 43
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Current Agency Action
The Agency is developing a Great Lakes communications strategy
to help ensure that EPA and State programs, accomplishments, and
challenges are most effectively communicated within and outside the
Agency, and to mobilize public support and assistance in protecting and
restoring the Great Lakes ecosystem.
The Agency has already taken steps to provide Members of
Congress and their staffs with additional information about its Great
Lakes accomplishments and challenges. For example, senior GLNPO
and Region V management recently met with Congressional staff to discuss
the Agency's Five-Year Strategy, Fiscal Year 1991 Action Plan, and
Pollution Prevention Strategy for the Great Lakes. GLNPO and Region V
anticipate that such meetings and contact will occur on a continuing
basis.
EPA has also taken initial steps to improve its responsiveness to
Congress in terms of tracking progress on meeting commitments made at
hearings and in the Great Lakes Critical Programs Act of 1990. Because
the commitments reflect the involvement of multiple program offices,
tracking will be coordinated by the Office of Congressional and Legislative
Affairs. The Office of Congressional and Legislative Affairs will maintain
a matrix that indicates the nature of the commitment, the deadline, and a
contact person for each activity. It will also remind the appropriate
individuals of upcoming deadlines, and if commitments will be missed,
will notify the Office of the Deputy Administrator and the Great Lakes
NPM.
ADMINISTRATIVE
MANAGEMENT
While GLNPO and Region V Planning and Management Division have
made progress in the administrative management of their programs
since the 1989 OARM management review, there is room for
improvement. The Region V Planning and Management Division
should continue to expand its focus and provide the leadership and
professional management support needed for this highly visible
program to succeed.
The Planning and Management Division, as a key participant in
the Agency's Great Lakes efforts, must go beyond providing the requisite
support services, and follow its "Commitment to Quality" approach, using
Total Quality Management principles to continually gauge and assess
GLNPO's service needs. This should be done with a continual emphasis
on improving processes and products and, at the same time, being able to
respond to ad hoc requests for special services such as assisting with
sensitive personnel issues, or providing contingency planning in
anticipation of expanding GLNPO requirements.
44 A Review of EPA's Great Lakes Program
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The new direction the Agency is taking for the Great Lakes poses
management challenges and demands that may exceed the current resource
and skill levels of the Region V Planning and Management Division. It is
incumbent upon Region V and GLNPO senior managers to address this
need and provide more collegial, proactive and creative management
solutions for dealing with the unique problems the Agency's Great Lakes
program presents.
In addition, changes are needed in the administration of GLNPO
in key management areas including: budget, grants management, contracts
management, financial management, management integrity, and
information resources management.
BUDGET
Findings
At the time of the 1989 management review, new budget tracking
procedures for GLNPO were established in recognition of the sub-par
performance of GLNPO's management to administer its budget in a man-
ner consistent with Congressional mandates and priorities. To buttress
these controls and to respond to the need for more effective leadership,
the Agency recently selected experienced senior managers to fill positions
which will be critical to the successful implementation of the Agency's
new Great Lakes strategy.
As noted earlier, the Great Lakes program will serve as a test case
and proving ground for pollution prevention as it endeavors to apply the
Administrator's more integrated approach to controlling environmental
contamination. Thus, along with this integrated approach comes the added
challenge of how to best tailor a budget process that responds to the
multimedia nature of the program, while comporting with the Agency's
overall framework for budgeting.
In the long term, therefore, the Agency expects to adopt budget
formulation and allocation processes which better accommodate strategic
planning and facilitate budgeting for cross-media efforts such as the Great
Lakes, m this regard, senior Agency managers currently are reexamining
the procedures for budget formulation and execution relative to GLNPO.
This analysis will be completed in March, 1991.
Recommendations
The overall principle for realigning the GLNPO budget process
should be an integrated environmental management and budget approach
which will require team work and consultation between the Great Lakes
NPM and the AA for Water to coordinate and carry out the planning,
development and execution of the GLNPO budget. For budget allocation
purposes, these senior managers should consider treating GLNPO as a
Regional Office-managed program, rather than a Headquarters-managed
one; operating plan resources would be allocated directly to the Great
Lakes NPM, rather than through the AA for Water.
A Review of EPA's Great Lakes Program 45
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GRANTS MANAGEMENT
Findings
The Region V Planning and Management Division has generally
implemented the grants-related recommendations from the 1989 OARM
report. Those recommendations were similar to recommendations in a
September, 1989, EPA Inspector General audit report.* Both the OARM
and Inspector General reports found that GLNPO did not have data
available to assure that GLNPO grant recipients met grant requirements,
including filing timely reports.
Since that time, GLNPO and the Region V Grants Management
Section have worked together to correct the information available in EPA's
Grants Information Control System. They have also developed data en-
try screens to track additional information on the status of grants (e.g.,
the receipt of quarterly and final reports, Financial Status Reports and
grant close outs).
The Inspector General's 1989 audit report also recommended that
GLNPO and Region V close out grants on a timely basis. The Region V
Grants Management Section and GLNPO are now systematically closing
out and deobligating unexpended funds under completed projects.
