The authors of this report wish to express our  sincere  appreciation

to the nearly 100 persons who have provided written  and/or oral  comments

upon which this study is constructed!
                                       A-..-.IGD 5, Library (5PL-16)
                                       gaE S. Dearborn Street, Eooo 157U
                                              , IL   60604

                         Table of Contents
Summary [[[ 2
R ecommendations [[[ J
Introduction [[[ ^
Scope of Problems .................................................. IS
Present IJC Surveillance Plan ...................................... 16
Lake Erie Surveillance Plan ........................................ 21
1978 Water Quality Agreement ....................................... 22
1978 New Directions ................................................ 24
Analysis of 1975 Surveillance Plan Problems ............. • .......... 25
Federal State Water Quality Surveillance and
  Related Research Activities on the Great Lakes ................... 28



     This review was undertaken at the request of Thomas C.  Jorling,

Assistant Administrator for Water and Waste Management of EPA.   A

similar study has been undertaken by the Canadian Government.

     The review largely focuses on the surveillance and monitoring

programs on the Great Lakes and especially as these activities  relate

to the U.S./Canadian Great Lakes Agreement and Region V of EPA.

     The multi-million dollar a year program presently concentrates on

a large number of open lake and near shore monitoring stations,  for one

lake a year and for a limited number of conventional pollutant  parameters.

     Long term open lake trends and early warning for toxics are presently

provided by the Fish and Wildlife Services of both nations.   One has to

only read the 1977 and especially the 1978 Water Quality Board  (I.J.C.)

report to see that biological monitoring is emphasized for open lake

trends and that very little of the present 5.P.A. open and nearshore lakes

information is utilized, even under present circumstances.

     In view of the new US/Canadian Agreement, requirements of  U.S. Laws

and the EPA Agency Guidance for 1980/81, recommendations are presented

herein for major changes.  Compliance monitoring programs of lake shore and

tributary point and non-point discharges, primarily through the States,

should be emphasized for toxics.

     There is a basic constraint for all such programs, limited to the

few skilled laboratory personnel available for priority toxic analyses.


                         ' RECOMMENDATIONS

     Present U.S. water quality surveillance efforts on the Great Lakes were

designed to meet the priorities o£ the 1972 Agreement.  However, the 1978

Agreement has re-focused the priorities and basic thrust of water quality

surveillance.  The new thrust is concerned with compliance monitoring and

toxic pollutant control.  Toxics introduced into the Great Lakes' ecosystem

are ubiquitous, persistent and pervasive.  If one doesn't prevent and/or

clean-up these pollutants, then the long term trends are predictable.

     Thus, the Canadian and U.S. Governments have each undertaken independent

reviews of the water quality surveillance and related research activities on

the Great Lakes,  Recommendations included in this report are based upon the

U.S. activities.  They reflect the new Agreement requirements for changes

in emphasis.  These recommendations are designed to help meet the requirements

of the Agreements as well as meet the requirements of U.S. Laws!

     These recommendations can serve to realize the •maximum benefit from all

resources applied to the lakes water quality surveillance effort and require

the development of a new comprehensive surveillance plan.  Concern for com-

pliance monitoring, water quality objective violations, trend monitoring and

anticipation of emerging problems in the new agreement shift the 1972 Agree-

ment's concern for nutrient control and add new dimensions for protection,

enhancement and maintenance of water quality with respect to toxics.  Complex

mixes of organic and inorganic chemicals are constantly being introduced to

the Great Lakes ecosystem.  Data on species or community responses to such

pollutants represent a common denominator for identification of trend analysis.

Compliance monitoring provides data on the input of pollutants into the Lakes


and should be directed at assisting in_cle_an-up as a first priority.  In

addition, classical monitoring of the identified toxic pollutants needs to

be supplemented by fish and bird tissue assays because:

     o of the large number of chemical species.

     o of the greater capability to detect certain chemicals in

       flesh rather than water.

     o of our inability to monitor continuously for all pollutants

       at all times.

     Compliance monitoring as defined generally by the U.S. EPA refers to

the monitoring of a permitted discharge to determine if the discharges are

in compliance with the National Pollutant Discharge Elimination (NPDES)

permit conditions.  The monitoring is accomplished either by self-monitoring

and reporting by the permitted discharge or by surveillance and analysis of

areas of concern identified by the States or EPA.  The areas of concern should

include significant non-point sources of pollution.

     Recommendations are presented with a two tier approach.  The first tier

deals with those actions which are appropriate to the US/Canadian I.J.C. Water

Quality Board activities, while the second deals with U.S. Federal and State

efforts and resources applied to water quality surveillance activities on

the Lakes.

Tier 1 - Water Quality Board

1.  It is recommended that the Water Quality Board charge the Surveillance

Subcommittee with the development of a new comprehensive Surveillance plan

which reflects the new monitoring focus found in the 1978 Agreement parti-

cularly with respect to its' emphases on compliance and water quality ob-


jective monitoring and for toxics.  The new surveillance plan should be goal
oriented.  Further, that the surveillance sub-committee and plan should
include the following areas:
     o re-structure the membership of the surveillance sub-committee to
       include a balance between users of monitoring data and developers
       of such data including the developers of water quality criteria.
     o identify those groups, governmental units and other organizations
       who will utilize the surveillance information.
     o identify how and where the surveillance information should be
       used for remedial actions.  Establish priorities.
     o establish a method to ensure inputs from data users into the develop-
       ment of the individual surveillance plan, concentrating on compliance
       monitoring and achievement of water quality objectives.
     o continue the present water intake sampling program as an adjunct
       to trend monitoring.
     o establish a common rationale for choice of water column and sediment
       sample sites for open lake trends.  The rationale should be based upon
       a few strategic sites coupled to biological monitoring.
     o establish a program which will provide water quality information
       to data users including the assessors of total loadings  and their
       effects, for the ultimate use of NPDES and other remedial programs.
     o establish a plan that balances data taking with data analysis and
       data use.
     o statistical analytical techniques have to be developed to determine
       the minimum number of samples.


     o establish a consistent ranking of monitoring tasks with each

       individual lake surveillance plan which will permit the most

       efficient utilization of resources, including consideration of

       the Lunitations of available laboratory, analytical and data

       analysis capability.

     o establish the surveillance priorities which reflect those in

       annex 11 of the 1978 Agreement.

