TD223.3
.ut4                                          OOOR82002
1982   D/ THE COMPTROLLER GENERAL

     Report To The Congress
     OF THE UNITED STATES
     A More Comprehensive Approach Is Needed
     To Clean Up The Great Lakes
     Despite spending millions of dollars on water
     pollution control, the United States isf inding
     it difficult to meet the comprehensive objec-
     tives of its Great Lakes Water Quality Agree-
     ment with Canada. Although the lakes are
     cleaner, the United States  is not fully meet-
     ing its agreement commitments.

     GAO is recommending that the Congress
     and the Environmental Protection  Agency
     Administrator take steps  to improve U.S.
     efforts to clean up the Great Lakes and meet
     water quality agreement commitments.
                                                 CED-82-63

                                                 MAY 21,1982

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                  COMPTROLLER GENERAL OF THE UNITED STATES

                           WASHINGTON D.C. 20648
B-203850
To the President of the Senate  and  the
Speaker of the House of Representatives

     The U.S.-Canadian Great  Lakes  Water  Quality Agreement has
resulted in cleaner water  in  the lakes, but serious pollution
problems remain.  Furthermore,  the  United States is having dif-
ficulty meeting its commitments under the agreement.  This
report discusses ways the  Congress  and the Environmental Protec-
tion Agency can help to meet  U.S. commitments and accomplish
objectives of the water quality agreement.

     In a 1975 report we stated that the United States needed
to make a greater commitment  to support Great Lakes Water
Quality Agreement objectives.   In 1978 the United States and
Canada entered into a new, more comprehensive agreement which
required a substantial commitment by the United States.  We made
this review to determine whether the United States is meeting
the objectives of the water quality agreement.

     We are sending copies of this  report to the Director,
Office of Management and Budget; the Administrator, Environ-
mental Protection Agency;  the Secretaries of State, Agriculture,
and Commerce; interested congressional committees; Members of
Congress; the International Joint Commission; the Governors of
affected States; and other interested parties.
                                 Comptroller  General
                                 of  the United States
                                     U.S. Environmental Protection Agency
                                     GLNPO Library Collection (PL-UJ*
                                     77 West Jackson Boulevard,.
                                     Chicago, IL  60604-3590

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COMPTROLLER GENERAL'S               A MORE COMPREHENSIVE APPROACH
REPORT TO THE CONGRESS              IS NEEDED TO CLEAN UP THE
                                    GREAT LAKES

        DIGEST

        The United States and Canada have an agreement
        to develop and implement programs and other
        measures to protect the water quality of the
        Great Lakes.  The Great Lakes Water Quality
        Agreement has comprehensive objectives to im-
        prove Great Lakes water quality and requires a
        substantial U.S. commitment.  GAO found that,
        although the lakes are cleaner, the United
        States is finding it difficult to meet agree-
        ment commitments and that to do so will
        require greater focus and direction of exist-
        ing efforts.

        U.S. efforts have been hampered by the
        (1) lack of effective overall strategies for
        dealing with Great Lakes water quality prob-
        lems, (2) lack of knowledge about the extent
        of pollution problems and the impact of con-
        trol programs, and (3) need for improved man-
        agement of Great Lakes pollution cleanup
        activities.

        GAO made this review to determine if the
        United States is meeting the objectives of
        the Great Lakes Water Quality Agreement
        because (1) a 1975 GAO report showed the
        United States needed to make a greater com-
        mitment to support water quality agreement
        objectives and (2) the new 1978 agreement
        is very comprehensive and requires a sub-
        stantial United States commitment.

        In the United States, both Federal and State
        agencies are responsible for Great Lakes
        cleanup efforts.  The Department of State
        and the Environmental Protection Agency (EPA)
        are the two Federal agencies most involved
        with the water quality agreement.  GAO's
        review was necessarily confined to U.S.
        Great Lakes water quality efforts.  Canadian
        efforts referred to herein are based on reports
        published primarily by the International Joint
        Commission—the permanent U.S.-Canadian body
        responsible for advising both Governments on
        Great Lakes water pollution matters.
 Tear Sheet                                               CED-82-63
                                                      MAY 21.1982

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MUNICIPAL POLLUTION SOURCES

The agreement goal of December 31,  1982,  for
adequate treatment of all municipal sewage
discharges to the lakes will not be met.   For
example, 31 percent of the municipal discharg-
ers on Lake Erie and 32 percent of those  on
Lake Ontario will not be under control until
sometime after 1982.  Furthermore,  according
to the International Joint Commission, only
64 percent of the sewered population in the
U.S. portion of the Great Lakes Basin was
receiving adequate treatment, compared with
99 percent of the Canadian sewered population.
Reasons cited for not meeting the agreement
goal include unrealistic timetables for con-
structing facilities, problems in obtaining
and using Federal grant funds, and lack of
municipal officials' support for construction
activities.  Budget reductions also could set
back the already extended dates for completing
municipal projects in the Great Lakes Basin.
(See pp. 10 to 13.)

Discharges from combined sewers (sewers that
carry municipal wastewater along with storm
runoff) continue to be a major source of  pol-
lution to the lakes, but little funding has
been directed to controlling these discharges.
Of 51 specific problem areas on the Great
Lakes, 20 had serious combined sewer over-
flows.  Structural solutions to controlling
combined sewer problems are costly—$8 billion
according to one EPA estimate.  But unless
combined sewer overflows are controlled,
existing municipal sewage treatment programs
will not be fully effective. (See pp. 14
and 15.)

PHOSPHORUS CONTROL

Phosphorus contamination—a prime factor  in
lake eutrophication (aging)—is a major prob-
lem facing the Great Lakes, particularly  Lakes
Erie and Ontario.  Phosphorus inputs to the
lakes from municipal treatment plants are
being reduced.  However, about 41 major U.S.
treatment plants may not meet the agreement's
phosphorus limitations because of plant equip-
ment availability problems and/or operational
difficulties.  (See pp. 15 to 19.)
                       11

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Efforts to control phosphorus pollution from
other sources, such as high-phosphate house-
hold detergents, have been controversial.
Research to resolve uncertciinty about the
nature and extent of overall phosphorus
controls may not be undertc.ken because a
coordinated Great Lakes research program
does not exist.  (See pp. }9 to 26.)

TOXIC POLLUTION
The U. S.-Canadian agreement}, recognized the
extent of toxic pollution o^f the lakes and
     red
II

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Specific U.S. monitoring efforts have been
hampered by a lack of funds.   In addition, the
International Joint Commission has yet to en-
dorse the Great Lakes International Surveil-
lance Plan, advocated by the  agreement as the
basic model for monitoring activities in the
Great Lakes Basin.  The Commission is not sure
whether the plan is effective and can be imple-
mented.  (See pp. 37 to 42.)

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        Efforts to control phosphorus pollution from
        other sources, such as high-phosphate house-
        hold detergents, have been controversial.
        Research to resolve uncertainty about the
        nature and extent of overall phosphorus
        controls may not be undertaken because a
        coordinated Great Lakes research program
        does not exist.  (See pp. 19 to 26.)

        TOXIC POLLUTION

        The U.S.-Canadian agreement recognized the
        extent of toxic pollution of the lakes and
        required the two Governments to meet  specific
        toxic control objectives.  However, the prob-
        lem has yet to be addressed comprehensively.
        Information is lacking about the nature,
        extent, and source of toxic pollution, and
        the activities necessary to provide the infor-
        mation have been limited.  Also, U.S.  toxic
        control programs are very new and their effec-
        tiveness is not known.  (See pp. 33 to 37.)

        NONPOINT POLLUTION SOURCES

        In some areas, nonpoint (diffused)  sources,
        such as agricultural, forestry, and urban
        runoff, deposit the major portion of  pollu-
        tants entering the lakes.  However, State  and
        areawide plans to address nonpoint pollution
        problems have not been comprehensive  and may
        not be completed.  Federal funding for new
        planning has been cut off.  Projects  to con-
        trol nonpoint pollution have not been exten-
        sive, and implementation of control mechanisms
        developed are site specific.

        Without more attention to nonpoint sources and
        a coordinated strategy and plan for dealing
        with them, the Great Lakes water quality objec-
        tives may not be achieved even if all other
        sources of pollution are completely controlled
        or eliminated.  (See pp. 26 to 33.)

        WATER QUALITY MONITORING

        Accurate, reliable data describing existing
        water quality conditions and trends,  how pol-
        lution occurs, and the effect of eliminating
        sources of pollution is essential to  control
        efforts.  But current water quality monitoring
        is not providing the data needed to address
        questions about toxic, nonpoint, and  phosphorus
       * pollution problems.
Tear Sheet

                              iii

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Specific U.S. monitoring efforts have been
hampered by a lack of funds.   In addition, the
International Joint Commission has yet to en-
dorse the Great Lakes International Surveil-
lance Plan, advocated by the  agreement as the
basic model for monitoring activities in the
Great Lakes Basin.  The Commission is not sure
whether the plan is effective and can be imple-
mented.  (See pp. 37 to 42.)

EPA's RESPONSIBILITIES

EPA has broad responsibilities for carrying
out programs and activities to implement
agreement objectives and coordinating the
Great Lakes activities of many Federal and
State agencies.  EPA's Great  Lakes National
Program Office has been frustrated in its
efforts to ensure that U.S. agreement commit-
ments are met because it does not have the
visibility, authority, or resources needed
to meet its responsibilities.  (See pp.  53
to 59.)

RECOMMENDATIONS TO THE CONGRESS

GAO recommends that the Congress, in consul-
tation with the Secretary of  State and the
Administrator, EPA, determine whether (1) the
Great Lakes Water Quality Agreement objectives
and commitments are overly ambitious and
(2) sufficient funding to meet agreement
objectives and commitments can be provided,
given current economic and budgetary condi-
tions.  GAO also recommends that the Congress
pass legislation currently pending to estab-
lish a Great Lakes research office in the
National Oceanic and Atmospheric Administra-
tion to coordinate and carry out needed
research activities.  (See p. 43.)

RECOMMENDATIONS TO EPA

GAO recommends that the EPA Administrator
(1) develop a comprehensive plan and strategy
to address phosphorus, nonpoint, and toxic
pollution problems in the Great Lakes and
(2) elevate the Great Lakes National Program
Office within EPA and give it the authority
and resources necessary to direct the Federal
Government's Great Lakes water quality activi-
ties.  GAO also makes other recommendations
to improve Great Lakes water  quality activi-
ties.  (See pp. 43, 44, and 59.)
                       IV

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      AGENCY  COMMENTS

      EPA,  the  Departments  of  State  and  Agriculture,
      and  the U.S.  Section  of  the International
      Joint Commission  provided  comments on  this
      report.   Although the agencies generally agreed
      that  Great  Lakes  water quality activities  are
      complex,  involve  a number  of Federal,  State and
      local agencies, and are  comprehensive,  they
      provided  additional comments and clarifications
      on  specific items.  None of the agencies com-
      mented  on GAO's recommendation to  the  Congress
      on  agreement  objectives  and funding.

      EPA stated  that GAO had  failed to  acknowledge
      (1)  the comprehensiveness  of the Great Lakes
      agreement's phosphorus objectives  and  (2)  the
      numerous  Federal  and  State efforts taken to
      meet  agreement terms. Also, although  EPA
      strongly  supports more effective coordination
      of  Great  Lakes research  activities, it is  con-
      cerned  that the pending  legislation endorsed by
      GAO will  fragment EPA's  established mechanisms
      for  addressing Great  Lakes problems.   Further-
      more, EPA had serious reservations about GAO's
      water quality monitoring discussion and did
      not believe the National Program Office needs
      to  be elevated within EPA  to exercise  more au-
      thority over  Great Lakes water quality programs,

      GAO has not understated  the comprehensive
      nature  of the water quality agreement  or the
      U.S.  efforts  to meet  agreement objectives.
      GAO believes  that:

      —Its discussion  of phosphorus objectives  is
        comprehensive and demonstrates that  the
        objectives  have yet to be met.

      —So  far  EPA has  not  developed a coordinated
        Great Lakes research program and has not
        funded  important research activities.

      —Problems  with water quality  monitoring will
        hinder  identifying  pollution sources and
        levels, developing  control strategies, and
        evaluating  control  measures.