The grants management issue of primary concern has been the
purchasing and refitting of GLNPO's research vessel. In fact, the purchase
delays were one reason that the 1989 OARM management review was
undertaken. More recent delays in refitting the vessel mainly have been
due to equipment and material delivery problems. The refitting work,
however, was already on a "catch-up" basis due to previous delays in
purchasing the ship. While the project officer's efforts were sensitive to
the contract delivery date, the principal focus was on assuring the job
was well done and as thorough as possible.
Recommendations
GLNPO and Region V management must stress to staff the critical
need to meet specific Congressional mandates and comply with Agency
grants management requirements. Emphasis should be put on
immediately reporting to GLNPO and Region V management any
problems potentially affecting grant delivery date requirements. Senior
managers will then be in a position to make decision between competing
objectives, such as time versus thoroughness.
CONTRACTS MANAGEMENT
Findings
Consistent with the 1989 management review, no major problems
within the contracting arena were discovered. Minor concerns were cited
regarding contract management techniques and file maintenance. For
* EPA Inspector General, "Great Lakes National Program Office Grants Program"
(Report No. E1H1F8-05-9100474), September 12,1989.
46 A Review of EPA's Great Lakes Program
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example, the Region V contracts office has not been as aggressive as it
should be in ensuring independent management oversight of contracts.
Also, one project officer issues delivery orders for time periods rather
than by task. These orders should be issued separately for each task to
promote better contract management and pinpoint accountability.
A shortage of contracting personnel was noted. Only one contract
specialist is assigned for all of Region V's non-Superfund procurements.
This is not currently a problem, but could become an issue if GLNPO's
contracts workload increases.
Recommendations
Minor changes should be made in GLNPO's contracts management.
The Region V contracts officer should be more aggressive in its independent
management oversight of contracts. In addition, delivery orders should be
issued separately for each task to promote better contract management
and pinpoint accountability. Also, should GLNPO's contracts workload
increase, serious thought should be given to funding a position for an
additional Region V contracts specialist dedicated to GLNPO procurements
and contract management.
FINANCIAL MANAGEMENT
Findings
Within Region V, audit resolution actions are not being completed
within the required time frames, and procedures are not in place to ensure
that corrective actions have actually been completed. These findings are
not directly related to any GLNPO audits in process, but rather to the
overall audit resolution process by which any audit reports, including any
GLNPO audit reports, will be resolved.
In addition, the Region V Financial Management Branch has not
established a comprehensive training plan to ensure that, in the absence
of key employees, critical operations continue without interruption.
Recommendations
Several changes should be made in Region V's financial
management operations which provide support to GLNPO. To ensure
that audit resolution actions are completed on schedule, Region V needs
to make audit resolution a higher priority, and to the extent possible,
assign additional resources to this area. The Region V Financial
Management Branch is now taking steps to implement a quality assurance
review process which will monitor the implementation and success of
corrective actions taken in response to audits.
To make certain that in the absence of key employees critical
operations continue without interruption, the Region V Financial
Management Branch should cross-train staff and assign back-up personnel.
A Review of EPA's Great Lakes Program 47
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MANAGEMENT INTEGRITY
Findings
GLNPO and Region V have made improvements in their internal
controls program since the 1989 OARM management review. Both
GLNPO and Region V have committed additional staff resources to the
internal control functions, allowing for more comprehensive oversight
and day-to-day management of the program at the staff level.
One area where improvements can be made, however, was the
timing and level of participation of Region V and GLNPO senior managers
in the internal controls process. Although these managers are certainly
familiar with the Federal Managers' Financial Integrity Act (FMFIA)
program and process, at the time of the review, the senior management
team was minimally involved in preparing the Fiscal Year 1990 annual
assurance letter required under FMFIA.
For example, the decision to submit separate assurance letters for
GLNPO and Region V in Fiscal Year 1990 was made without input from
the GLNPO Director, the Great Lakes NPM, or the Region V DRA.
Although these officials were later briefed on the internal control issues
for GLNPO and Region V and concurred with those recommendations,
their active involvement early in the process is critical to assure that
senior management's concerns and priorities are reflected in the Agency's
annual FMFIA assurance letter.
Recommendations
GLNPO and Region V staff should continue their present efforts
to strengthen the internal controls documentation and process. These
efforts should include obtaining the personal involvement of GLNPO
and Region V senior managers early in the process of identifying,
declaring, and correcting Agency-level and matericil weaknesses.
In addition, Region V should strengthen its audit management
process to ensure more timely resolution of and follow up to audits. A
verification program should be established to ensure that corrective actions
are taken as reported, and that these actions indeed eliminate the
weaknesses identified in the audit.
INFORMATION RESOURCES MANAGEMENT
Findings
Region V's Planning and Management Division has continued to
effectively deliver basic information resources management services to
GLNPO. While GLNPO has a significant need to use the Geographic
Information System as a means of integrating and presenting large quan-
tities of data, it is receiving limited support from the Region V Geo-
graphic Information Systems program.