2.  It is recommended, that the Surveillance Subcommittee in drafting a

new Comprehensive Surveillance Strategy focus on toxj.c pollutants and:

     o establish common sampling protocols.

     o establish common analytical and test protocols methods.

     o establish analytical capabilities for the routine measurement

       of ambient levels of toxics pollutants in water columns, fish,

       biota and sediments.

     o establish common quality control and quality assurance programs.

     o establish a common data base for easy assess and exchange of water

       quality data by all institutions.

     o establish a mechanism which will actively consider and

       up-date methodologies as new techniques become available.

     o establish joint data analysis and interpretation programs.

     o establish sound data management programs.

3.  It is recommended, given the focus of the new Agreement on compliance

monitoring and concern for meeting the water quality objectives,  that the

Surveillance Subcommittee in developing the individual lake surveillance


     o establish compliance programs for monitoring for major point, non-point

       and tributary compliance in support of enforcement and planning efforts.


       Note that the *PLUARG study suggests  "looking at near-shore areas

       most affected by man's activities" and provides a guide to areas most

       impacted by agriculture.

     o establish joint compliance monitoring schedules especially concen-

       trating on major sources  of pollution for all lakes.

     o identify the remedial actions that should be implemented when water

       quality objectives are exceeded.

     o identify a mechanism that can be used to identify areas to focus

       compliance monitoring attention.

     o provide for a comprehensive review of compliance monitoring data to

       ensure that data are being used by the remedial programs.

     o for open lake long term trend monitoring, use the biological monitor-

       ing programs of the U.S.  and Canadian Fish and Wildlife Services supple-

       mented by strategic location monitoring of water column and sediments.

     o establish a mechanism to  integrate self-monitoring data from the

       NPDES programs for the United States.

     o for those Canadian jursidictions which use limited use  zones, that

       there be a requirement to monitor these closely in order to minimize

       toxic emissions to the Lakes, in accordance with Annex  12 of the

       Agreement which states "the philosophy adopted for control of inputs

       of persistent toxic substances shall  be zero discharge."

4.  It is recommended that a Water Quality Board member task force (1 U.S.

and 1 Canadian) be established with responsibility for reviewing the surveil-

lance plan and providing management direction from the WQB to  the Surveillance

Subcommittee, on a structured basis.

*PLUARG - Planning and Land Use  Activities Reference Group report
          issued by I.J.C.  in 1978.


5.  Both Government's should create an independent review team similar to

that created for this study to seriously review the research activities on

the Great Lakes, because of the limitation of strategic resources (skills

and laboratories) and ascertaining whether or not the projects will result

in information that will lead to enhanced water quality.   A better delineation

of research problems should help some research agencies in the design of

their programs.

Tier 2 - U.S. - EPA - Federal Agencies - States

     It is necessary to coordinate the U.S. Federal and State Agencies

responsible for taking water quality data on the Great Lakes if the

Agreement monitoring priorities are to be met.  The second tier of recom-

mendation deals with this issue.

1.  It is recommended that the emphasis within EPA focus  on re-inforcing

and expanding the present State-EPA compliance monitoring program and that

the open lake water quality monitoring efforts be undertaken by the appropriate

FWS and NOAA laboratories.  Also, that the U.S.G.S. ;and primarily the States

continue to be involved in the tributary monitoring.   The funds presently

used by GLNPO-Region V for support of "research" should be utilized to assist in

support of the State programs.  (There is an EPA-ORD research budget designed

to support research projects.)  This effort will involve:

     o the use of the State-EPA agreement process for implementing much of

       the proposed new plan building on the present State tributary and

       compliance programs.

     o the re-establishment of the Federal Interagency Support Committee

       t£ the U.S. Great Lakes Water Quality 3oard Co-Chairman to coordinate

       and facilitate water quality data collection,  analytical procedures

  and utilization of water quality data for remedial action.   Particular
  attention should be paid to which agencies can provide analytic data
  and flow data.
o establish the requirements of EPA-Region V to carry out effluent standard
  and non-point source compliance monitoring in addition to that carried
  out by the States and in support of Enforcement and the Water Division
  (Planning).   Note that the "EPA Agency Guidance for FY 1980/81 calls
  for expanded S£A Division monitoring of industrial toxics effluents.
o establish a water quality monitoring program for a few selected
  strategic locations (for toxics) on every lake every year to supple-
  ment the Fish Contaminant Program.  The open lakes are relatively
  homogenous and will only show trends over long periods of time.  Several
  strategic locations for water column and sediment monitoring will
  be more useful, than very intensive open lake sampling on a lake every
  nine years, and as a supplement to the biological monitoring program
  of the FWS (Fish Contaminant Program).   The Interagency Agreement between
  Region V and FWS should provide funds now utilized for the present
  open lake program.
o to develop an Interagency Agreement with Fish and Wildlife Service
  (FWS) to conduct open lake water quality surveillance.  This
  effort should be integrated with the F/VS existing fish and wildlife
  monitoring programs.  This will permit the open lake trend monitoring
  and the connecting channels on an annual basis with fewer vessel re-
  sources.  The NOAA Laboratory at Ann Arbor should also be given consi-
  deration for additional analytical work.
o transfer to FWS  (if they believe these vessels are better than their
  own) or ORD or retire the 4 large vessels now in operation by the


       Great Lakes National Program Office.   Having wet lab space on these

       vessels is of little importance,  since "toxics" have to be analyzed

       by selected shore laboratories!   (Note the ORD is supporting 2 other

       large vessels and that Region II  has  a 28 foot surveillance craft).

     o continue the water intake monitoring  program which also assists in

       trend monitoring.

     o responsibility for coordination  and orchestration of the entire Great

       Lakes monitoring program should  be with Region V, S§A Division.  The

       present GLNPO Surveillance and Research staff should be integrated into

       that Division.

     o The EPA's Office of Research and Development's large Lakes Research staff

       at Grosse He is in the best position to assist Region V in data analysis

       and management.   The 65 people at Grosse lie are in better position to

       provide services for data analysis, interpretation and report preparation

       than the Region V GLNPO staff.  Remedial action recommendations can be

       augmented and coordinated within EPA  for appropriate enforcement action.

       Grosse lie staff presently support the enforcement programs of Region V!