      Appendixes  IX to  XII  contain the agencies'
      comments  and  GAO's responses.
Tear Sheet

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                                                          Page

DIGEST                                                      i

CHAPTER
   1       INTRODUCTION                                     1
               Importance of the  Great  Lakes                 1
               Boundary Waters Treaty of  1909                1
               U.S. and Canadian  Great  Lakes
                 Water Quality Agreements                   3
               Primary agencies involved  in
                 Great Lakes cleanup                        4
               Objectives, scope,  and methodology            5

   2       U.S.  GREAT LAKES WATER QUALITY
             OBJECTIVES ARE NOT BEING FULLY MET            10
               Controlling municipal pollution sources
                 continues to lag behind  schedule          10
                   Sewage treatment  goals will not
                     be met                               11
                   Limited progress  in  controlling
                     combined sewer  discharges             14
               Phosphorus is not  being  completely
                 controlled and control efforts may not
                 be properly focused                      15
                   Discharge limits  not being met          16
                   Detergent phosphate  bans are contro-
                     versial                              19
                   Need to resolve uncertainties about
                     lake phosphorus inputs and target
                     loads                                20
               Nonpoint pollution sources have received
                 little attention                         26
                   Nonpoint sources  may contribute
                     most to Great Lakes  pollution         26
                   Nonpoint control  efforts have been
                     slow and resources devoted minimal    28
               Toxic pollution—potentially the
                 greatest problem                         33
                   Emphasis on toxics is  relatively
                     new                                  33
                   Nature, extent, and  source of
                     toxics are undefined                 34
                   Effectiveness  of  control
                     efforts unknown                      36
               Effective water quality  monitoring
                 activities have  not been developed
                 and implemented                           37
                   Importance of monitoring recog-
                     nized in water  quality agree-
                     ment                                 37

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CHAPTER                                                    Page

                   Existing Great Lakes monitoring
                     activities have been constrained
                     and criticized                         38
                   Questions raised about proposed
                     monitoring plan                        40
               Conclusions                                  42
               Recommendations to the Congress              43
               Recommendations to the Administrator,  EPA    43
               Agency comments and our evaluation           44

   3       EPA SHOULD GIVE GREATER ORGANIZATIONAL
             VISIBILITY TO ITS GREAT LAKES ACTIVITIES       53
               Great Lakes responsibilities are broad
                 and complex                                53
               Problems limit EPA efforts to meet agree-
                 ment objectives                            54
                   Great Lakes responsibilities are
                     handled at a low organizational
                     level                                  54
                   Lack of authority frustrates GLNPO's
                     ability to carry out responsibil-
                     ities                                  55
                   Funding problems limit Great Lakes
                     activities                             58
               Conclusions                                  58
               Recommendations to the Administrator,
                 EPA                                        59
               Agency comments and our evaluation           59

APPENDIX

    I      Selected Federal environmental legisla-
             lation and agencies affecting the Great
             Lakes                                          61

   II      Selected and annotated bibliography of
             GAO reports involving water quality
             issues in the United States                    70

  III      Estimated construction completion dates
             for major U.S. municipal treatment
             plants—lower Great Lakes                      74

   IV      Great Lake Basin funding for municipal
             sewage treatment plants                        75

    V      Additional uncertainties about Great
             Lakes phosphorus controls                      76

   VI      Federal grant outlays for pollution
             control programs and activities in the
             Great Lakes Basin, 1978-80                     80

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APPENDIX


   VII

  VIII




   IX
   XI

  XII
Significant tributary sampling locations

Interrelationship of major Federal and State
  agencies involved in carrying out Great
  Lakes Water Quality Agreement objectives

Letter from the Acting Associate Administrator
  for Policy and Resource Management,
  Environmental Protection Agency

Letter from the Comptroller, Department
  of State

Letter from the Secretary of Agriculture

Letter from the Secretary, United States
  Section, International Joint Commission
Page

 81



 82



 83


100

102


106
  EPA

  GAO

  GLISP

  GLNPO

  IJC

  NOAA

  mg/i
              ABBREVIATIONS

 Environmental Protection Agency

 General Accounting Office

 Great Lakes International Surveillance Plan

 Great Lakes National Program Office

 International Joint Commission

 National Oceanic and Atmospheric Administration

 milligrams per liter

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                          GLOSSARY
Combined sewer
Detergent
Effluent
Effluent
  limitations
Eutrophication
Nonpoint sources
Phosphorus


Point sources
A sewer that carries both wastewater and
storm water to a treatment plant.   During
a storm, only part of the flow is  inter-
cepted, and the remainder goes directly
into the receiving stream untreated.

Synthetic,  water-soluble or liquid,  sur-
face active agents used in washing.   To the
extent that they are not biodegradable,
they create a long-term pollution  problem.

The wastewater discharged by an industry
or municipality.

Restrictions established by a State or EPA
on quantities, rates, and concentrations
of chemical, physical,  biological,  and
other constituents discharged from point
sources.

The normally slow aging process by which
a lake evolves into marsh and ultimately
becomes completely filled with debris
and disappears.  It is caused by an excess
of dissolved nutrients—for example,  nitro-
gen and phosphorus.  Untreated wastes
(pollution) greatly accelerate the aging
process.

Sources of pollution that are difficult to
pinpoint and measure.  Common examples in-
clude runoff from agriculture and  forest
lands, runoff from mining and construction,
and storm runoff from urban areas.

An essential element and nutrient  for all
life forms present in wastewater.

Specific sources of pollution that can be
readily identified, such as factories and
sewage treatment plants.
Toxic substance
A substance that either directly poisons
living things or alters their environment so
that they die.  Examples are cyanides found
in plating and steel mill wastes, phenols
from coke and chemical operations,  pesti-
cides and herbicides, and heavy metal salts.
Another group includes sulfides, produced by
oil refineries, smelters, and chemical plants

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                           CHAPTER 1

                         INTRODUCTION

     The Great Lakes have been viewed as a  virtually inexhaustible
supply of high-quality water.   But intensifying water and  land
use coupled with various forms of municipal and industrial  pollu-
tion has resulted in a continuing degradation of the lakes.   To
protect this vast and valuable natural resource,  the United  States
and Canada have entered into a series of treaties and agreements.

IMPORTANCE OF THE GREAT LAKES

     The United States and Canada share the Great Lakes—Erie,
Huron, Michigan, Ontario, and  Superior (see map on p.  2)—and the
connecting channels which form the Earth's  largest freshwater lake
system.  The lakes contain about 20 percent of the world's  fresh
surface water and over 95 percent of  the U.S.  fresh surface  water
supply for the contiguous 48 States.

     The Great Lakes Basin--that part of North America drained by
the five lakes, their tributaries and connectors,  and the  inter-
national section of the St.  Lawrence  River—includes all of  Mich-
igan and parts of Illinois,  Indiana,  Minnesota,  New York,  Ohio,
Pennsylvania, Wisconsin, and the Province of Ontario.  The basin
constitutes one of North America's most important regions.   It
contains about 50 percent of Canada's total population and  nearly
20 percent of the total U.S. population. The basin supports eco-
nomic activity that accounts for 60 percent of the annual  national
income for Canada and 25 percent for  the United States.  Thus, the
abundant water resources of the Great Lakes must be protected.

BOUNDARY WATERS TREATY OF 1909

     The Great Lakes are unique in that virtually all  lake activi-
ties require a cooperative effort by  both the  United States  and
Canada.  Consequently, both countries must  work together to  ensure
the continued cleanup of the lakes.

     The basic U.S.-Canadian agreement covering the Great  Lakes
is the Boundary Waters Treaty of 1909, which was to prevent  and
settle disputes over the use of boundary waters including, but
not limited to, the Great Lakes.  The treaty provides that boun-
dary waters and waters flowing across the boundary are not to be
polluted on either side to the point  of injuring human health or
the property of the other country.

     To carry out the purposes of the treaty,  the International
Joint Commission (IJC) was established.   The IJC,  a permanent body
made up of three members from  each country,  is responsible  for:

     —Approving or disapproving applications  from the govern-
       ments, companies, or individuals for the use,  obstruction,
       or diversion of boundary waters.

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     —Investigating any differences arising between the two
       governments involving the rights,  obligations, interests,
       and inhabitants of the other along the boundary.   These
       investigations are called references and are referred to
       IJC by the two Governments.

     —Monitoring compliance with^the terms and conditions set
       forth in its approval of applications and,  when requested
       by the Governments, monitoring and coordinating actions or
       programs it has recommendect •

     Responding to requests by the!  U.S. and Canadian Governments
between 1909 and 1970, IJC made three major studies on Great Lakes
water pollution.  One study, made from 1964 to 1970, examined
water pollution in Lakes Erie and Ontario (the lower lakes)  and
the international section of the St. Lawrence River.  This IJC
study recommended that common water quality objectives be estab-
lished for the Great Lakes and that the United States and Canada
agree on the programs and measures  needed to achieve these objec-
tives.  IJC further recommended that its  powers be expanded to
include coordinating and monitoring efforts to implement inter-
national agreements reached.  These recommendations led  to the
Great Lakes Water Quality Agreement of 1972.

U.S. AND CANADIAN GREAT LAKES
WATER QUALITY AGREEMENTS

     The first Great Lakes Water Quality  Agreement between the
United States and Canada was signed April 15,  1972, by the Presi-
dent and the Prime Minister.  The agreement was to provide a
basis for more effective cooperation to restore and enhance  Great
Lakes water quality.  The initial emphasis under the 1972 agree-
ment was to find solutions to the more obvious water quality prob-
lems.  Accordingly, high priority was given to implementing
effective industrial and municipal  wastewater treatment, includ-
ing phosphorus removal.

     In November 1978, the Governments reaffirmed  their  determina-
tion to clean up the Great Lakes by entering into  a new agreement.
Like its predecessor, the new agreement established both general
and specific water quality objectives for Great Lakes waters.   The
specific objectives were, however,  far more comprehensive and
stringent than those established in 1972.  The 1978 agreement
recognized that water quality depends on  the interacting compo-
nents of air, land, water, and living organisms and therefore more
comprehensively addressed the remedial programs and measures to
be developed by the Governments and committed them to specific
actions to meet the objectives.

     Each Government agreed to develop and implement programs
and other measures to control, abate, and prevent  pollution  from
seven specific sources or activities:  (1) municipalities,
(2) industries,  (3) agriculture, forestry, and other land uses,
(4) shipping, (5) dredging, (6) onshore and offshore facilities,

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and (7) airborne contaminants.   The Governments  also  agreed to
develop and implement programs  and measures  to reduce and  control
inputs of phosphorus to the lakes,  minimize  or eliminate the
release of hazardous substances, and eliminate all discharges of
persistent toxic substances. Further,  the agreement  requires a
coordinated surveillance and monitoring program  which, when suc-
cessfully implemented,  would (1) assess compliance with pollution
control requirements and achievement of agreement objectives,
(2) provide information for measuring lake response to control
measures, and (3) identify emerging problems.

     The 1978 agreement remains in force for a period of 5 years
and thereafter,  until terminated by one of the Governments.
Article 10 of the agreement requires the Governments  to conduct
a comprehensive review of the operation and  effectiveness  of the
agreement following the third biennial  report  of the  IJC due in
1986.  Therefore, the Governments may not be assessing the agree-
ment until then.

PRIMARY AGENCIES INVOLVED
IN GREAT LAKES CLEANUP

     In the United States,  both Federal and  State agencies are
responsible for Great Lakes cleanup efforts.   The Department of
State and the Environmental Protection Agency  (EPA) are the two
Federal agencies most involved  with the water  quality agreement.
The Department's Office of Canadian Affairs  was  primarily  respon-
sible for negotiating the agreement and now  works with EPA to
maintain open communication with Canada and  IJC  concerning
agreement implementation.  EPA  is the prime  U.S. agency respon-
sible for actually implementing the agreement.  EPA implements
programs and measures through existing Federal legislation, pri-
marily through the Clean Water  Act, as amended,  although numerous
other legislative authorities governing clean  air, toxic sub-
stances control, and resource conservation and recovery play
important roles.  Also, Great Lakes agreement  activities are not
generally separately funded under domestic law.

     To fulfill its responsibilities under the agreement,  EPA
created the Great Lakes National Program Office  (GLNPO).   This
office, located within EPA1s region V office,  acts as the  focal
point to plan, coordinate,  and  oversee cleanup efforts by  EPA
divisions, other Federal agencies, and the Great Lakes States.
Other Federal agencies which directly support  activities related
to the agreement include the Departments of  Agriculture, Com-
merce, Defense,  the Interior, and Transportation.  As with other
U.S. pollution control efforts, the States are responsible for
implementing control programs under EPA's direction.   Appendix  I
lists selected U.S. agencies, departments, and organizations
and U.S. laws affecting Great Lakes activities.

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       The  chart below shows the primary  agencies, departments, and
organizations involved with  activities  covered by  the Great  Lakes
Water Quality Agreement in both Canada  and  the United States.   It
also  shows that  the efforts  of all these groups should be coordi-
nated with the IJC.
       CANADIAN PROVINCES

       Ontario
            CANADIAN AGENCIES

       Department of the Environment:
        Atmospheric Environment Service
        Environmental Management Service
        Environmental Protection Service
       Department of Agriculture:
        Food Production and Marketing Branch
        Research Branch
       Department of Energy, Mines and Resources
       Department of External Affairs
       Department of Public Works
       Department of Transportation
           INTERNATIONAL
           JOINT COMMISSION
       IJC Commissioners and Staff
       Great Lakes Water Quality Board
       Great Lakes Science Advisory Board
       Windsor Regional Office
       IJC Committees/Subcommittees/
         Special Task Forces
        Environmental Protection Agency
        Department of Agriculture-
          Agricultural Stabilization and
           Conservation Service
          Farmers Home Administration
          Forest Service
          Science and Education Administration
          Soil Conservation Service
        Department of Commerce.
          Maritime Administration
          National Oceanic and Atmospheric
           Administration
        Department of Defense:
          Army Corps of Engineers
Department of the Interior
  Fish and Wildlife Service
Department of State
Department of Transportation.
  Coast Guard
  St. Lawrence Seaway Development
    Corporation
Council On Environmental Quality
Great Lakes Basin Commission a I
Great Lakes Commission
Water Resource Council
     _a/The commission was abolished effective Sept. 30, 1981.
OBJECTIVES, SCOPE, AND  METHODOLOGY
      On March 21,  1975,  we  issued  a report  entitled "Cleaning Up
the Great Lakes:   United States and Canada  Are  Making Progress  in
Controlling  Pollution  from  Cities  and Towns"  (RED-75-338).   We
reported  that both  nations  had made substantial progress  in con-
trolling  pollution  from municipal  sources,  but  the  United  States
needed to make a greater commitment to support  other  agreement
provisions.   Since  our  1975 report, the  United  States and  Canada
have entered into a new Great  Lakes Water Quality Agreement.

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Because over 6 years have passed since our report and because  the
United States and Canada have entered into a new agreement,  we
believed that a followup study of Great Lakes pollution  control
efforts would be useful to the Congress,  EPA, and the Department
of State in assessing U.S. progress in meeting agreement commit-
ments with Canada.