The GLNPO and Region V Geographic Information Systems
program faces a significant challenge in meeting GLNPO's special data
integration needs. This effort requires the integration of information
48 A Review of EPA's Great Lakes Program
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obtained from multiple sources—three EPA Regional Offices, eight States,
other Federal agencies and Canada. In addition, no model organization
exists in EPA that has successfully integrated data on this scale.
Recommendations
Regarding Geographic Information System support to GLNPO,
Region V and GLNPO senior management should review Region V's
support priorities and resource allocations. If possible, Geographic
Information System support to GLNPO should be increased.
To better meet GLNPO's special data integration needs, Region V
should develop a data integration plan for senior management review.
Region V should consider establishing an inter-divisional task force or
working group for assistance in developing the plan. Since the Geographic
Information System program is managed by the Environmental Services
Division and other information resources management services are
provided by the Planning and Management Division, the task force should
report directly to the DRA. This task force should seek consultation and
assistance from Headquarters (e.g., Office of Information Resources
Management, the Office of Modeling, Monitoring Systems, and Quality
Assurance which implements the Environmental Monitoring and
Assessment Program), other EPA Regional Offices, and the States.
CURRENT AGENCY ACTION
In recent months, new leadership within GLNPO and Region V
has taken important steps toward redirecting the administrative
management of GLNPO activities. The GLNPO Director and DRA for
Region V have demonstrated their awareness of the management issues
facing GLNPO and a willingness to share responsibility for resolving those
issues; they recognize the need for increased dialogue and coordination at
both the senior management and staff levels as well as the need to apply
state of the art management concepts, including Total Quality Management
principles, to resolve these concerns.
Senior GLNPO, Region V, and Agency management also are
currently assessing the best way to modify their existing systems and
processes to improve the GLNPO's administrative management in a
number of areas.
Example: Senior Agency managers currently are reexamining the
procedures for budget formulation and allocation relative to
GLNPO. This analysis will be competed in March, 1991.
Example: GLNPO is in the process of establishing a Great Lakes
liaison officer at Headquarters to facilitate coordination between
and among GLNPO, EPA Headquarters offices, and other Great
Lakes-related organizations.
These changes, coupled with the progress noted since OARM's
1989 management review, are highly promising for the continued
improvement of GLNPO's administrative management. It is expected
that GLNPO and Region V will address these management concerns raised
in the review with enthusiasm and vigor.
A Review of EPA's Great Lakes Program 49
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APPENDIX
STUDIES AND REVIEWS
OF EPA'S EFFORTS ON THE GREAT LAKES
EPA Inspector General, Audit Report No. E1H1F8-05-9100474, "Great Lakes
National Program Office Grants Program," September 12,1989.
EPA Management and Organization Division, "Management and
Organization Review of the Great Lakes National Program Office,"
February, 1986.
EPA Office of Administration and Resources Management, "Review of
Region V, Great Lakes National Program Office," April 24-27,1989.
EPA Office of Administration and Resources Management, "Special
Management Review: Great Lakes National Program Office," October
24-26,1990.
National Wildlife Federation, "Promises to Keep," June 14,1989.
U.S. General Accounting Office, GAO-RCED-90-197, "Improved
Coordination Needed in Great Lakes Cleanup," September, 1990.
U.S. General Accounting Office, GAO-RCED-88-164, "Efforts to Clean up
Michigan's Rouge River," August, 1988.
US. General Accounting Office, GAO-CED-82-63, "A More Comprehensive
Approach is Needed to Clean up the Great Lakes," May, 1982.
A Review of EPA's Great Lakes Program 51
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AGENCY REVIEW TEAM
The Program Evaluation Division in the Office of Policy, Planning
and Evaluation was responsible for coordinating the overall review,
preparing the report, and conducting the review of the Agency's Great
Lakes program management. Betty Walter served as Project Manager,
while Irv Auerbach provided management support. Granville Sewell,
Pamela Harris, and Pam Herman served as team analysts. Paula Hawkins
provided administrative support.
The Office of Marine and Estuarine Protection in the Office of
Water prepared the chapter of the report on the Agency's environmental
accomplishments and the challenges remaining. Mary Lou Soscia and
Leanne Stahl prepared the chapter.
The Office of Administration and Resources Management was
responsible for undertaking a separate review of GLNPO's administrative
management. The results from this review serve as the basis for the
findings and recommendations on GLNPO's management covered in this
report. Willis Greenstreet and John Sandy served as Team Leaders. Team
analysts included: Leslie Baldwin, German Guajardo, Karen Holt, Pam
Hurt, Debbie Ingram, Ron Kovach, Scott McMoran, Harvey Pippen, Kathy
Sedlak-O'Brien, and Jack Sweeney.
The Program Evaluation Division would like to extend its
appreciation to a number of people who were particularly helpful in this
review: Dale Bryson, Director, Region V Water Division; and Mary
Setnicar, Chief, Environmental Planning Staff, GLNPO.
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