2.  It is recommended that the State monitoring programs on the Great Lakes

be supported via a defined funding mechanism, and that Compliance monitoring

and tributary monitoring be carried out  by the State.   This can be achieved


     o providing an assured source of funding via State-EPA agreements.

     o integrating the NPDES self-monitoring data analysis into the

       compliance monitoring effort.

     o integrating at the State-EPA level the air quality monitoring data

       as it affects water quality.  This should be implemented by the

       Regional S§A Division and by the  States.


     o improving the toxic chemical analytical capabilities of the States
       as called for in the FY 1980/81 EPA Agency Guidance.
3.  It is recommended that a procedure be identified by an EPA-State Task
Force (chaired by Region V and Region II for Lake Ontario) in the individual
lake water quality surveillance plans to establish a prioritized sample site
selection program as called for by by Article VI (m) of the Agreement.
Priority consideration is to assess compliance monitoring with pollution
control requirements.  It will be necessary to:
     o establish a formal procedure for States and EPA to identify
       problem areas.
     o formulate a means for integrating water quality data into the
       remedial programs.  This will require a. close coordination with
       the U.S. EPA Regional Water Divisions, Enforcement Division and
       the appropriate State authorities.
4.  It is recommended that the EPA Regions II, III and V and States first
task be to determine existing laboratory capabilities to measure the water
quality objectives in the Agreement.  The complexities of measuring the
organic and inorganic pollutants at the levels identified in the Agreement
and the CWA of 1977 requires analytical procedures far more complex than
those procedures now used to measure the more traditional pollutants.  It
will be very easy to create a large backlog of samples.  Kence, in order to
maximize the sample collection, analytic procedures and data analysis,  it
will be necessary to:
     o identify the laboratories within EPA, NOAA and FtfS, States, and
       universities which are equipped and staffed to perform the complex
       analytical procedures that meet the requirements of the Regional
       quality assurance program.


     o inventory the present workload of the identified laboratories and

       determine what additional work loads could be imposed.

     o define the maximum number of sites which can be sampled given the

       laboratory constraints.

     o develop the individual Lake monitoring plans given the monitoring/

       analytical realities.

5.  It is recommended that common test analytical procedures be established

since the new methods are complex and consistent interpretation of results

requires common test results.  It will be necessary to:

     o establish round-robbin analytical test protocols.

     o establish coordinated analytical procedures between Agencies

       and States.

     o establish procedures for the evaluation of new test methods.

6.  It is recommended that responsibility for management direction of

EPA in these matters reside in the Deputy Administrator or at least with

the Director of the Surveillance and Analysis Division of Region V.

7.  It is recommended that the Great Lakes research'program involve Regional

personnel in its planning and implementation similar to the overall ORD

effort in EPA.  This will include:

     o the present ORD "Research Committee Planning System" expansion

       to include a module on "Great Lakes Research" with a co-chairman

       from Region V.

     o the energy related program at Argonne National Laboratory funded

       by EPA.

     o setting of priorities.


     At the October 1978 meeting of the Water Quality Board of the Inter-
national Joint Commission (IJC), the United States Environmental Protection
Agency and the Department of the Environment of Canada announced that each
would undertake a separate and independent review of the water quality sur-
veillance activities of their respective countries on the Great Lakes.  They
agreed further that the review of the surveillance efforts and plans would
be undertaken by individuals not previously involved with the joint US/
Canadian Great Lakes water quality surveillance and monitoring planning
efforts.  The review is to ensure that maximum benefit is derived from all
resources applied to the taking of water quality data on the Lakes.  The
ultimate objective is the "restoration and enhancement" of the Lakes' water

     Water quality data gathering programs are broadly interpreted in this
study.  Both surveillance and related research activities were considered
in this study on the Great Lakes since data leading to the understanding of
biological, physical and chemical processes ongoing in the Lakes as specified
in the Agreement derives from both types of activities.  There is an inter-
dependence of resources between surveillance and research as well as some
redundancy.  State activities and compliance monitoring was included in the
cataloging of water quality surveillance activities on the Lakes.  The report
presents a picture of the "Federal-State" involvement in monitoring and
research on the Lakes necessary for the enhancement and maintenance of lake
water quality.  U.S. agency programs are described but not critically evaluated.
The  concerns here focus more on how programs could make better use of resources,


The self monitoring program under the National Pollutant Discharge Elimination

System (NPDES) was not evaluated in this study.  Information from that program

will be increasingly utilized as concern focuses on "toxics" monitoring.

     Federal Agencies and States and a number of individuals were contacted

to better understand the various complex programs underway.  These people

were very generous with their time and provided the data, much information

and suggested many of the recommendations contained within this report.

A preliminary draft document describing the activities and missions of

the various groups engaged in surveillance and water quality research was

completed in February 1979, and circulated for comment to ensure accuracy.

Numerous suggestions and additions were made.  These ideas were incorporated

and are greatfully acknowledged.  It is obvious that there is a complex and

interrelated effort now ongoing and supported by the dedication of those

involved in the surveillance and related research activities.I/

_!/ One issue raised during the review of the initial document was that
research activities on the Great Lakes related to water quality data and
information is separate from and should not be considered in the review
of the activities relating to surveillance and monitoring on the Great
Lakes.  One of the major reasons for including these activities, is that
research vessels can and are being used for collection of water quality
data for the purpose of background information and for the more conven-
tional surveillance activities.  The resources for research and surveillance
in this area can be interchangeable.  Indeed within EPA, the normal Region V
surveillance vessels piggyback research activities and the EPA-ORD research
vessels support some other Regional work -- as it should be under present
arrangements.  A minority of researchers viewed this review with some
hostility while others thought it was time for someone to pull these ac-
tivities together!

     It should be also noted that the EPA-ORD program should be developed
in closer cooperation with operating programs needs and that within EPA-ORD
there are two different Great Lakes research activities which need closer
integration with themselves and with the rest of E.P.A..  Sources of funding
for Argonne Lab Great Lakes Research as examples, are funded through two
EPA sources without coordination.


                        •• Scope of Problem

     Eighty percent of the fresh surface water supply in North America is

contained in the Great Lakes.  These Lakes provide 45 million people in

the basin with drinking, agricultural and industrial process water.   As a

consequence, this unique and priceless resource is basic to both the United

States and Canada.  The Canadian and U.S. governments signed the Great

Lakes Water Quality Agreement in 1972 and entered into a new Agreement in

1978 in recognition of the iunportance of this resource.