     The objectives of our review were to

     —evaluate whether substantial progress is being made  in
       controlling pollution from municipal sources since our
       last report in 1975,

     —determine how well the United States is meeting other
       agreement provisions,

     —evaluate whether EPA is fulfilling its lead agency
       responsibility for implementing the programs and  other
       measures necessary to achieve agreement objectives,  and

     —determine whether IJC is fulfilling its advisory  role
       required under the latest agreement.

     We did not review the entire 1978 water quality agreement
because of the time and resources that would have been required
to comprehensively evaluate the numerous provisions.   Rather,  to
meet our objectives, we focused on several key areas of  the agree-
ment—the control of municipal wastewater and phosphorus dis-
charges, nonpoint (diffused) pollutants,  toxic substances,  and
surveillance and monitoring efforts.  We selected these  areas
because (1) the construction of municipal wastewater treatment
plants has been slow despite the substantial Federal investment
in these plants, (2) the control of phosphorus, particularly in
the two lower lakes (Erie and Ontario), was identified in the
1972 and 1978 agreements as being of high importance, (3) the
1978 agreement recognized that nonpoint pollution was a  major
problem, (4) the control of toxics and other hazardous polluting
substances was identified in the 1978 agreement as being needed,
and (5) the need for comprehensive surveillance and monitoring
to provide the management data needed for decisionmaking with
respect to Great Lakes activities was an important require-
ment in both agreements.

     We performed our review during the period February  to
October 1981 at the following principal locations:

     —EPA headquarters, Washington, D.C.; EPA's region  V office
       and the Great Lakes National Program Office, Chicago,
       Illinois; EPA's Large Lakes Research Station,  Grosse
       lie, Michigan; and EPA's Environmental Research Labora-
       tory, Duluth, Minnesota.

     —IJC headquarters, Washington, D.C.; and the Great Lakes
       IJC regional office, Windsor, Ontario.

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     --Department of Agriculture (Soil Conservation Service and
       the Agricultural Stabilization and Conservation Service)
       headquarters, Washington, D.C.

     —The Great Lakes Basin Commission,  Ann Arbor,  Michigan.

     —The Michigan Department of Natural Resources,  Lansing,
       Michigan.

     —The New York Department of Environmental Conservation,
       Albany,  New York.

     —The Ohio Environmental Protection Agency, Columbus,
       Ohio.

     —U.S. Department of State headquarters, Washington,  D.C.

Our review was performed in accordance with our "Standards for
Audit of Governmental Organizations,  Programs, Activities,  and
Functions."

     We made an extensive literature  and legislative search to
identify the major U.S. Federal agencies and laws affecting the
water quality agreements.  (See app.  I.)   We also researched our
reports and studies dealing with water quality issues and  prob-
lems Federal agencies have experienced in meeting legislated
objectives for water quality.  Appendix II is a selected and
annotated bibliography of our reports involving water quality
issues in the United States.

     To evaluate EPA region V activities related to the water
quality agreements, we interviewed the current and former
regional administrators,  the director and individual staff mem-
bers in the Great Lakes National Program Office, and other
regional officials responsible for specific programs needed to
meet water quality agreement objectives.   To determine the extent
of EPA's efforts to fulfill its lead  agency responsibility under
the agreement,  we obtained and analyzed congressional budget
justifications for fiscal years 1979  through 1982,  funding and
position statements for fiscal years  1977 through 1980, organiza-
tional and function statements, staff position descriptions,
Great Lakes strategies and program plans for fiscal years  1980
and 1981, internal evaluations of EPA programs or operations,
and cost data for various programs and demonstration projects.
To determine the role of EPA headquarters and its relationship
with region V,  we interviewed headquarters staff involved  with
international activities and obtained and analyzed correspondence
and records pertaining to EPA headquarters' role as the liaison
between region V and the Department of State.

     IJC was a significant source of  information.  We inter-
viewed various  IJC officials, including the three former U.S.
commissioners,  the IJC Secretary and  staff members of the  head-
quarters office,  the current and former directors of the IJC
regional office, and the  U.S. chairpersons of IJC advisory

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boards.  We also examined and analyzed numerous  IJC  studies,
reports, and other documents and correspondence,  some  dating
back to 1972, dealing with government activities  and progress
under the agreements and other water quality problems  peculiar
to the Great Lakes.  One of the key documents obtained and
analyzed was the Great Lakes International  Surveillance Plan
(GLISP) which represents the long-term strategy to coordinate
and plan water quality monitoring activities in  the  Great Lakes
Basin.  We also attended various IJC public hearings,  as well
as the 1980 and 1981 IJC annual meetings.

     To determine State Great Lakes activities, we interviewed
officials in State environmental departments and  agencies respon-
sible for the administration and coordination of  State activities
involving Great Lakes water quality.  We obtained and  analyzed
State water quality planning and programing documents;  State/EPA
agreements; State legislation and hearings; and  various Great
Lakes water quality studies done by industry, academia, and other
private organizations.  Our State work was  limited to  agreement
activities in Michigan, New York, and Ohio  because these States
border the two lower lakes—Erie and Ontario—which  have experi-
enced the most serious pollution problems over the years.  In
addition, the State of Michigan borders Lakes Huron, Michigan, and
Superior.  We did, however, obtain and analyze information concern-
ing the other five Great Lakes States'  activities, primarily from
IJC and the Great Lakes Basin Commission.

     To obtain information on the activities of  other  agencies and
organizations related to Great Lakes water  quality activities, we
interviewed the Department of State officer responsible for coor-
dinating environmental affairs with Canada; key  staff  members in
Water Quality Project Implementation in the Soil  Conservation
Service of the Department of Agriculture; officials  and staff mem-
bers of the Army Corps of Engineers (North  Central Division); the
Deputy Director of the Office of Marine Pollution Assessment in
the National Oceanic and Atmospheric Administration  (NOAA)r the
Director of EPA's Large Lakes Research Station;  senior staff mem-
bers with the Council on Environmental Quality;  and  various offi-
cials, including the Executive Director,  of the  Great  Lakes Basin
Commission.

     To determine program costs for pollution control  activities
in the Great Lakes Basin, we obtained funding data for the State
and county levels for fiscal years 1978 through  1980 from the
Federal Information Exchange System compiled by  the  Community
Services Administration.  Assistance in obtaining and  processing
this data was provided by House Information Systems, Committee
on House Administration, the U.S. House of  Representatives.  We
also obtained overall fiscal years 1981 and 1982  funding for
these activities and assessed the impact of the  March  1981 budget
revisions proposed by the President.

     This report relates to only U.S. Great Lakes water quality
efforts because we have neither the authority nor responsibility


                               8

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to review Canadian efforts.  Any references to Canadian data or
efforts in this report are based on reports published by IJC and
others.  We did not verify the accuracy of the data on Canadian
efforts or evaluate their effectiveness in meeting Canadian
responsibilities under the agreement.

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                           CHAPTER 2

           U.S. GREAT LAKES WATER QUALITY OBJECTIVES

                   ARE NOT BEING FULLY MET

     Although in 1978 the United States committed itself to a
comprehensive program to control Great Lakes  pollution,  the lakes
continue to experience eutrophication (aging)  and toxic  pollution
problems because

     —controlling municipal pollution sources continues to lag
       behind schedule;

     —phosphorus, a major factor in  controlling  lake  eutrophica-
       tion, is not being completely  controlled and control
       efforts may not be properly focused;

     —little attention has been directed to  nonpoint  sources of
       lake pollution;

     —the extent and sources of toxic pollution  remain  undefined,
       and an overall toxic control strategy  has  not been devel-
       oped; and

     —comprehensive, effective surveillance  and  monitoring
       activities needed to determine water quality conditions
       and trends and assess pollution control efforts have not
       been developed and implemented.

     Although progress is being made  in cleaning  up the  Great
Lakes, the United States has experienced many difficulties in
attempting to meet its water quality  agreement commitments.  The
lack of information about the nature, source,  and extent of lake
pollution from some substances, funding constraints, and other
factors have all hindered U.S. efforts.  If the United States
is to meet its commitments to protect the Great Lakes, however,
greater and more comprehensive efforts will be needed.

CONTROLLING MUNICIPAL POLLUTION SOURCES
CONTINUES TO LAG BEHIND SCHEDULE

     From 1972 to February 1981, the  United States spent about
$4.9 billion in Federal, State, and local funds to construct and
upgrade municipal sewage facilities to treat  wastewater  dis-
charges to the lakes, but more remains to be  done.  The  Nation
will not meet the December 31, 1982,  agreement goal for  adequate
treatment of all municipal sewage discharges  to the lakes.  In
addition, discharges from combined sewers (sewers that carry
municipal wastewater along with storm runoff)  continue to be a
major source of lake pollution, but little funding or  effort has
been directed to controlling these discharges. Ambitious agree-
ment timetables, difficulties in obtaining funding, and  treatment
plant operational problems, among other factors,  have  all

                               10

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contributed to the difficulties in controlling  municipal
pollution sources.

Sewage treatment goals will not be met

     The Water Quality Agreements require the United  States  to
(1) construct and operate waste treatment facilities  to provide
adequate treatment for the sewered population in the  U.S.  portion
of the Great Lakes Basin, (2)  provide financial resources  to
ensure prompt construction of needed facilities, and  (3) estab-
lish pretreatment requirements for industrial plants  discharging
waste into municipal systems.   We reported in March 1975 that
the United States had made substantial progress with  its munici-
pal point source control program, but that much remained to  be
done.  That continues to be the case today.

     A goal of the 1972 agreement was that the  municipal point
source control programs in both Canada and the  United States
would be either completed or in process by December 31, 1975.
We reported in 1975 that the United States would not  realize
this goal.  We further reported that, at that time, only about
60 percent of the U.S. sewered population had adequate treatment
compared with about 98 percent for Canada.

     When the Governments negotiated the 1978 agreement, they
established December 31, 1982, as the new goal  for completion of
municipal point source control programs, including the require-
ment for providing adequate treatment.  In the  United States, the
Clean Water Act, as amended, requires publicly  owned  treatment
works to provide a minimum of secondary treatment with more
stringent treatment to be provided if secondary treatment  would
be insufficient to protect water quality.  Meeting the require-
ment for secondary treatment satisfies !_/ the 1978 agreement
requirement for adequate municipal treatment.

     In its Seventh Annual Report on Great Lakes Water Quality,
issued October 1980, IJC reported that only 64  percent (compared
with 60 percent in 1975) of the sewered population in the  U.S.
portion of the basin has adequate sewage treatment, compared to
99 percent for Canada.  In that report,  EPA estimated that com-
pletion of treatment facilities under construction should  provide
99 percent of the U.S. sewered population with  adequate treatment
by 1983.  We found, however, that a significant number of  munici-
pal plants on the Great Lakes will not be completed in time  to
meet the agreement goal of December 31,  1982.   EPA's  own esti-
mates (see app. Ill) show that 31 percent of all major municipal
treatment facilities on the lower Great Lakes will not be  com-
pleted until 1983 or later.   At the same time,  however, EPA
l./The agreement also requires phosphorus  effluent  limitations  for
  municipal wastewater treatment plants.   Phosphorus  control
  efforts are discussed on pp. 15-26.

                               11

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points out that the unfinished facilities represent only about
15 percent of the total municipal sewage flow from major facil-
ities into the lower lakes.

     In addition, the completion of municipal treatment  plants
does not in itself guarantee that adequate treatment will  be
provided.  For example, in a 1980 report I/ on wastewater  treat-
ment plants, we found that municipal facilities nationwide were
experiencing severe problems limiting their ability to treat
waste.  These problems included plant design and equipment defi-
ciencies, defective sewer systems allowing infiltration  of ground
water that overloads existing facilities, industry waste that is
not compatible with the plant's treatment system process,  and
operation and maintenance deficiencies.   We reported that  inade-
quate operation and maintenance of the 242 municipal plants
sampled nationwide resulted in such repeated violations  of dis-
charge permits 2/ that the violations constituted the norm rather
than the exception.  Using the sampling data in that report,
we determined that 22 (85 percent) of the 26 sampled municipal
dischargers in the Great Lakes Basin violated their discharge
permits at least 1 month during the 12-month study period.
Further analysis showed that 35 percent of the 26 sampled  plants
were, in our opinion, in serious violation of the permit dis-
charge limits for biochemical oxygen demand, total suspended
solids, or total phosphorus.

     According to the GLNPO director and staff, several  reasons
exist for the delays in completing adequate treatment facilities
in the United States.  They stated that (1)  unrealistic  time-
tables were set to pressure the Governments to take action,
(2) larger, more complex facilities are needed in the United
States than in Canada because of greater population and  indus-
trialization, thereby necessitating a longer time frame, and
(3) lack of expertise among State and local recipients in
handling construction grant funds impeded efforts to assess
treatment needs and design the types of facilities needed  to
correct pollution problems.  An official with the Ohio EPA cited
several reasons for the program slippage in Ohio, including the
time required to obtain Federal construction grants, construction
problems, and the lack of support by municipal officials for
the construction of treatment facilities at a time when  other
pollution sources are not being controlled.
JL/"Costly Wastewater Treatment Plants Fail To Perform as  Expected"
  (CED-81-9, Nov. 1980).

2_/All dischargers are required to have a permit issued by EPA or
  an EPA-approved State which specifies the pollutants that may
  be discharged and the limits on such discharges.   The discharge
  permit is the principal enforcement mechanism for the water
  pollution program.


                               12

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     While many factors have limited the pace of construction for
waste treatment facilities, EPA believes that funding limits have
also slowed construction.  For example,  when a large Federal
grants program made funds available to local communities to use
in completing construction of waste treatment facilities, the
communities were no longer willing to construct facilities using
only local funds.  In addition, faced with limited funds, States
were not funding low-priority projects—typically the large num-
ber of small plants that will fail to meet the December 31,  1982,
deadline.