     A Great Lakes Water Quality Board under the IJC was established and

mandated to be the Conmission's "principal advisor" in the implementation

of the Agreement.  The Commission is to collect, analyze and disseminate

information relating to the water quality of the Great Lakes, and to

tender appropriate advice and recommendations to the governments.  Recog-

nizing the need for a uniform surveillance effort as required by the 1972

Agreement, the IJC directed the WQB to develop an international surveillance

effort directed by the U.S. and Canada as required by the Agreement  in

Article VI, (c).  In addition, there are large scale fish contaminant studies

being conducted under programs coordinated by the Great Lakes Fishery


     The persons who have developed and are implementing the present plan

are to be complemented for their work to date.   Any critique within  this

study is based on changing environmental perspectives, and an approach of

trying to ascertain who, how, and can the water quality monitoring data be


     An important and fundamental transition took place in the monitoring


philosophy since the revision of the 1972 Agreement, with the re-orientation

to toxic pollutants and with the addition of many new water quality objectives,

There will be complex analytical problems associated with monitoring of

toxic pollutants and the need for stressing a quality assurance quality

control program because of this new thrust.  Consideration of non-point

sources to lake pollutants loadings will also impose significant monitoring

burdens.  Hence, a prioritization of efforts is required since there are

finite resources available to meet the new task of the 1978 Agreement,   As

one commentator noted, while "trend monitoring sounds good" such activities

must be defined so that "trend stations" will not proliferate beyond avail-

able resources.

     It must be noted that there is a critical constraint with respect to the

availability of the sophisticated analytical laboratory skills that are avail-

able.  This implies competition for these scarce resources between the needs

for water quality data, monitoring programs and research programs.

     The 1978 Agreement clearly states priorities for surveillance and will

provide the basis for a number of the recommendations for re-orientation of

present efforts.  These priorities were also discussed at the Water Quality

Board February 1979 meeting.

                    Present IJC Surveillance Plan

     Based upon the 1972 Agreement, a surveillance plan was established in

1975 by the Surveillance Subcommittee of the Water Quality Board, providing

for the collection of information which would lead to the establishment of

efficient and economical programs for pollution abatement and preservation


efficient and economical "programs for pollution abatement and preservation

of water quality.  A series of general surveillance tasks were identified

by the Surveillance Subcommittee in the development of the plan.   In general,

the Identified surveillance tasks were:

     o Objective violations:  violations of the water quality objectives

                              (criteria) of the Agreement.

     o Trends:  determine compliance with non-degradation and long-term

                effects of remedial programs.

     o Cause and effects:   describe and quantify loads and water quality


     Having identified the specific tasks, the Surveillance Plan presented

the operational components required for implementation of the plan.   It

was recognized that for open lake studies, oceanographic vessels  equipped

with on board laboratories were required,  while in the nearshore  areas and

the connecting channels, smaller boats would do monitoring work.   The 1975

surveillance plan was based on the premise that the •governments would operate

and maintain two very large vessels (one U.S. and one Canadian) and eight

medium size "lab" boats.  The plan is generally described below with a

critique as to where it was implemented.

     The Surveillance Plan identified as an important aspect in managing

Great Lakes water quality, the determination of the types and quantities

of materials entering the Lakes.  The three operational components identified

to be monitored  were:  tributaries, atmospheric and compliance monitoring.

A strategy laid out to meet the requirements inherent in monitoring inputs

from the three sources included nearshore monitoring.  Since the nearshore


areas are the first to react to changes in point-source and land drainage

pollutant discharges, this area and the tributaries would be the first to

respond to remedial programs.

     Open lake monitoring was judged under the comprehensive surveillance

plan, to be an djnportant component since:

     o materials enter the Lakes from atmospheric fallout and precipitation.

     o the majority of lake water is in the mainlake and provides a

       connection between the nearshore areas.

     o the open lake responses were slow to changes.

     It was recognized in the 1975 surveillance plan that open lake monitoring

is much more difficult and expensive than the nearshore monitoring efforts.

A series of additional monitoring components identified were:  connecting

channels; municipal water intakes; biota; water-sediment analysis for hazard-

ous substances; and fish tissue analysis.

     Tasks identified as critical to the overall success of the surveillance

plan were:

     o Data quality - a coordinated data quality assurance system

                      between agencies was called for.

     o Data management - implementation of a program to ensure analysis

                         and timely reporting.

     o Data reporting - data analysis and reporting were identified as

                        weak points in past efforts.  Therefore, additional

                        resources were requested to bring these areas up

                        to par for the annual assessment -- even at the

                        expense of curtailing data collection.


     Scheduling of open lake monitoring activities was planned as a nine

year cycle based upon maximizing the use of eight vessels (see Table 1).

However, because of the degraded state of Lakes Erie and Ontario, yearly

sampling for enrichment parameters (nutrients, dissolved oxygen,  chlorophyll

and microbiology) was called for.  The connecting channels were to be monitor-

ed annually along with the tributaries.  Nearshore and problem areas were

specified to be sampled on a rotating basis with somewhat increased intensity

of frequency in number of stations and parameter coverage corresponding with

main lake intensive years and the nature of the specific problem.

     Implementation of the Surveillance Plan was to be keyed to resource

allocations.  It was recommended in the plan that rather than eliminate any-

single component, the plan be carried out in total but that the work be

extended over a longer time period; if resources were to be less  than those

envisioned in the development of the 1975 plan.

     Present Great Lakes National Program Office (GLNPO) - Region V monitoring

strategy using four large (Tab 1) vessels is to concentrate open lake

surveillance efforts on one lake at a time and to focus intensive studies

on the nearshore areas of the same lake near where problems exist.  The

open lake studies are presently the foundation of the surveillance program

but a part of the program is concentrated in nearshore areas.   The overall

schedule consists of a nine year cycle with 2 years spent on each lake, ex-

cept Superior and Huron where only one year is dedicated for surveillance

activities.  A year is to be spent studying the connecting channels.  The

nine year cycle is based upon economic utilization of ships and personnel.

     Developraent of surveillance plans for each of the Great Lakes is the

responsibility of the WQB of the IJC under the US/Canadian Agreement.  A

Surveillance Subcommittee of the WQB was established in 1973 and actually

prepared the overall surveillance plan in 1975.  The individual lake plans

are prepared without concern for resource constraints, and are thus idealized

plans as stated in the Lake Erie plan.  Membership of the working groups

preparing the plan varies between lakes but has representatives from the

Canadian Federal government, the Ontario Provincial government, the U.S.  EPA-

(the Regions and GLNPO), the eight Great Lakes States, and the Fish and Wildlife

Service and National Oceanic Atmospheric Administration.   The Lake Erie Sur-

veillance plan has been established and Lake Ontario Surveillance Plan has been

essentially completed.  Lakes Huron, Michigan and Superior surveillance

plans are nearing completion.  All of the individual Lake plans were

scheduled to be completed by April 1979.