     From 1972 through February 1981, almost $4.9 billion in
Federal, State, and local funds was provided for municipal
sewerage construction in the Great Lakes Basin.  (App.  IV shows
municipal wastewater treatment plant construction funding by
State.)  Actions being taken to reduce the Federal budget, how-
ever, could affect the already extended dates for completing
municipal projects in the Great Lakes Basin.  For fiscal year
1980, actual funding for the construction grants program nation-
wide was $3.4 billion, $1.6 billion less than the $5 billion
authorized.  Furthermore, as part of his economic recovery pro-
gram, the President proposed, and the Congress agreed,  to
rescind $1.7 billion in previously appropriated but unobligated
construction grant funds.  Also,  on December 29,  1981,  the
President signed Public Law 97-117, the Municipal Wastewater
Treatment Construction Grant Amendments of 1981.   This  act
amended the construction grant provisions of the Clean  Water Act
to, among other things, authorize appropriations of $2.4 billion
for fiscal years 1982-85 for the grants program.   EPA's fiscal
year 1982 appropriation does not include funding for the program,
but the administration requested $2.4 billion for fiscal year
1982.  How much of this money, if appropriated, will go for
Great Lakes projects is not known.

     The 1978 agreement also requires the United States to estab-
lish pretreatment requirements for industrial wastes being dis-
charged into municipal treatment systems where such wastes are
not amenable to adequate treatment or removal using conventional
waste treatment processes.  In a 1982 report !_/ on EPA's indus-
trial pretreatment program, we reported that although the program
was authorized in 1972, it has yet to be fully implemented.   We
found that the overall scope and impact of the program  remains
undefined;  the program may result in costly, inequitable,  and/or
redundant treatment which may not address critical pollution
problems;  and the program will be a further drain on scarce
Federal, State, and local pollution control resources.   In addi-
tion, we found that the program is undergoing a regulatory review
analysis and EPA has proposed that the effective date for program
implementation be postponed indefinitely.
I/"A New Approach Is Needed for the Federal  Industrial Wastewater
  Pretreatment Program" (CED-82-37, Feb.  19,  1982) .

                               13

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Limited progress in controlling
combined sewer discharges

     To avoid overloading treatment  facilities, combined sewer
systems divert part of the storm flows  directly into waterways.
Combined sewers have caused pollution resulting in beach closures;
health hazards; fish kills; and unsightly conditions in rivers,
harbors, and bays.   Although both the 1972 and 1978 water quality
agreements addressed the need  to control  this problem, limited
progress has been made,  primarily because the structural solu-
tions proposed are  very expensive and EPA has not emphasized
alternative control techniques.  In  addition, according to EPA,
any funds available for controlling  combined sewer discharges have
instead been spent  on waste treatment facilities for treatment of
the more concentrated portion  of wastewaters.

     In 1976 IJC reported that overflows  from combined sewers
were reaching serious proportions and that accelerated control
efforts were needed.  In November 1980  IJC's Great Lakes Water
Quality Board reported that, of 51 specific problem areas (hot
spots) on the Great Lakes, 20  had serious combined sewer over-
flows.  Our analysis of these  20 areas  showed that the overflows
were most severe on Lakes Erie and Ontario.

     One reason for the limited progress  made in controlling com-
bined sewer problems is that structural solutions to the prob-
lems, such as catchment basins, are  costly.  EPA estimates that
the Great Lakes Basin States will need  $8 billion to control
combined sewer overflows—$2 billion just in the Chicago area.
In the past, little funding was directed  to correcting overflow
problems largely because States gave combined sewers low priority
compared to other municipal treatment needs.

     The adequacy of future funding  to  control combined sewer
overflows is highly questionable. Beginning in fiscal year 1983,
$200 million a year is authorized for combined sewer projects
nationwide, but the Great Lakes are  ineligible for this funding
as it only applies to projects which address water quality prob-
lems of marine bays and estuaries.  Funding to address combined
sewer problems in the Great Lakes will  not be available until
October 1, 1984, at which time the EPA  Administrator is author-
ized to use construction grant funds for  combined  sewer overflow
projects but only when such projects are  major State priorities
and the State Governor specifically  requests the funding.
Although a funding  level of $2.4 billion  annually  is expected
for the construction grants program, it is important to note
that this money will be competed for on a national basis.  Con-
sequently, the amount of money that  will  become available for
combined sewer problems in the Great Lakes is uncertain.

     In controlling pollution  from combined  sewers, the 1978
agreement emphasizes the adoption of practical solutions, but,
as noted previously, the solutions usually proposed are costly,


                               14

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large-scale structural projects.  In a 1979 report !_/ we noted
that a number of innovative or alternative control techniq-ues
which hold promise in helping control overflows are available.
These techniques include storing rainwater on rooftops,  parking
lots, and elsewhere; disconnecting downspouts;  cleaning  streets;
and using devices to increase sewage flow and to regulate and
treat sewage at overflow points.  While no technique alone pro-
vides the same degree of improvement offered by structural
changes, a number of techniques together could minimize  overflows
and reduce the size of the construction projects.   In our report
we recommended that EPA emphasize the use of inexpensive tech-
niques and require communities to make maximum use of lower cost
alternatives.

     Until additional emphasis is placed on abating pollution
from combined sewer overflows, the United States will not meet
a major provision of the 1978 agreement.  Furthermore, uncon-
trolled overflows from combined sewers will diminish the effec-
tiveness of existing municipal sewage treatment programs in
those metropolitan areas in the Great Lakes Basin experiencing
overflow problems.

PHOSPHORUS IS NOT BEING COMPLETELY CONTROLLED,
AND CONTROL EFFORTS MAY NOT BE PROPERLY FOCUSED

     Excessive phosphorus is a significant factor in lake eutro-
phication. 2_/  Phosphorus control was identified in both the 1972
and 1978 agreements as a major objective, but the agreement
objectives are not being met.  Progress is being made but treat-
ment plants are not achieving the phosphorus discharge limits
established, and the need for detergent phosphate controls is
controversial.  In addition, many uncertainties exist concerning
the extent of the phosphorus pollution problem, acceptable levels
of phosphorus inputs to the lakes, and the value and cost effec-
tiveness of various control programs.   Research efforts
_l/"Large Construction Projects To Correct Combined  Sewer  Over-
  flows Are Too Costly" (CED-80-40,  Dec.  28,  1979).

2/Substantial additions of phosphorus to  a body of  water  such as
  the Great Lakes usually results in accelerated plant growth and
  oxygen depletion.   As chemical and biological conditions  in the
  lakes become altered (eutrophication),  less desirable types of
  fish become prevalent,  the water takes  on an unpleasant odor,
  and algae builds up on the water surface.  While  such changes
  can occur naturally, human activities have  accelerated  the
  process substantially by adding large amounts of  phosphorus to
  the lakes from such sources as agricultural and urban runoff
  and effluents from municipal sources carrying sewage, detergent
  residues, and garbage.   Human-induced eutrophication can  be
  reversed.
                               15

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needed to better understand these uncertainties and their impli-
cations for future U.S. control strategies may not be undertaken
or coordinated.  Without more accurate data on phosphorus inputs
and a more thorough understanding of how phosphorus affects the
eutrophication process, the United States is not in the best
position to implement control programs most likely to result in
the greatest improvements in Great Lakes water quality.

Discharge limits not being met

     A cornerstone of the 1972 agreement was the requirement that
phosphorus concentrations in effluent from major municipal sewage
treatment plants (those discharging more than 1 million gallons
per day), and from smaller plants as required by regulatory
agencies, would not exceed a daily average of 1 milligram per
liter (1.0 mg/1) into the lower lakes.  The 1978 agreement
extended the 1.0 mg/1 limit to the three upper lakes and further
reduced the limit on the lower lakes to 0.5 mg/1, as necessary to
meet phosphorus target loads.  The 1978 agreement is silent, how-
ever, as to whether the 1.0 mg/1 limit was intended to be a daily,
monthly, annual, or some other type of average.  The 1978 require-
ments do not take effect until the Governments determine the
allowable future phosphorus loads to all the Great Lakes and
allocate these target loads between the United States and Canada
and among the States and the Province of Ontario.  This alloca-
tion was to have been finished by May 22, 1980, but the Govern-
ments have extended this date twice since then and still have not
reached a formal agreement.  (See p. 23.)  According to the U.S.
Section of IJC, attention is not likely to be paid to the more
stringent phosphorus requirements in the 1978 agreement until
the allocations are made.

     According to EPA, until the 1978 agreement requirements
become effective, only major treatment plants on the two lower
lakes are required to achieve the 1972 requirement of 1.0 mg/1
daily average phosphorus discharge by December 31, 1982.  Never-
theless, major municipal plants, as well as some smaller ones,
in operation throughout the Great Lakes Basin generally have a
Federal requirement for a 1.0 mg/1 monthly average phosphorus
discharge in their discharge permits.

     In its November 1981 report to IJC, the Great Lakes Water
Quality Board  stated that most major municipal facilities on the
lower lakes had achieved an annual average of 1.0 mg/1, despite
earlier predictions that many of the major plants would not
achieve this limit until as late as 1986.  According to the Di-
rector of GLNPO, EPA has been very successful, especially during
the last half  of fiscal year 1981, in working with the States to
accelerate the installation of phosphorus removal equipment at
major U.S. municipal plants on the lower lakes.  Another GLNPO
official said  that a major problem in getting municipal plants
ready for phosphorus removal is the time needed to construct the
facilities to  handle the large quantities of sludge produced as
a result of the phosphorus removal process.

                               16

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     While we agree that the United States  has made  substantial
progress in limiting municipal phosphorus discharges on the two
lower lakes, we do not agree that the  1982  target date will be
met.  As discussed below, we believe it is  unlikely  that many
major U.S. municipal plants on the lower lakes will  be achieving
a daily average phosphorus discharge of 1.0 mg/1 by  December 31,
1982.

     The following chart, based on statistics compiled for
region V by a contractor and released in September 1981, shows
that for major municipal facilities on the  lower lakes alone,
85 plants had not achieved an annual average of 1.0  mg/1 at the
end of 1980.  These 85 major plants accounted for about 76 percent
of the municipal sewage flow into the lower lakes for fiscal year
1980.  Furthermore, of these 85 plants,  as  many as 41 may not
have the equipment for phosphorus removal capability necessary to
achieve an annual average of 1.0 mg/1  until after the 1982 dead-
line.
Status
at

of Phosphorus
Removal Equipment Installation

Major Municipal Plants Exceeding 1.0 mg/1
on
the Lower Lakes

Fiscal Year 1980
Lake
Erie
Ontario
Total
Number of
plants
exceeding
1.0 mg/1
56
2_9
85
Calendar year phosphorus removal
capability completed
Completed 1982 1983 1984
9 18 7 13
4 13 11
13 31 18 13
1985
9
_1
10
     Even if the completion dates  are met, this in itself does
not guarantee that a 1.0  mg/1 effluent will be achieved.  Of the
85 municipal plants in the above table,  13 already have the
necessary phosphorus removal equipment installed but were not
achieving the 1.0 mg/1 effluent limitation.  GLNPO staff and a
regional water division official told us that this was caused by
either startup problems or operational difficulties at the munic-
ipal plants.  As discussed on page 12, operational difficulties
are a major problem at U.S.  municipal plants and many plants, both
major and minor, violated their discharge permits.  Discharges of
phosphorus in excess of 1.0 mg/1 were a  common violation.

     Once the United States and Canada agree on an allocation of
the phosphorus target loads for all the  lakes, the 1978 agreement
requirements will take effect.   The requirements are 1.0 mg/1
phosphorus discharge limit for major municipal plants on the
upper lakes and a 0.5 mg/1 limit for plants on the lower lakes
where necessary to achieve the target loads, unless the Govern-
ments decide the phosphorus limits should be either relaxed or

                                17

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set at even stricter limits than currently called for by the
agreement.

     More stringent phosphorus discharge limitations may be
needed.  In 1980 an IJC Phosphorus Management Task Force report
concluded after 2 years of study that phosphorus limits  in the
range of 0.1 to 0.5 mg/1 may be needed on the lower lakes if
other suggested measures did not prove effective.  IJC recommended
in a January 1981 supplemental report to the Governments that
they assess the ability of municipal plants in the basin to
achieve concentrations below 1.0 mg/1 and consider requiring
that plants meet the more stringent limitation where technically
and economically feasible.

     It is unlikely that U.S. municipal plants will be able to
meet more stringent discharge limits.  The following table shows
that in 1980 only 123 of 240 plants were achieving annual average
discharge limits of 1.0 mg/1 or less.

               Status of Phosphorus Discharges
               by Major Municipal Dischargers
                   on All the Great Lakes
                       Water Year 1980

                                                        Number of
                    Number of plants  Number of plants    plants
             Total   achieving 0.5    achieving between  exceeding
Upper lakes  plants  mg/1 or less     0.5 and 1.0 mg/1     mg/1

Huron          19          3                  88

Michigan       76         18                 37             21

Superior      	9         _1                 _5_            	3_

    Total     104         2_2_                 50_             32

Lower lakes

Erie           97         15                 26             56

Ontario        39         __1                 _9_             29

    Total     136         16^                 3_5_             85

    Total     240         3£                 85_            117

     As shown, 117 (about 49 percent) of 240 major municipal dis-
chargers on the Great Lakes did not achieve an annual average
phosphorus discharge limit of at least 1.0 mg/1 in 1980.  Accord-
ing to EPA, 16 of these dischargers, although not achieving an
annual average, were in compliance with the 1.0 mg/1 limit by the
end of the year.  We found that the 117 plants shown above com-
prised about 61 percent of the municipal sewage flow in  the basin.