     While sampling sites have been chosen for many of the Lakes, there is

flexibility in changing these sites so long as there is an appropriate

rationale and coordination with the Surveillance Subcommittee.   The para-

meters to be covered and objectives are all developed by the Surveillance

Subcommittee.  For example, on Lake Erie the Canadian government chose the

nearshore and tributary sites to be monitored in Canada.   The U.S. provided

a similar site plan for the U.S. waters.  The two plans are then added to-

gether to form a single plan.


                    Lake' 'Erie Surveillance Plan

     To better understand a single lake "plan" the Lake Erie plan is
reviewed,  A two component plan was developed for monitoring Lake Erie.
A total of 28 cruises are planned for Lake Erie over the 2 year intensive
study time.  The cruises are scheduled based upon the seasonal cycles
of the Lake and each cruise is intended to monitor the various conditions
of the Lake in order to develop a basis for comparison in the future.
The first portion involves the tributaries and the second the open lake.
Within each component there is a breakdown of sampling sites and the
general criteria used for site selection.   The priorities of the Lake Erie
plan were modified to include "all of the open lake activities but with
only three days instead of the five originally scheduled for each nearshore
area cruise on the U.S. side."  Emphasis once again is on the open lakes.

     As noted in the 1978 Sixth Annual Report to the IJC, "some parts of the
program that are not fully developed are:  the nearshore fish contaminants
program, additional sampling for radioactivity and atmospheric loads to the
Great Lakes, and sampling of tributaries during heavy runoff periods."  It
should be noted that tributary monitoring is largely a task of the States
and USGS at present.  The sampling of organics did not follow the 1975 plan
because of lack of analytical capability in the central regional laboratory.

     Selection of sample sites in the open lake are based on the stations
chosen by individual researchers who have worked on the Lakes dating back
to 1954 and also by work done by various universities.  The Surveillance
Subcommittee therefore chose stations where previous work had been perfomed

and where a partial baseline of data existed for comparison.   In Lake Erie,
there are 80 stations in the open lake which have been chosen based on
sampling stations used in project "HYPO" in a previous R§D sampling program.
Also the water quality model developed by Manhattan College for the EPA
Laboratory at Grosse lie dictated the choice of sample sites  in additon to
these of the International Field Year and the annual Canadian Programs.

                    1978 Water Quality Agreement

     Monitoring priorities have been structured in the Agreement to be
compatible with the heightened concern for toxic pollutants.   Annex 11
therefore gives first emphasis to compliance monitoring and in achiev-
ing the water quality objectives.  Evaluation of trends and identification
of emerging problems rank as the third and fourth stated priorities.  Given
the Agreements, rank order for monitoring tasks, the need for "reduced"
pollutant discharges and Agency resource constraints, listing of priority
tasks must be formulated which can be accomplished with the available
     "Cleaning-up" the Lakes and therefore compliance monitoring should
be the first order of priority even if the other tasks were not mentioned.
     Annex 11 of the new Agreement was discussed at the February Water
Quality Board meeting and the following order of priorities was enumerated
by the U.S. Co-Chairman:
     o Compliance:  Assessment of the effectiveness of jursidictional control
       for pollution abatement.  If one doesn't clean-up and/or prevent pol-
       lution, then the long term trends are obvious.
     o Achievement of general and specific objectives:  Definition of the
       location, severity, area or volume extent, frequency and duration


       of non-achievement  of the "objectives" as a basis for determining

       the need for more stringent control requirements.

     o ^valuation of wat^^r quality trends:  Provision of data on local and

       whole lake responses to control measures using trend analyses and

       cause/effect relationships and provision of information to assist in

       the development and application of predictive techniques for assessing

       new developments and pollution sources.  Results of these evalua-

       tions will:

       (i) allow for the assessment of remedial programs and identify

           improved pollution control requirements.

       (ii) allow for the assessment of enforcement and management


       (iii) identify the need for future technology and research


     o Identification of emerging problems:   To determine undetected

       problems in the Great Lakes for implementation of appropriate

       control measures.

     Future programs which should address these four priority considera-

tions are to include baseline data collection, sample analysis, evaluation

and quaility assurance programs (including standard sampling and analytical

methodology, inter-laboratory comparisons, and compatible data management)

to allow assessments of:

     o inputs from tributaries, pointsource discharges, non-point source

       discharges, atmospheric depositon and connecting channel quality;

     o whole lake data for nearshoreshore areas (e.g. harbors and embayments,


       general shoreline, cladphora growth areas) and open waters of the
       lake, fish and wildlife contaminants;
     o outflows including connecting channels, water intakes and oulets;

                        1978 New Directions

     A major shift in emphasis since the 1972 Agreement from an emphasis
on conventional pollutant parameters and eutrophication problems to a
concern for toxic pollutants in the Great Lakes has occured.  This new
focus of the 1978 Agreement is found in:
     Article IV (1) (b); (l)(c)
     Article VI (1)(e), (l)(e); CD(m), (1)(e)(viii)
     Annex 11
     Annex 12, item (4)(a)(d)

     Briefly these Articles and Annexes deal with an increase in specific
water quality objectives from 8 to 41 toxic pollutants *(1); routes of entry
to the lakes including atmospheric loading of toxic'pollutants; establishment
of an early warning system, i.e. fish contaminant study for toxic pollutants;
and tributary loading of phosphorus.

     Toxic pollutants are of major significance, of far more concern than
conventional pollutants, because of human health significance and because
they are ubiquitous, pervasive, and persistent.

     Activities specified in Annex 11 related to the new toxic focus place
additional surveillance responsibilities on the parties and include:
     o Sampling and analytical methods development, statistical analysis,
*(1) EPA is focusing on 65 families and specific toxic pollutants for
     remedial action.  Also, on the basis of a recent study of structure -
     activity correlations, there may be a number of other toxic pollutants
     of concern in the Great Lakes Basin.

       quality control and data management because of many new water

       quality objectives.

     o Expanded atmospheric chemistry program.

     o Improved contaminants data for wildlife and fish (early warning).

     o Enhanced tributary monitoring.