                                18

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We also found that at least 56 (48 percent)  of these  117  plants
were not expected to achieve an annual average of 1.0 mg/1  until
after 1982.   In addition,  of 136 municipal  plants on  the  lower
lakes,  only 16 (12 percent) were achieving  the 1978 agreement
proposed limit of 0.5 mg/1 or less.

Detergent phosphate bans are controversial

     In 1970 IJC  estimated that 70 percent  of the phosphorus
entering the lakes from municipal waste came from laundry
detergents.   IJC  advocated banning or limiting phosphates in
household detergents if necessary to achieve target phosphorus
loads for the lakes.  Even though the 1972  and 1978 water quality
agreements advocated limitations on phosphorus in detergents,
key Great Lakes States have resisted such limitations because of
the increased cost to consumers and the uncertainties about the
benefit the limitations would actually provide.

     While the 1972 water quality agreement only suggested  the
use of detergent  phosphate limitations,  the 1978 agreement
requires a 0.5-percent weight limitation of phosphorus in house-
hold detergents when necessary to meet allowable phosphorus
levels.  But not  all the Great Lakes States have achieved the
0.5-percent detergent phosphate limitation.   For example, of the
four States bordering Lake Erie, the most severely polluted lake,
only New York and Michigan have enacted detergent phosphorus
limitations.  Ohio and Pennsylvania have not enacted  limits,
although Pennsylvania claims that limits in New York  and  Ohio
would cover the grocery wholesalers in the  two affected Pennsyl-
vania counties.  In addition, Canada's detergent phosphorus limi-
tation is 2.2 percent by weight, as opposed to 0.5 percent  in
the United States, which has been the basis for controversy.

     The Ohio EPA and the Soap and Detergent Association  strongly
oppose a detergent phosphorus ban or limitation.  They believe it
is more cost effective overall to remove phosphorus at sewage
treatment plants.  A 1980 study funded by the Soap and Detergent
Association estimated that detergent phosphate bans currently in
effect may cost consumers as much as $448 million per year  (not
including industry's costs)'for additional  hot water, whiteners,
and water softeners necessary to achieve the cleaning power of
phosphate detergents.  In addition,  the Pennsylvania  representa-
tive to the IJC Water Quality Board pointed out that  no one has
come up with good economic criteria to justify detergent  phos-
phorus limits. The issue became more controversial in 1980 when
IJC's Phosphorus  Management Strategies Task Force reported  that
voluntarily the detergent industry had drastically reduced  the
amount of phosphorus in detergents (detergents now account  for
20 to 35 percent  of phosphorus in wastewater rather than  70 per-
cent) .   The task  force also reported that all that may be
necessary now for phosphorus control on the two lower lakes is
municipal sewage  treatment at 1.0 mg/1.   On the other hand, in
a January 1981 supplemental report (see p.  18),  the task  force
reported that more stringent control measures may be  necessary

                               19

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for the lower lakes.  According to EPA,  additional  evidence
uncovered since the task force report was released  shows further
phosphorus load reductions more likely to be needed.

     Despite the controversy,  EPA and IJC continue  to press for
extension of phosphorus limitations to Ohio and Pennsylvania.
A GLNPO environmental protection specialist told us that the
cost estimates in the Soap and Detergent Association study were
too high.  In addition to questioning the industry  study cost
figures, IJC and EPA support detergent phosphate limits  because
they provide partial control for small sewage treatment  plants
that are not required to remove phosphorus and communities whose
sewage occasionally bypasses treatment because of combined sewer
overflows and sewage systems breakdowns.  For treatment  plants
that remove phosphorus, detergent limits also reduce the degree
of treatment required, the amount of energy and chemicals used,
and the volume of sludge produced.  In addition, the U.S. Section
of IJC believes that, if the detergent phosphate limit were
suddenly removed, treatment plants now barely achieving  their
1.0 mg/1 effluent limitation would no longer meet this require-
ment, as an increase of about 20 to 35 percent could be  expected
in the quantity of phosphorus that would need to be removed.

Need to resolve uncertainties about
lake phosphorus inputs and target loads

     Even though eutrophication control through phosphorus
removal has received most of the attention since the first water
quality agreement, uncertainties abound concerning  the extent of
the phosphorus pollution problem, the acceptable level of phos-
phorus inputs to the Great Lakes, and the value and cost effec-
tiveness of various control programs.  These uncertainties
exist because of the difficulty in accurately measuring  phos-
phorus inputs to the lakes, calculating phosphorus  target loads
to direct future control efforts, and analyzing in-lake  biologi-
cal and chemical processes, such as whether all of  the phosphorus
going into the lakes will result in excessive algae blooms and
what happens to phosphorus as it travels to the lakes in rivers
and streams.  In addition, research efforts needed  to better
understand these issues and their implications may  not be under-
taken or coordinated.  Without more accurate data on phosphorus
inputs and a more thorough understanding of how phosphorus acts
in the aging process, the United States is not in the best posi-
tion to implement control programs most likely to result in the
greatest improvement in Great Lakes water quality.

     Future phosphorus control
     strategy uncertain

     The 1978 agreement contained estimated target  phosphorus
loads for each of the Great Lakes and required the  Governments  to
confirm what the future phosphorus loads would be and use this
data to establish load allocations and compliance schedules for
each country.  Establishing valid target loads is critical

                               20

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because they will form the basis for an overall  phosphorus
control strategy to direct future Great Lakes control  pr6grams.

     To answer a number of unresolved phosphorus questions,  IJC
in 1978 established a Phosphorus Management Strategies Task  Force
comprised of representatives from government and academia.
The task force was to review and analyze data concerning  phos-
phorus input loads for 1976 (the base year)  and  evaluate  the
scientific models used to establish target loads.

     In a July 1980 report, endorsed by IJC,  the task  force
concluded that (1) clear directions on the extent,  timing, and
type of phosphorus controls are not apparent and (2) many uncer-
tainties (information needs) should be dealt with so that future
phosphorus management decisions can be more reliable.   The task
force also reported that its efforts were constrained  because
it had to use secondary sources of information,  had little
opportunity to resolve conflicts among these sources,  and had
to rely on models that could not resolve crucial issues.

     In confirming what the target loads should  be, the task
force accounted for some of the uncertainty by calculating both
a best estimate and a range of phosphorus input  reductions
needed.  The calculations assumed that the goal  of  reducing
wastewater treatment plant phosphorus discharges to 1.0 mg/1
would be achieved on all the lakes.   The following  table  shows
the target loads for all the lakes and depicts the  measured
uncertainty for Lakes Erie and Ontario.
                               21

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Lake
             Estimated Phosphorus Loads
              in Metric Tons per Year

                    Load after municipal
                      treatment plants
1976 best              achieve 1.0  mg/1
estimate   Target load   best estimate
(note a)   best estimate    (note a)
                                    3,400
                                    5,600
                                    4,400
                                   14,700
                                    9,600
Superior
Michigan
Huron
Erie
Ontario
4/200
6,400
4,900
18,400
11,800
3,400
5,600
4,400
c/ 11,000
c/ 7,000
 Additional
 reductions
 which may
 be required
best estimate

     (b)
     (b)
     (b)
    3,700
    2,600
   Range

     (b)
     (b)
     (b)
  0 to 9,400
200 to 5,400
     a/The Task Force found that the 1976 (the base year) estimates of
       phosphorus inputs had no rigid scientific or statistical basis.
       The task force considered these estimates to be accurate within
       plus or minus 15 percent.

     b/Although the estimates for the three upper lakes are subject
       to the same uncertainty as for the lower lakes, the task force
       believed that to maintain the present high quality waters of
       the upper lakes, only phosphorus from sewage needs to be con-
       trolled.

     c/The figures shown represent the best estimate.  The task force
       used four different models to predict the phosphorus target
       loads for the lakes with each model producing similar results.
       Considering the error inherent in the modeling process, coupled
       with the discrepancies among the four models used, the task
       force estimated that the range of uncertainty for Lakes Erie
       and Ontario target loads is plus or minus 30 percent and
       20 percent, respectively.  (According to EPA, the amount of
       error associated with models has since been reduced.)

     Although the task force was not  able  to quantify all the
errors or uncertainties surrounding the phosphorus  issue, the
two  errors it measured (estimated actual  loads  and  target loads)
alone  could  justify program decisions ranging from  doing no
additional cleanup work to  instituting massive  new  programs.
For  example, the  best estimate for Lake Erie required reducing
phosphorus inputs by an additional 3,700 metric tons per year
if treatment plants achieved the discharge goal of  1.0 mg/1.
However, because  of-the mathematical  uncertainty, the estimates
of control needed ranged from no additional reductions to
reducing inputs by another  9,400 metric tons per year.  For
example, on  Lake  Erie the target load could be  as high as 14,300
metric tons  if the high range is accepted.   Conversely, the  load
after  municipal treatment plants achieve  1.0 mg/1 could be as
low  as 12,495 tons  (minus 15 percent).   Therefore,  no additional
phosphorus reductions would be required for Lake Erie.
                                   22

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     According to the Canadian Chairman of the IJC Water  Quality
Board, if the figures are viewed optimistically,  they indicate
that all that is needed is to achieve the 1.0 mg/1 point  source
phosphorus discharge limit on municipal sources.  Conversely, if
the worst case is considered, much stricter point source  controls
and nonpoint source programs would be needed.

     The 1978 water quality agreement requires the two countries
to establish phosphorus loads and compliance schedules within 18
months after the effective date of the agreement.  It was not
until May 1981, however, that representatives from the two
Governments met to negotiate the details of a phosphorus  supple-
ment to the agreement.  The result of that meeting was a  draft
document entitled "Phosphorus Load Reduction Supplement to Annex
3 of the 1978 Agreement Between Canada and the United States of
America on Great Lakes Water Quality."  The agreement still has
not been finalized between the two countries.  In the phosphorus
supplement being proposed, the Governments basically are
(1) agreeing about the target loads in the Phosphorus Management
Strategies Task Force report and (2)  beginning the process of
allocating the loads and establishing completion  schedules for
each country.  In addition, the Governments are proposing that
all municipal wastewater treatment plants discharging more than
1 million gallons per day achieve compliance with a  1.0 mg/1
effluent concentration (on a monthly average basis).  The Govern-
ments also recognize that reductions  from nonpoint sources will
be required to meet the phosphorus target loads and  have  proposed
measures and programs to accomplish this.

     The Phosphorus Management Strategies Task Force stated that
the next major decision point in the  phosphorus management pro-
gram for the lakes advocated by the task force should be  in about
5 years and that the Governments should use this  time to  resolve
or reduce the uncertainties concerning the extent, timing, and
type of phosphorus controls needed.  In addition  to  the problems
created by the task force's inability to calculate phophorus in-
puts to the lakes and set valid target loads, other  uncertainties
remain which could have a significant impact on the  selection of
an optimum phosphorus control strategy.  For example, questions
about (1) the extent to which different phosphorus forms  contrib-
ute to algae growth, (2) the contribution of tributaries  to
phosphorus loads, (3) shoreline erosion contributions to  phos-
phorus inputs, and (4) the extent to  which the atmosphere con-
tributes to phosphorus inputs all remain unanswered.  As  dis-
cussed in appendix V, obtaining definite information regarding
any one of these issues could drastically affect  the types and
extent of programs needed to control  the phosphorus  problem.

     Needed research efforts may not
     be undertaken or coordinated

     The IJC Phosphorus Management Strategies Task Force  reported
in 1980 that its efforts to resolve the uncertainties surrounding
phosphorus pollution and control were hampered by its inability

                                23

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to conduct its own research.   For the future,  the task force
recommended that a permanent organization be established within
IJC and given the responsibility for continually analyzing  and
refining information concerning target loads,  availability  of
phosphorus for algae growth,  benefits and costs  of control  meas-
ures, and other related phosphorus issues.  According to the
Chief of GLNPO's Environmental Planning Staff, such a group has
not been established within IJC.  This official  further stated
that a coordinated approach to dealing with phosphorus-related
research issues does not currently exist.

     EPA, as the lead U.S.  agency on agreement matters, is
responsible for coordinating research efforts and ensuring  that
the principal U.S. research funding agencies consider identified
Great Lakes research needs  as part of their organizations'
research programs.  In 1974 we issued a report ^/ critical  of
EPA's research coordination efforts and calling  for stronger EPA
leadership to improve Great Lakes research coordination.  EPA's
research coordination efforts since then generally have been
limited, informal, and have not ensured that agreement commit-
ments are met.  For example,  according to the Director of EPA's
Large Lakes Research Station, since 1975 the station's coordina-
tion efforts primarily have involved periodic meetings with two
other research facilities—NOAA's Great Lakes Environmental
Research Laboratory, and the Department of the Interior's Great
Lakes Fisheries Laboratory.  In addition, the EPA official  said
that, beginning in May 1981,  U.S. and Canadian directors of
various research organizations have met under the aegis of  IJC
to discuss research projects, data collection methods, and
interpretations of research results to prevent overlapping
research.  The official said that meetings are informal—
agendas, meeting minutes, or other documentation are not pre-
pared.  The Director of EPA's Environmental Research Laboratory
agreed that formal coordination among EPA, the States, and  other
Federal agencies, including NOAA, does not occur.  This official
cited an example in which three research laboratories funded by
three different Federal agencies and located within 50 miles of
one another in one of the Great Lakes Basin States were doing
similar research work.

     In 1980 EPA developed  a draft of a research strategy and
5-year plan in conjunction  with the Argonne National Laboratory
and two EPA laboratories.  According to the Director of EPA's
Environmental Research Laboratory, the EPA plan  is in its third
draft and has not been implemented because two of the participat-
ing laboratories were not funded in fiscal year  1982.  We found
that the EPA plan is limited to the work performed by the three
laboratories and thus it is not a comprehensive, multiagency
JL/"Cleaning North America's Inland Seas:   A Study of Federal Water
  Pollution Research and Demonstration Programs on the Great Lakes"
  (Vol. II, B-166506,  Jan.  16,  1974).

                               24

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strategy and plan for all Great Lakes research.   Officials with
the Great Lakes Basin Commission told us that an overall plan is
needed to identify research needs,  establish priorities, and
coordinate efforts, but that such a plan has not been developed.

     The National Ocean Pollution Research and Development and
Monitoring Planning Act of 1978 (Public Law 95-273)  gives NOAA
the responsibility to develop a 5-year plan for the  overall
Federal effort in ocean pollution research and development.
EPA is responsible, however, for providing input to  this Federal
research plan to ensure that Great Lakes research needs, such
as those identified by the IJC Task Force to resolve the uncer-
tainties about phosphorus, are included and receive  attention.

     The first 5-year plan was published in August 1979.  In for-
mally commenting on this plan, the Chairman of the Great Lakes
Basin Commission wrote that the plan was "incomplete,  inaccurate,
and inadequate" and only superficially addressed Great Lakes
issues.  The chairman further stated that the section in the plan
dealing with the Great Lakes was too general to provide a basis
for decisionmaking.  Our review of the plan showed no new specific
research goals and objectives listed for the Great Lakes, no
suggested increases or decreases in funding for existing pro-
grams, and no specific proposals for interagency cooperation.
According to the Deputy Director of NOAA's Office of Marine
Pollution Assessment, the 5-year plan was intentionally made
very general to accommodate the wide range of legislatively man-
dated missions of the various Federal agencies involved in Great
Lakes pollution research.  In the absence of a complete and
effective research plan and strategy for the Great Lakes, the
Great Lakes Basin Commission attempted to provide some leadership
in this area by developing such a plan.  However, the Commission
received no funds for 1982 and shut down its operations in
September 1981.

     NOAA is preparing its next 5-year plan and EPA's input to
that process thus far consists of a small writeup on Great Lakes
research which discusses the activities of two EPA groups—one
primarily involved in Great Lakes research and the other pri-
marily involved in surveillance and monitoring activities.  The
few research activities listed are grouped into very broad areas
with no explanation of what the research is attempting to accom-
plish and how these efforts relate to a coordinated  research
strategy for the Great Lakes.  Further, the EPA input does not
identify any type of priority to be placed on Great  Lakes
research projects, nor does it identify other Federal organiza-
tions that are or need to be involved with Great Lakes research
activities.  The Director of EPA's Environmental Research
Laboratory said that EPA's research process is not geared to
setting priorities for the Great Lakes.  Instead, any priorities
established are in response to EPA program office needs and an
attempt is made to balance regulatory and scientific research
within EPA.  In the absence of EPA's identifying Great Lakes


                                25

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research needs and placing some type of priority on these  needs,
such information is not being provided to NOAA's planning  process.

     On May 14, 1981,  a bill entitled the "Great Lakes Protection
Act of 1981" (H.R. 3600) was introduced into the House of  Repre-
sentatives.  This bill would amend the National  Ocean Pollution
Research Development and Monitoring Planning Act to provide
greater coordination of research efforts concerning the Great
Lakes.  More specifically, the bill would direct NOAA to estab-
lish a Great Lakes research office to identify research needs
and priorities, coordinate federally supported research, and
encourage the utilization of research results and findings.   As
proposed, the bill would set aside for the Great Lakes research
office a part of the funds authorized under the  National Ocean
Pollution Research Development and Monitoring Planning Act.
Since the total amounts authorized under that act would be con-
sistent with previous fiscal year authorizations, the amount  set
aside for the research office would not seem to  require an in-
crease in the Federal budget.

     EPA's efforts to coordinate research have been limited,  and
NOAA's current 5-year research plan contains no  specific research
goals or objectives for the Great Lakes.  Enactment of H.R. 3600,
or similar legislation, would help assure that needed Great Lakes
research activities are pursued and coordinated.

NONPOINT POLLUTION SOURCES
HAVE RECEIVED LITTLE ATTENTION

     In both the 1972 and 1978 water quality agreements, the  U.S.
Government agreed to develop a variety of programs and other
measures for the abatement and control of pollution from nonpoint
sources.  Little attention, funding, and effort  have been  directed
to nonpoint sources, particularly sources contributing toxic  pol-
lutants, even though nonpoint sources in some areas constitute
the majority of the pollutants entering the lakes.  EPA has
focused its planning efforts and funding on point sources, and
recent attempts to plan for and control nonpoint sources have not
been comprehensive or coordinated.  In addition, the resources
devoted to the actual control of nonpoint sources have not been
extensive and have had limited impact.  Without  more attention to
nonpoint sources and a coordinated strategy and  plan for dealing
with them, the Great Lakes water quality objectives may not be
achieved even if all other sources of pollution  are eventually
controlled or eliminated.

Nonpoint sources may contribute
most to Great Lakes pollution

     Nonpoint sources of pollution generally involve the contami-
nation of receiving waters by storm runoff.  Runoff contributes
pollutants from farmlands, forests, urban streets, construction
sites, and mines.  The pollutants are deposited  in streams,
rivers, and lakes in a diffused manner rather than from a

                              26

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specific point.  EPA estimates that nonpoint sources account for
more than half of the pollutants entering the Nation's waters.

     With the exception of Lake Superior, agricultural activities
and urban storm water runoff are the major sources of nonpoint
pollution to the lakes.  In volume, the major nonpoint pollutant
is sediment from soil erosion of agricultural lands.  As erosion
depletes topsoil from the land, the resulting sediment transports
other pollutants, such as pesticides and excess nutrients, into
the waterways.  Runoff from lands used to support livestock also
contributes large quantities of nitrogen and phosphorus.  Urban
runoff contains a variety of pollutants, such as sediment, toxic
materials, oil and suspended grease, and animal litterings.
IJC and EPA have recognized that the deposition of air pollutants
into the Great Lakes is an important source of nonpoint pollution.
A 1981 IJC report shows that some of the pollutants being trans-
ported by air include polychlorinated biphenyls (PCB's), DDT,  and
the pesticide dieldrin, which can seriously threaten human health
or biological resources.  The report further shows that air trans-
port is believed to be a major route of phosphorus and a number
of other substances entering the lakes.

     In 1978 the Council on Environmental Quality reported that
nutrient loadings from nonpoint sources are approximately five to
six times the loadings from municipal and industrial point
sources.  IJC has supported two major studies !_/ to identify all
sources of phosphorus inputs to the lakes and determine their
relative importance.  These studies confirmed that nonpoint
sources are the largest component of the overall phosphorus in-
puts to the Great Lakes.  The table on the following page shows
IJC1s best estimates of the percentage of phosphorus inputs by
source for each lake.
^/International Reference Group on Great Lakes Pollution from
  Land Use Activities, "Environmental Management Strategy for
  the Great Lakes System," Final Report to the International
  Joint Commission, Windsor,  Ontario,  July 1978; and "Phosphorus
  Management for the Great Lakes," Final Report of the Phosphorus
  Management Strategies Task  Force,  July 1980.
                               27

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        1976 Phosphorus Loadings by Source (Percent.)

          	Point	   	Nonpoint	
  Lake    Municipal  Industrial  Total   Air  Upstream Land  Total

Superior       7          3       10      37       0      54     91

Michigan      39          5       44      26       0      30     56

Huron         11          2       13      23      14      50     87

Erie          39          3       42       4       6      49     59

Ontario       24          2       26       4      41      31     76

     As shown, nonpoint sources are estimated to  contribute the
greatest amount of phosphorus to all five Great Lakes,  accounting
for 74 percent overall.  Land uses (primarily farming)  account
for about 50 percent of the total input on three  lakes and about
30 percent on the other two.  However, as discussed on pages  16 to
19, the major emphasis in controlling phosphorus  pollution has
been in point source controls.  EPA's justification for this  is
that the type of phosphorus from nonpoint sources does not
affect algal growth as much as the type from point sources.

     As discussed on pages 20 to 23, uncertainties exist about
phosphorus loadings.  At the same time, however,  much more is
known about phosphorus than is known about toxic  and  hazardous
substances loadings to the lakes from nonpoint sources. IJC
considers toxic and hazardous substance pollution from nonpoint
sources of equal or greater concern than nutrient loadings.

     Whatever the present percentage of the total pollution prob-
lem represented by nonpoint sources, the percentage will only
increase as further progress is made in abating point sources of
pollution.  On June 10, 1981, in testimony before the Subcommit-
tee on Environmental Pollution, Senate Committee  on Environment
and Public Works, we stated that the funds now being  spent to
build facilities to control point sources of pollution may not
have as much impact on improving water quality as originally
believed because nonpoint pollution may be negating or at least
lessening the impact.

Nonpoint control efforts have been
slow and resources devoted minimal

     Various provisions in the Great Lakes agreements address
the need to control pollution from nonpoint sources.   Under the
1972 agreement, the Governments agreed to develop a variety of
programs and other measures for the abatement and control of
pollution from agricultural, forestry, and other  land use activ-
ities and to implement the control programs and measures by
December 31, 1975.  The 1978 agreement removed the target date
for the implementation of control programs and measures but

                               28

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substantially broadened the control requirements for nonpoint
sources to include measures to (1) control soil losses from
all areas, (2) encourage and facilitate improvements in land
use planning and management programs, and (3) abate and con-
trol inputs of toxic substances from nonpoint sources.

     The major U.S. legislation addressing pollution from non-
point sources is the Clean Water Act, as amended.  The act sets
forth specific provisions for nonpoint planning and control
efforts, including (1) grants for the development of areawide
management plans to identify and develop procedures for control-
ling nonpoint pollution sources,  (2) grants for projects to
demonstrate new methods and techniques for the elimination of
pollution in the Great Lakes, (3) long-tern, contracts with rural
landowners and operators for the purpose of installing and main-
taining measures to control nonpoint sources, and (4) the design
and development of a demonstration wastewater management program
for the rehabilitation and environmental repair of Lake Erie.

     Despite the significant provisions in the Clean Water Act
addressing nonpoint pollution problems on the Great Lakes, we
found that overall progress has been limited and slow, as dis-
cussed below.

     Planning efforts have not been
     comprehensive or coordinated

     Areawide water quality management plans authorized by sec-
tion 208(a) of the Clean Water Act, as amended, were intended
to be a primary U.S.  vehicle for addressing nonpoint pollution
problems in the Great Lakes.  This program, which is administered
by EPA, has yet to have a significant impact on nonpoint problems
In 1978 we reported _!/ that although the planning program had
achieved some success, many problems hindered its effectiveness.
We specifically noted that the technical capability to identify
the cause and effect relationship among nonpoint pollution
sources and the expected water quality impacts of various con-
trol techniques still does not exist; planning agencies will not
continue areawide planning without Federal funds; areawide plans,
if developed, may not be implemented because of institutional
problems; and the general public has participated little in the
planning process.

     No funding has been provided for the areawide planning pro-
gram for fiscal year 1982.  However, the Municipal Wastewater
Treatment Construction Grant Amendments of 1981 (Public Law
97-117) authorize the Administrator to reserve up to 1 percent of
the sum allotted and available for construction grants for State
_l/"Water Quality Management Planning Is Not Comprehensive and May
  Not Be Effective for Many Years" (CED-78-167,  Dec.  11,  1978).
                               29

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grants to carry out water quality management  planning,  including
facility and nonpoint measures to meet and maintain water
quality standards.  As noted previously,  however,  funding  has
not yet been provided for the construction grants  programs for
fiscal year 1982.

     Although section 208 planning funds  were for  both  point
and nonpoint planning activities, nonpoint planning has been
emphasized only recently.  For example the 38 water quality
management planning agencies in region V  have obligated about
$14 million for nonpoint planning activities  in  the basin  since
1972, but about $11.4 million of the $14  million has been  obli-
gated since 1979.   In addition,  the nonpoint  portions of most
areawide plans have yet to be completed.

     According to region V Water Division officials, the point
source portions of the areawide plans identify specific point
source problems that need to be addressed and recommend
solutions, but this level of planning does not yet exist on a
broad scale for nonpoint sources.  These  officials said the area-
wide plans do not generally include implementation plans and
strategies to identify and set priorities on  worthwhile projects
and identify best management practices which, if successfully
implemented, would remedy specific nonpoint problems.   According
to region V Water Division officials, the States are preparing
statewide strategies which will identify  worthwhile projects
and rank these projects.  The officials said  the State  of
Wisconsin is finished with its strategy but the  strategies of
the other Great Lakes states are in various stages of completion
and will require more work before EPA can approve  them  uncondi-
tionally.

     Department of Agriculture Soil Conservation Service (SCS)
officials involved with water quality matters stated that  the
Great Lakes States were beginning to make progress in nonpoint
planning efforts but that these plans may remain uncompleted
because the section 208 planning program  has  not been funded in
fiscal year 1982.   These officials further stated  that  a question
remains as to who will coordinate the individual State  plans into
an overall basinwide strategy, should they be completed, because
the primary coordinating mechanism in the Great  Lakes—the Great
Lakes Basin Commission—has been abolished.