     Concern for toxic pollutants in the Agreement is parallel with the

regulatory efforts and priorities of the U.S.  Clean Water Act (OVA).

The list of hazardous pollutants in appendices 1 and 2 of the Agreement

is equivalent to the OTA, hazardous pollutant list and the water quality

objectives of the Agreement are similar in composition to the toxic

pollutant list of the OVA and the Agency water quality criteria covered

under and published in the Quality Criteria for Water.  However, the

number of pollutants in the Agreement is less than that in the CWA.

         Analysis of 1975 Surveillance Plan Problem Areas

     In the context of the new Agreement, the 1975 surveillance plan serves

useful experience to build upon.  While the 1975 plan expresses concern for

data management, there are no specifics given as to how the monitoring program

can or should be tied into lake water quality management programs.

     There is no guide to the relationships between the publication of data

and the needs of the users, nor are the potential users identified.  Who

is going to use the information?  Can the data be used?  How are the data


     o In the 1975 plan, emphasis was not placed on compliance monitoring

       and achieving general and specific objectives.

     o There was no development of uniform protocols for data collection


       and analysis.

     o There was no strategy to maximize and coordinate use of all Federal

       and State resources now applied to the lakes to achieve the eval-

       uation o£ water quality trends and identification of emerging


     o A quality assurance program for monitoring of toxic pollutants

       was not material.

     o Biological monitoring and open lake studies plan which was con-

       sistent between the US and Canada was not presently included.

     o Balance of resources between water quality data analysis and

       planning and sampling of water quality data leaves much to be


     o The identification and close integration, of the various program

       needs such as the regional planning requirements of the CWA

       surveillance and analysis, enforcement, EPA-ORD and the GLNPO

       was not done.

     In addressing the specific program areas the comprehensive surveillance

plan would provide a framework within which the specific lake surveillance

plans can begin to address the areas defined in the Agreement.

     Since the Lake Erie surveillance plan is the most currently adopted

plan now being implemented, this plan can serve as a useful example of

problems.  Specific comments on the Lake Erie plan are as follows:

     o With regard to the format, there is no apparent integration of

       efforts but rather there seems to be several nearly independent

       activities.  This gives the appearance of a lack of coordination.

       For example, the surveillance plan lists component parts without


  relating the parts to a whole objective for lake improvement and


o Several components appear to be either missijng or subsumed.   There

  appears to be a massive data collection and in-the-field program

  while the objectives for both types of projects are not measurable

  (i.e. how does one define "refinement of knowledge" or "better

  understanding of).  There is a suggestion that data will be used

  eventually to develop a management scheme but there is no tangible

  means indicated as to how this goal will be achieved.

o There should be a scheme spelled out that will allow lake water

  quality management which is the objective of the plan.  Such a

  scheme must include compliance activities.  Data collection must

  be related to specific ends.  Hence the "needs" for data must be

  defined.  Who is going to use the information?  How is it to be used?

o Time and problem identification is the stated principle for near-

  shore sampling but the sampling frequency does not follow these

  principles in order to achieve measurable results.  Also there

  appears to be no integration between point and non-point sources

  with the in-lake program.  Only a portion of the materials balance

  is included in the study.

o There is no explanation of the "product" which will result from

  any of the studies.  If one assumes that the results will be

  published as an IJC surveillance report how will this report

  translate into a "management scheme?"

o Finally there ought be in one place in the plan all resources of

  all the cooperating institutions/organizations in one table under

  specific objectives.  Such format would allow for a ranking of

  objectives and deciding resource allocations.


        Federal-State Water Quality Surveillance and Related
              Kesearcn Activities on the breat Lakes

     Protection and management of the Great Lakes is vested in many

Federal Agencies and institutions.  There are few historical data bases

from which management schemes are developed.  These exist almost no-

where for large bodies of water.  Programs on the Great Lakes, such as

the National Oceanic and Atmospheric Administration (NCAA) or the Fish

and Wildlife Service (FWS) have specific charges and program priorities

which are related to the sponsoring Agencies mission and responsibilities

but which are also totally related to water quality and to resource

management and environmental services.  There is no attempt to correlate

or integrate this data with the present EPA Great Lakes Agreement monitoring


     Several agencies and at least two components of EPA are sponsoring

water quality sampling and data analysis through the use of large research

vessels.  A list of the larger of these vessels is found in tab 1.  In

addition, there are a number of laboratories using increasingly sophisticated

equipment, that operate in support of the data collection program but with

no agreed upon quality assurance program.

     Since there are limitations on the amount of skilled manpower available

in all of these activities, it is prudent to at least inventory these re-

sources  (both in operating programs and in research) in order to assess

whether  or not these available resources can be used more efficiently in

support  of the various programs and the objective for "cleaning-up" the



     The review process how being undertaken is to establish where the
research program priorities can be meshed with the surveillance activities
on the Great Lakes for maximum utilization of resources, keeping in mind
the various missions and requirements of the various Federal research
programs.  What follows is a description of the various research efforts
in the Federal establishment.

                        EPA - GLNPO Activities
Specific GLNPO Great Lakes research and surveillance activities include:
     o Open lake monitoring program for eutrophication and toxic substances
       and longterm trends largely dependent upon chemical analyses of a. few
       selected parameters.
     o Nearshore monitoring program for eutrophication and toxic
     o Supplementary tributary monitoring to determine annual
       loadings to lakes.
     o Atmospheric loadings - transfer of materials'from air to

     A nine year  (one lake at a time) monitoring cycle was established to determine
long term trends in the lakes and provide input for management decisions.  This
objective is accomplished by a 165 ft. research and monitoring vessel for the
open lake surveys and through grants and contracts for nearshore monitoring using
other large EPA vessels.  Supplementary event monitoring to provide accurate
loading estimates through grants and contracts is also utilized,

     GLNPO provides Ad Hoc support to the Enforcement Division as required on
special cases.


     It should be noted that Region II has it's own 28 foot vessel for compliance

monitoring purposes on Lake Ontario.


Specific ORD Great Lake research efforts involve:

     o Eutrophication and its effects.

     o Problems associated with power production on the biology

       of the lakes.

     o Hazardous maaterial sources, fate and effects.

     o Disposal of dredging spoils, ecological effects on wetlands

       of shoreline construction and hydrologic modification.