     A coordinated nonpoint strategy and  plan for  the Great Lakes
Basin is particularly important because the authority and  respon-
sibility for nonpoint programs and activities in the basin is
spread among several Federal agencies—EPA, the  Army Corps of
Engineers, and the Department of Agriculture—in addition  to
various State and local governments.  In  1981 EPA, the  Army Corps
of Engineers North Central Division, and  the  Soil  Conservation
Service, Department of Agriculture, entered into an agreement to
(1) foster accelerated implementation of  agricultural nonpoint
source controls in Great Lakes Basin areas where such sources
preclude the achievement of phosphorus goals  contained  in  the

                               30

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1978 water quality agreement and (2)  identify critical  areas for
targeting nonpoint control efforts.   Although a good step,  the
agreement does not include Department of Agriculture agencies
other than SCS and only focuses on obtaining acceptance of
reduced tillage practices on certain  soil types in the  south-
western portion of the Lake Erie Basin.   For example, the agree-
ment does not include the Agricultural Stabilization and Conser-
vation Service which manages the Agriculture Conservation Program
and the Rural Clean Water Program, both of which provide up to
75 percent of the cost to carry out needed conservation and
environmental measures.

     Moreover, the Department's Farmers Home Administration pro-
vides water conservation and protection loans for a variety of
activities, including the construction of livestock waste storage
facilities.  Its Science and Education Administration carries out
basic, applied, and developmental agricultural research,  includ-
ing research directed to water quality improvements, through both
inhouse efforts and grants to State agricultural experiment sta-
tions and land grant universities.  These agencies could be of
assistance in developing and carrying out more comprehensive
efforts to address agricultural pollution concerns covered  by the
water quality agreement.

     In our opinion, Great Lakes nonpoint pollution planning
efforts would be greatly facilitated  by a coordinated approach
with a single agency because of the many Federal,  State,  and
local agencies involved in these activities.   Furthermore,  with-
out a central coordinating agency—the Great Lakes Basin Commis-
sion has been disbanded—areawide plans being developed by  the
States and the plans and efforts of other agencies may  not  be
brought together into an overall nonpoint control strategy.

     Control efforts have been minimal

     Very few projects to actually control nonpoint pollution
problems in the Great Lakes Basin have been undertaken  because
only limited funds have been provided for such purposes.  In
addition, the implementation of control efforts or projects
undertaken are usually site specific, the use of some nonpoint
control measures requires new management skills and increased
technical assistance, and the effectiveness and acceptability of
some of the techniques is not known.

     Several Federal programs provide funds for projects to con-
trol nonpoint pollution sources,  but  some of these programs also
serve other purposes, such as the stimulation of agricultural
production.  Therefore, it is difficult to determine the total
number of projects or amount of funds in the basin specifically
directed to nonpoint control efforts.  We found,  however, that
Federal pollution funding for all purposes for fiscal years
1978-80, including funding for nonpoint control and planning
efforts, was very low compared to Federal funding for the
construction of municipal point source facilities during the

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same period.  (See app.  VI.)   This is  particularly  significant,
given that nonpoint pollution sources  may constitute  the majority
of many pollutants entering the lakes.

     The experimental Rural Clean Water  Program authorized by
Public Law 96-108—a major nonpoint pollution control program—
provides an example of limited nonpoint  control efforts to date.
This program,  which provides Federal financial  assistance through
long-term contracts to agricultural producers to voluntarily
adopt practices to control agricultural  nonpoint pollution, was
appropriated only $50 million in fiscal  year 1980 and $20 million
in fiscal year 1981.  Although the Great Lakes  area received
additional consideration in the selection of projects in 1980,
the program has had limited impact. Of  21 projects funded
nationwide, only 2 projects,  valued at $3.5 million,  are located
in the Great Lakes Basin.   In addition,  according to  IJC and the
Department of Agriculture, the implementation program developed
in Great Lakes Basin projects, as well as the projects outside
the basin, are site specific and must  be tailored to  specific
problems identified at each project site.

     Another major nonpoint control program authorized by the
Clean Water Act—the demonstration project program  under sec-
tion I08(a)—has also had limited impact.  Since 1972, EPA has
funded 10 projects, totaling about $9.9  million,  to develop and
implement new methods and techniques for reducing sediment and
related pollutants from rural runoff.  As of December 1981, 6 of
the 10 projects were still active.  No new demonstration projects
have been funded for fiscal year 1982.

     Of the 10 demonstration projects, 7, totaling  about $4.7 mil-
lion in Federal funds, have been in the  Maumee  River  Basin of
Lake Erie.  The GLNPO program administrator for these projects
said that little has been accomplished in the other Great Lakes,
although Lake Ontario has been discussed as a possibility for
locating future projects if EPA region II would cooperate.  The
program administrator said that none of  the demonstration proj-
ects involved toxics aspects of nonpoint pollution  because EPA
has been unable to decide on what type of project could be
demonstrated that would not be too costly.

     According to the Chief of GLNPO's Environmental  Planning
Section, most of EPA's efforts have centered around demonstrating
the feasibility of using minimum or no-tillage  farming practices
at sites identified by the Army Corps  of Engineers  as susceptible
to erosion.  Further, according to the Chief, careful measure-
ment of results has been used to create  and verify  a  computer
simulation model to estimate loading reductions that  can reason-
ably be attributed to the adoption of  modified  tillage practices.

     EPA region V officials question,  however,  the  acceptability
of the practices being promoted by the demonstration  projects and
the willingness of program participants  to continue using such
practices.  They pointed out that minimum or no-tillage practices

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are not suitable for all crops, soils, and climates and EPA has
experienced difficulty in demonstrating phosphorus and sediment
runoff reductions along with equal or better crop yields at
reduced costs through the use of such practices.   For example,
Ohio EPA water quality officials estimated that only about 5 to
10 percent of the farms in the Maumee River Basin currently use
no-tillage practices.  A GLNPO official told us that other
farmers may be reluctant to use no-tillage practices and because
participation in nonpoint control programs is voluntary, program
acceptance may be slow and unpredictable.  Another problem
related to the increased use of minimum/no-tillage practices
pointed out by the U.S. Section of IJC is that such practices may
require greater use of herbicides for the control of weeds.
Also, the Department of Agriculture pointed out that the adoption
of minimum or no-tillage technology is slow because of the need
for new equipment and increased management skills, which necessi-
tates greater technical assistance to farmers.

TOXIC POLLUTION—POTENTIALLY
THE GREATEST PROBLEM

     As early as 1970 EPA and IJC recognized that toxic pollution
is potentially a greater threat to the Great Lakes than eutrophi-
cation.  Toxic pollution could endanger human health, destroy
Great Lakes commercial fishing, and ultimately render the lakes
useless for a variety of desirable activities.  The 1978 water
quality agreement emphasized the toxic pollution problem and
required the Governments to meet specific toxic control objec-
tives.  Great Lakes toxic pollution has yet to be comprehensively
addressed, however,  because too little is known about the nature,
extent, and source of such pollution.  Likewise,  toxic control
programs are only in their infancy and their effectiveness is not
yet known.

Emphasis on toxics is relatively new

     While the 1972 agreement required the United States and
Canada to control toxic substance pollution, the  emphasis was
clearly on eutrophication control.  The agreement provisions con-
cerning toxic and hazardous polluting substances  were limited and
very general.  Since the agreement emphasized eutrophication con-
trol, the United States and Canada concentrated efforts in that
area and little was done about toxic substance pollution.

     When the water quality agreement was renegotiated in 1978,
it gave increased emphasis to the problem of toxic and hazardous
substance pollution.  The 1978 agreement expanded the Governments'
responsibilities by including specific objectives for certain
known, persistent toxic substances,  and requiring the development
of lists of hazardous and potentially hazardous polluting sub-
stances and the development of general programs to control them.
It also called for monitoring and research programs to determine
the sources,  fate,  and effects of toxic substances in the Great
Lakes .

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Nature, extent,  and source
of toxics are undefined

     Neither IJC,  EPA,  or other concerned  organizations have
quantified the toxic substance pollution problem in  the Great
Lakes or addressed the  questions needed  to make  effective toxic
control decisions.  However,  the potential harm  of toxic sub-
stance pollution has been demonstrated by  its  effect on the Great
Lakes fishing industry.  According to the  Acting Chief of GLNPO's
Remedial Programs Staff,  toxic substances  in fish have already
severely reduced commercial fishing for  some preferred species on
the Great Lakes, and if the Food and Drug  Administration reduces
the allowable amount of PCB's in fish, as  proposed,  commercial
fishing could be further reduced.

     In its 1975 annual report, IJC stated that  too  little was
known about toxic substances—identity,  sources, amounts present,
characteristic forms and behavior, and effects.   The report went
on to say that research was required to  enable the establishment
of objectives and the evaluation of potential  hazards. While
IJC and EPA have given increased attention to  the problem of
toxic substance pollution in the Great Lakes,  many questions
about toxic substances remain unanswered.

     In fiscal year 1981, the IJC Toxic  Substances Committee
reported that more than 30,000 chemical  compounds were produced
in the Great Lakes Basin.  To date over  450 of these chemical
compounds have been found in the lakes.  Some  of the compounds
identified are known to be toxic, but the  environmental and human
health effects of many others are as yet unknown.  In  addition,
IJC reported that other toxic and hazardous substances will
undoubtedly be found as detection methods  improve.

     Information on some of the "traditional"  toxic  substances,
such as DDT, mercury, and PCB's, has been  available  for some  time
because these substances have been studied fairly well, and some
control measures implemented.  In 1980 the IJC Water Quality
Board reported that the levels of PCB's  and DDT  in Great Lakes
fish have begun to decline and attributed  this decline to the
controls implemented.

     Lack of data is a major stumbling block to  U.S. efforts  to
control toxic substance pollution.  For  example, in 1980 the  IJC
Committee on the Assessment of Human Health Effects  of Great
Lakes Water Quality reported that of 381 chemical compounds ex-
amined, data to allow for meaningful toxicity  evaluations was
available for only 89 compounds.  Even for the 89, the committee
said that much more information was needed to  set acceptable
exposure levels and allowable limits for the  safe consumption of
fish.  Although the committee originally was asked to  gather
exposure data in  1978, in November 1980  the acting chairman told
IJC that little progress had been made in gathering this data
because monitoring and research efforts  had not provided  the
needed information.

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     Delays in EPA's open lake fish monitoring program have
hampered U.S. efforts to identify toxic substances and track the
lakes' status.  Toxic substances are generally present at very
low concentrations in the lakes and accumulate in certain fish
over time.  By analyzing the tissue of fish caught in the open
lake, EPA can determine the lake's status concerning toxics and
determine trends and the general effectiveness of control pro-
grams.  According to the Chief of GLNPO's Surveillance and
Research Staff, EPA has a 3-year backlog (1978,  1979,  and 1980)
of fish samples from all five Great Lakes to be tested.   The
backlog resulted because funds were not available to develop the
laboratory capability to do the testing.   The Chief said EPA has
now developed the capability to test these samples and plans to
gradually reduce the backlog.  Michigan environmental officials,
however, questioned the value of testing 3-year old fish samples
because the fish have suffered some dehydration and any test
results may not be accurate.

     Limited laboratory capability is also a major problem affect-
ing monitoring for toxic substances in the Great Lakes.   The Chief
of GLNPO's Surveillance and Research Staff said that the United
States currently lacks the personnel and equipment to adequately
monitor for toxics.  He said that the problem would probably be
solved by the forces of supply and demand but estimated that it
would take several years.  In 1980 the Great Lakes Water Quality
Board advised IJC that all jurisdictions along the lakes were
having problems funding the needed analytical capacity and capa-
bility.  The board concluded that the increasing demands for com-
plex analyses, sophisticated equipment, and skilled staff must be
met, or timely and accurate toxic pollution information will not
be available and control programs will be hindered.

     In January 1981 IJC issued "Special Report on Pollution in
the Niagara River" to the Governments in which it expressed con-
cern with the extent of pollution from toxic and hazardous sub-
stances as well as the unknown impact of the pollutants  on the
Niagara River and Lake Ontario.  IJC also pointed out (1) the
need for a comprehensive study to identify the sources,  concen-
trations,  fate, and probable effects of these pollutants so that
the seriousness of the problem could be assessed and required
remedial actions pursued and (2) the need for a comprehensive and
continuing monitoring program which would allow a better under-
standing of interactions among pollutants for which agreement
objectives or human health or biological criteria do not yet
exist.  The Governments have yet to respond formally to the IJC
report, but they have consulted and have begun to take correc-
tive action beginning with designating the Niagara area as a
priority area for remedial action.  In addition,  the Governments
are proceeding with further efforts to identify and characterize
the significant sources of persistent toxic substances entering
the Niagara River, and interagency consultations involving EPA,
the New York Department of Environmental Conservation,  the
Ontario Ministry of the Environment, and Environment Canada have
been increased in an effort to expand remedial efforts.   Although

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corrective action has begun,  several  questions  and  issues  raised
by IJC have yet to be comprehensively addressed and the  effec-
tiveness of those corrective  actions  already being  pursued is
unknown at the present time.

Effectiveness of control efforts unknown

     Just as information about toxic  substance  pollution is needed
to design control programs, information about toxic control programs
is needed to determine their  effectiveness.   By the end  of fiscal
year 1981, no overall analysis of U.S.  toxic substance control pro-
grams had been completed.

     Early in 1980,  IJC's Water Quality Board formed a Toxic
Substances Committee to evaluate the  effectiveness  of existing
programs.  In a November 1980 report,  the  committee stated that the
United States has an adequate legislative  base  to protect  people
and the environment from toxic substances  but the committee was
unable to assess the effectiveness of programs  under this  legisla-
tion.

     In testimony before IJC, the New York representative  to
the IJC Water Quality Board  stated that the  Government's failure
to recognize the need for an  integrated approach to control
toxics has been devastating.   He pointed out that to date  both
U.S. and Canadian toxic efforts have  been  piecemeal and  such an
approach cannot control the discharge of toxic  substances.   In
1980 the Great Lakes Basin Commission reported  similar findings.
The Commission stated that a  major shortcoming  to controlling
toxic substances is the lack  of sufficient coordination  and inte-
gration among State and Federal programs.  For  example,  the Com-
mission said that confidential information on toxic substances
production collected by EPA  is not available to the States, which
need it for effective State programs.   Without  this information
the States must create their  own data programs, which places an
added burden on both the States and industry.