     A five year reserach plan has been developed by ORD to address these

issues and encompasses the broad areas outilined above.   In addition

to these program objectives, ORD provides ad hoc support to the Enforcement

and Surveillance and Analysis Divisions of Region V in the form of special

environmental studies, expert witnesses and in-review and development of

scientific support documentary.

DEPARTMENT OF INTERIOR - Fish and Wildlife Service

     Assessment of fisheries resources, trends and biomass in the Great Lakes

is the prinary mission of the Fish and Wildlife Service (FWS).   This objective

is accomplished by the Great Lakes Fisheries Laboratory, in Ann Arbor,  Michigan

which has 5 boats ranging in size of 47 feet to 75 feet.  Each of the Lakes

is surveyed intensively with from 11 to 12 cruises per season from April to

December depending on the Lake.

     The primary mission of the FWS is to fulfill the objectives of resource


raanagement in the Lakes but it is currently collecting fish samples for

EPA for pollution trend analysis in the fish tissues.  While the FWS vessels

are equipped for fisheries  activities and the scheduling of vessel operations

is full, the boats can be equipped to conduct routine liminological survey

work and the scheduling may be flexible enough to accommodate EPA sampling

requirements and the EPA sample site selection.

     Additional FWS investigations on the Great Lakes are conducted by the

Regional office in Minneapolis and include pesticide monitoring (PCS, DDT,

etc.) and effects of dredged material disposal in the Lakes.  The investi-

gations now underway or planned on the Lakes include:

     o Wetland damage area surveys

     o Development of a. fish atlas

     o Migratory bird habits

     o Development of an oil spill contengency plan

     o Fish census of the Duluth/Superior area

     o Various benthic studies

     Both the Corps of Engineers and the FWS are developing under a

cooperative agreement an environmental study plan to determine the effects

of winter navigation on the Great Lakes.  The development of the Environmental

Plan of Action is to be completed early in 1979.  It is anticipated that

the funding for the whole Great Lakes plan will require approximately $100

to $150 million dollars over 20 years.  Funding has not yet been obtained

for this program.



     Presently, the U.S.G.S. operates gaging and water quality surveillance

stations in 69 per cent of the Great Lakes drainage area.   Data collected

at these sites include, in addition to water flow information, physical

parameters as well as suspended sediment concentrations, metals, pesticides

and organic materials sorbed onto the sediment.  These data are included in

the STORE! water quality data file.  The U.S.G.S. data collection system

is operated in conjunction with State and Federal programs.  Federal agencies

using the U.S.G.S. service include EPA, FWS, DOE, the Forest Service and the

Naval Facility Engineering Command.

     Data collection frequency and parameter numbers vary with each of the

stations.  A compilation of the station sites, parameters surveyed and fre-

quency can be found in the U.S.G.S. publications Regional Plan for Federal

Water-Data Acquisition, Fiscal Year 1978 - 1979, (Appendix 3- Quality of

Surface Water Stations, US/DOI Office of Water Data Coordination.

     There are no large boats operated by the USGS on any of the Great Lakes.

However, two 19 foot boats are used for water quality data collection in

the connecting channels between Lakes Erie and Ontario.  No open-lake is



     NOAA's primary mission on the Great Lakes is to conduct research to

understand the processes of the lake-land-atmosphere system sufficiently

to build useful numerical predictive and simulation models of physical

phenomena and the ecosystem; and to assist in solving problems in resource


management and environmental services.  The laboratory responsible for this

effort is in Ann Arbor, Michigan and has four groups involved in the overall

mission.  There are 49 full time positions allocated to the laboratory.  The

Great Lakes Research Program is organized into 3 management activities as


     o Physical phenomenon:  to improve data, statistical description, under

       standing and methods of prediction of physical variables, processes,

       phenomenon that are hazards and relate to ecosystem dynamics such

       as currents., temperatures, waves, storms, ice, lake levels, river

       flows and interdependent atmospheric variables.

     o Lake Ecosystem Dynamic:  to improve understanding of existing

       lake ecosystem conditions, recognition of trends and develop

       the capacity to predict the future course of events given al-

       ternative approach to management of material movement, aquatic

       ecology models and planktonic succession.

     o Environmental Engineering Tool and Services: • to develop, improve

       useful engineering models, statistical description and environment

       maps, and conducts system studies to support users needs for

       information and to provide an enclosed advisory service.

     Research is conducted on all the Great Lakes, although some studies

have concentrated in particular lakes.  A 65 foot converted "T-boat" is

operated by NOAA along with two 21 foot boats.  These vessels are used to

support physical, chemistry and biology field studies.  Physical liminology

research studies underway for Lake Erie include currents, wind waves and

storm surges.  The current studies are partially funded by EPA-GLNPO.



     Current NASA programs on the Great Lakes involve two major activities:

modeling and field work.  The basic mission of the programs is to develop

a remote sensing activity that will be able to monitor a parameter in water.

Equipment available to accomplish this mission are two aircraft with scanners.

These aircraft collect the ice cover and thermal data on the lakes.  The

satellite program using LANDSAT and the Nimbus G are developing methods for

measurement of chlorophyl and sediment data in the lakes.  There is an inter-

agency work group that shares the information and includes EPA.  The satellite

studies have aided in the PLUARG report.  Some EPA vessel time is paid for

by NASA and some NASA work is paid for by EPA/ORD funds.


     Great Lakes research conducted by the Department of Energy is funded

by pass-through dollars from the EPA/ORD to the Argonne National Labora-

tories (ANL).   The total expenditure from EPA to the ANL is approximately

$1.2 million per year.  This involves research efforts predominately on

Lake Michigan and makes use of a new research vessel Ekos, a 56 foot vessel

conmissioned in October 1978.  The mission of the ANL vessel is to obtain

water, sediment and air samples to help identify transport mechanisms  of

energy related toxic pollutants (e.g. heavy metals)  into and within the

Great Lakes.

     The objectives of the ANL biological research effort are to:

     o describe biological processes and fate of pollutants.

     o determine effects of pollutants on the lake biota.

     o identify long-term changes in the trends of the biota.


     o develop numerical 'models to predict pollutant pathways,

       timescales and suspension in the lakes.

     o determine the bio-geochemical processes which govern the

       bio-availability of transuranic elements in the Great Lakes.

     Effects of chemical pollution are also the subject of the ANL water

quality data collection efforts.  Sources of pollution input to the Great

Lakes are being studied.


     As noted above, the COE is coordinating a major research planning effort

with the FWS on the Great Lakes.  This effort is to produce an Environmental

Plan of Action for all the Great Lakes and the St. Lawrence River.  The thrust

of the COE programs are for monitoring dredge and fill activities and the

winter navigation program.  Biological assessment of the winter navigation

program is a task which is being shared with the FWS office located in

Minneapolis under a cooperative agreement.  Also, the COE is working with the

IJC Lakes level board.


     All eight States bordering the Great Lakes have some water quality

surveillance programs.  However, the extent of the efforts vary considerably.

Each State's program is described briefly.  The objectives of the various

State surveillance programs generally are similar, and these are to:

     o assess the effectiveness of the remedial program.

     o monitor drinking water intakes.

     o provide trends analysis by fish tissue monitoring.


     An attempt was made"to provide a budget breakdown for the Great Lakes

State surveillance effort but this was not always possible.  Often the States

have  a total surveillance budget with the Great Lakes effort being a part

of the total.  Where budgets are given they may be approximate (Tab 2).

     State water quality surveillance programs on the Great Lakes are as


New York - A total of $250,000 is budgeted by the State to collect water,

biological and sediment samples.  Fish tissues are surveyed to identify

potential problems.  However, the fish tissue sampling is on a 3 year cycle.

A fishing boat is operated on Lakes Erie and Ontario by the State in con-

junction with the 3 year fish collection program.

Pennsylvania - A total of between $10,000 to $12,000 is budgeted by the State

for tributary and drinking water intake monitoring.  A fish tissue analysis

program is also being conducted by the State.  The State does rely upon the

I.J.C. to estimate the compliance with remedial programs!?

Ohio - A budget of approximately $20,000 per year is allocated for tributary

and drinking water intake studies.  A subcontract with the U.S.  Geological

Survey is used for the tributary monitoring program,

Indiana - A total budget of approximately $450,000 is allocated by the State

for compliance, biological and chemical monitoring programs.   There are basic-

ally two programs operated by the States.  Tributary monitoring with a total

of 33 parameters being tested.  The second program is for drinking water

intake studies.  The State operates a 55 foot boat (Norwester) which is used

by the Department of Natural Resources and the State Public Health Department,

There is also a proposal for an independent Lake sampling program which ex-

tends about 5 miles into Lake Michigan.  A fish tissue analysis program is


operated by the State.  Sample site locations are chosen by a grid matrix.

Representatives from the States are involved with the Region V and GLNPO staff.

Michigan - The State has a budget of approximately $500,000 per year allocated

to surveillance programs on the Great Lakes.  About 40 per cent of this effort

is for samples of discharges, with the remainder split among tributaries,

water intakes, studies of nearshore areas and the Detroit River.  A fish

collection program on Lakes Superior, Huron, Michigan and Erie has been under-

taken for fish tissue analysis.  There is coordination between the State, IJC

and the GLNPO.

Illinois - No budget breakdown was possible by the State representatives con-

tacted.  A drinking water intake monitoring program is conducted by the city

of Chicago under a cooperative agreement with the State.  This program is

coordinated with the GLNPO.  A fish tissue analysis is being conducted.

Wisconsin - A budget of approximately $84,000 is allocated by the State for

tributary monitoring, fish collection and tissue and ambient water quality


Minnesota - No budget breakdown for the Lake Superior monitoring program was

given by the representatives.  The object of the program is for compliance

monitoring for the point source control program.


     Private industry is required under the NPDES system to undertake a self

monitoring program.  All permitted industrial and municipal discharges collect

water quality data on their effluents.  The financial burden of collecting

these data are placed on the industries or municipalities and no estimate of

the total expenditures is available.  However, it has been suggested that the

cost involved is in the millions of dollars.  Data from the self monitoring


program is provided to the Regional Enforcement Divisions.

                           Problem Areas

     In discussion with the Regional personnel in the GLNPO - surveillance

staff, Surveillance and Analysis Division, Enforcement Division and thejDffice

of Research and Development, a variety of problems and concerns were made


     Water quality data for the regional planning activities, calculation of

waste load allocations, assessment of the various remedial actions implemented

and identification of water quality problem areas, all require the water quality

data.  However, personnel from the Region are in agreement that a dialogue

between the various offices and the GLNPO is at best minimal.   One of the

underlying points made by Regional personnel was that data should be fed back

into the various programs and that planning of GLNPO surveillance activities

should be coordinated with the Region and between Regions and States.  Again,

regional personnel are in agreement that this exchange does not occur.  The

regional planning agencies do not use the water quality data generated by

the Great Lakes Surveillance programs and a consensus of opinion of the

Regional personnel was that there is a need for priority attention to the

Great Lakes.  However, the belief expressed was that the water quality

surveillance program should place more emphasis on the regional monitoring

needs to determine effectiveness of remedial programs.  Program priorities

are believed not to be given enough consideration with respect to the

monitoring strategy.  Further, it was stated that more attention should be

given to nearshore and tributary water quality data collection.


     Another problem highlighted during discussions with the GLNPO surveillance

staff was the imbalance between resources committed for data analysis and

data collection.   Thus there is a backlog of water quality data to be analyzed

even as new water quality data are collected.  As noted in the 1975 Great Lakes

Surveillance Plan, a priority on data analysis was deemed basic.   Another

significant problem highlighted was a general lack of common test protocols

and procedures between the U.S. and Canada.   While there are some common

test protocols available, sampling procedures and a quality assurance program

between the U.S.  and Canada is now beginning to be discussed.   This is

critical to a good toxic surveillance program for both countries.   Quality

assurance within the GLNPO office does occur but again only on an ad hoc

basis between the U.S. and Canada.

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Tab 2
                   Summary of State and Federal Expenditures

                   for Great Lakes Water Quality Surveillance

                    and Related Research Activities - FY 79
  Dollars Spent
  (in Thousands)
Total Budget
S tates
New York












Total State

Dept. of Interior



     Total USDI









GLNPO                            $3,500

ORD                               2,100

Region V, Air Program               103

Region II                            70

     Total EPA                   $5,773                      5,775

Dept. of Energy                  $1,200                      1,200

Dept. of Commerce

NQAA  (approx.)                   $3,200                      5,200

  Total Federal Budget  (Exclusive                          $14,765

  of Corps of Engineers and U.S.

  Coast Guard)

  Total Budget including States                            $16,136