     In a report released at  IJC's November  1981 annual  meeting,
the Toxic Substances Committee reported that an overall  strategy
for toxic substances control  activities does not exist and there-
fore the overall management of toxic  substances control  programs
is difficult.  The committee  reported that control  programs were
fragmented, which resulted in incomplete program coverage,  dupli-
cative activities, or limited impact  on emerging problems.   The
report also stated that actions are being  taken in  the United
States to improve toxics coordination at the Federal and State
levels.  Specifically, EPA is developing a toxic substances
integration strategy and EPA regional offices as well as many of
the States have developed internal coordination mechanisms to im-
prove integration.  However,  these programs  are in  their initial
stages of development and the extent  to which they  will  be able
to effectively coordinate toxic substances programs remains to
be seen.
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     In addition to improved coordination among the various toxic
substance control programs, the United States needs to understand
how conventional wastewater treatment affects toxic pollutants
and take advantage of possible benefits.   EPA's pretreatment pro-
gram to control toxic industrial pollution is an example of a
control measure that could provide these benefits.   Both U.S.
legislation and the 1978 agreement require the Government to
establish requirements to pretreat industrial wastewater con-
taining toxic pollutants before they are discharged to municipal
wastewater treatment plants.

     In a fiscal year 1982 report I/ on EPA's industrial pre-
treatment program, we reported that although the program was
authorized in 1972, it has yet to be fully implemented.  As of
December 15, 1981, EPA has issued final standards for only 2
industries and has proposed standards for only 13 of the other
32 industries required to be regulated by U.S. law.  The report
concluded that the delays were at least partially due to the lack
of data about the nature and source of toxic substances, their
impact on the environment and health, or the effectiveness of
available treatment measures.  For example, an EPA study found
that conventional wastewater treatment technologies effectively
remove some toxic pollutants, but the source of these pollutants—
storm runoff, industrial discharges, or other sources—was not
identified.

EFFECTIVE WATER QUALITY MONITORING ACTIVITIES
HAVE NOT BEEN DEVELOPED AND IMPLEMENTED

     Accurate, reliable data describing existing water quality
conditions and trends, how pollution occurs, and the effect of
eliminating sources of pollution is essential to control efforts.
EPA monitoring efforts, however, have been hampered by funding
constraints and questions have been raised about their adequacy.
Also, the IJC has yet to endorse the Great Lakes International
Surveillance Plan, advocated in the agreement as the model for
monitoring activities in the Great Lakes Basin, because the
Commission has not concluded whether the plan is scientifically
effective and managerially implementable.  Comprehensive and
scientifically valid monitoring efforts are needed  if Great
Lakes pollution problems are to be identified, control strate-
gies are to be developed, and the effectiveness of control
measures are to be evaluated.

Importance of monitoring recognized
in water quality agreement

     The 1978 agreement devotes an entire section to monitoring
and requires the United States to
!_/"A New Approach Is Needed for the Federal  Industrial
  Wastewater Pretreatment Program" (CED-82-37,  Feb.  19,  1982).

                               37

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     —determine if pollution control  requirements  are being met;

     —identify and report on instances where agreement  objec-
       tives are not being achieved;

     —evaluate water quality trends  in order to assess  the
       effectiveness of remedial and preventive  measures, assess
       enforcement and management strategies, and identify the
       need for further technology and research  activities; and

     —identify emerging problems in order to develop and imple-
       ment appropriate pollution control  measures.

The agreement also requires the United States to develop monitor-
ing programs which will allow assessments  of  (1) inputs  from
tributaries, point source discharges,  the  atmosphere, and con-
necting channels and (2) whole lake data for  nearshore areas,
open waters of the lakes, and fish and wildlife  contaminants.

     The benefits of good monitoring have  been well  established.
IJC has reported that early measurements of phosphorus content
in the lakes led to phosphorus controls being implemented
basinwide.  Monitoring PCB levels in  fish  led to the closing of
Green Bay commercial fisheries, and water  quality surveys of the
Cuyahoga River demonstrated the need  for more stringent  indus-
trial and municipal effluent controls.  According to an  environ-
mental advisor to IJC, reliable and comparable monitoring data is
needed to arrive at correct conclusions about the state  of the
lakes so that intelligent decisions about  their  future can be
made.

Existing Great Lakes monitoring activities
have been constrained and criticized

     Since 1969 IJC has repeatedly called  for the Governments to
pay more attention to monitoring needs. For  example, in February
1977 IJC reported that

      "The Commission has * * * in the past emphasized to
      the Governments the need to implement a comprehensive
      water quality surveillance and monitoring  program  to
      provide the information necessary to identify water
      quality issues, to assess the achievement  of  water
      quality objectives, and to relate achievement or
      non-achievement of objectives to a particular cause.
      The Commission reiterates the need for  adequate sur-
      veillance and monitoring of water quality  and * *  *
      longterm funding * * *."

     In a January 1981 interim report  to the  Governments, IJC
again concluded that adequate water quality monitoring is a
cornerstone to successful implementation of agreement require-
ments , but that substantial concerns  cloud the Governments'
ability to meet the intent of the agreement.   IJC raised concern

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that the surveillance and monitoring plan followed by the
Governments in the Great Lakes may not satisfy the specific
information and reporting requirements for the four purposes  of
surveillance specified in the agreement,  and may have been con-
strained in its development by budgetary  considerations to the
detriment of ensuring the satisfaction of agreement requirements.
IJC also expressed concern with the adequacy of analytical
resources needed to accommodate the increased and more complex
Great Lakes water quality monitoring activities.

     Funding constraints have affected EPA's ability to meet  its
Great Lakes monitoring responsibilities.   For example,  EPA's
Great Lakes Fish Monitoring Program, a cooperative effort among
nine State and three Federal agencies throughout the Great Lakes
Basin, includes both open lake and nearshore fish monitoring.
Its three objectives are to (1) identify  environmental problems
and public health concerns by determining contaminant levels  in
Great Lakes fish, (2) evaluate the effectiveness of remedial
programs in controlling sources and distribution of toxic sub-
stances, and (3) detect new problems by scanning appropriate
samples for the presence of a wide range  of contaminants.

     According to GLNPO's Chief of Surveillance and Research,
timely testing of fish samples is essential for measuring the
levels and extent of toxic contaminants.   However,  EPA has a
3-year backlog of fish samples because lack of funds precluded
it from contracting with a testing facility.  Although the sam-
ples may still provide valid data, the Chief said that a 3-year
data gap means trend data is not being established and toxics
harmful to the environment may remain undetected.

     Other EPA monitoring activities have faced funding conr
straints.  In 1976 EPA completed its open lake water quality
monitoring but did not do river mouth or  nearshore monitoring.
(Nearshore conditions change often and must be monitored
regularly to get good data.)  In 1977 EPA completed an esti-
mated one-third of the open lake monitoring and approximately
one-half of the nearshore program, but water supply intake and
river mouth monitoring was not done.  In  1980 EPA met its
requirements for open lake monitoring but completed less than
20 percent of its nearshore program.

     Because of anticipated budget cuts,  GLNPO will not be able
to fund some monitoring functions in upcoming fiscal years that
are essential to the overall monitoring strategy on the Great
Lakes.  GLNPO's Chief of Surveillance and Research said that
budget cuts for fiscal year 1983 will result in the elimination
of open lake monitoring scheduled for Lake Superior.  In addi-
tion, State agencies anticipate cutbacks  in their monitoring
programs.  In Michigan, for example, funding problems will result
in the State's scrapping most of its tributary monitoring activi-
ties.  Since Michigan tributaries feed into four of the five
Great Lakes, cessation of tributary monitoring will reduce the
ability of the United States to measure progress toward achieving

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agreement objectives and to identify problem areas.   The  GLNPO
Chief said that not being able to measure tributary loadings  will
keep EPA from using models to determine how the  Lakes are respond-
ing and thus from establishing trend data.

Questions raised about
proposed monitoring plan

     The 1978 agreement calls upon the Governments  to design  and
implement a strategy to coordinate and plan monitoring activi-
ties.  A prototype Great Lakes International Surveillance Plan
was developed by the IJC Water Quality Board as  early as  1975,
but IJC has yet to endorse a final plan.

     IJC refuses to endorse the present GLISP because, as stated
in a January 1981 report, the IJC "has not concluded whether
GLISP represents a scientifically effective and  managerially
implementable plan to obtain and assess the data required by
(the agreement)."  Major problems with the plan  include

     —sampling time frame and location biases which could
       produce unrealistic estimates of sampled  substances,

     --inconsistent sampling techniques which could result
       in noncomparable data, and

     —omissions of key components which could result in
       the failure to monitor certain elements directly
       affecting the quality of water in the lakes.

In commenting on the GLISP, an environmental advisor to IJC
stated that:

      "Overall, the plan reads as though it were a  eutrophi-
      cation study to which has been added anything and
      everything somebody thought we ought to know  about
      toxic substances. * * * The frequencies of sampling *  * *
      the station choices, data handling procedures, ration-
      ales for what is done and where are unexplained.
      Basically one has a phosphorus plan with an associated
      menagerie of chemical tests."

     Timing and location bias distort data

     Knowing when and where to take water quality samples is
important for comparable and meaningful water quality measure-
ments.  Sample timing bias is demonstrated by the GLISP specifi-
cations for nearshore monitoring.  Although the  plan requires
samples of nearshore water conditions three times annually—in
spring, summer, and fall—it does not specify the month,  day, or
hour for the sampling.  An environmental advisor to IJC believes
that jurisdictions and agencies doing monitoring could schedule
their activities-based on the availability of vessels, facili-
ties, and personnel and not on the basis of the  best or most

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 critical  times  for  sampling nearshore conditions.  Unreliable or
 misleading  trend data  and overlooked water quality problems or
 changes could result.

      GLISP  tributary monitoring requirements provide an example
 of sample location  bias.  Environmental advisors to IJC criti-
 cized the plan  because in instances where two or more streams
 or rivers meet, the plan does not require monitoring of the
 tributaries above that meeting point.  Rather, samples are to
 be taken  below  or right at the meeting point.  One advisor
 believes  that failure  to sample above the meeting point prevents
 assessing where specific pollutants originated.  Another advisor
 agreed with this observation and said that because tributaries
 represent a major transport mechanism for many point and nonpoint
 pollutant loads to  the Great Lakes, monitoring tributaries at
 improper  locations  will result in an inability to accurately
 quantify  the inputs to the lakes, as well as an inability to
 identify  specific sources of pollutant inputs in the basin.

      A water quality consultant who reviewed the GLISP said that
 data  obtained from  tributary monitoring may not be useful because
 sampling  sites  are  located at distances too far away from cities
 and industries  to identify loadings to the lakes from municipal
 and industrial  sources.  He said to accurately assess pollution
 from  tributaries, samples should also be taken at the river mouth
 (where the  river flows into the lake), not at an isolated site
 upriver of  major cities and industries.  An examination of sam-
 pling locations for Lake Erie specified in the plan shows that two
 sites—the  Maumee and  Sandusky Rivers--are located at least
_20 miles  from Toledo and Sandusky, two large Ohio cities situated
 at the river mouths.   The map in appendix VII taken from the
 GLISP shows that most of the sampling sites in the United States
 and in Canada generally are substantially upriver from the
 lakes.

      Inconsistent sampling makes
      data noncomparable

      Data comparisons -are facilitated when the number of samples
 taken and the way they are taken are identical.  However, the
 GLISP does  not  require the various State and Federal monitoring
 agencies  to use the same techniques and the results may not be
 comparable.  According to environmental advisors to IJC, because
 the data  may not be comparable, data users may not be able to
 gain  the  overall basin perspective so important in making deci-
 sions affecting the Great^ Lakes.

      A water quality consultant told us that GLISP requirements
 for monitoring  nearshore fish contaminants in Lake Erie do not
 provide for collecting consistent, comparable data.  He found
 that  the  monitoring requirements differed for each of the four
 States performing monitoring on Lake Erie.  He also found that
 (1) the times for monitoring nearshore conditions are not
 defined,  (2) the species sampled and number of samples may differ

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for each State even when sampling  is  done on the  same lake, and
(3) the types of samples taken (for example, fillet versus whole
fish) and the contaminants  analyzed differ.  For  Ohio, for
example, under the categories of time sampled, species to be sam-
pled, number of samples,  and sample type, the GLISP shows "N/A" or
"not applicable."  The consultant  believes that problems in the
fish sampling program,  such as those  identified above, will pro-
duce monitoring data which  cannot  be  meaningfully compared and
interpreted.

     Omissions from the plan result
     in incomplete monitoring

     Major omissions from the plan may further limit the GLISP's
usefulness.  For example, IJC has  had reservations for years
about using the herring gull as the sole indicator of how pollu-
tants affect wildlife.   The current GLISP, however, does not pro-
vide for sample monitoring  of other birds and animals.  Further,
the GLISP does not provide  for monitoring ground  water that seeps
into the lakes, does not examine the  relationship of wetlands to
the lakes, and does not require sampling of tributary sediments
which may release pollutants into  the lakes.

     The answers to many eutrophication, nonpoint source, and
toxic questions might be provided  by  an adequate  surveillance and
monitoring program.  Such a program has yet to be developed and
implemented, however, despite the  importance placed on such a
program in the 1978 Great Lakes Water Quality Agreement.

CONCLUSIONS

     Progress is being made in cleaning up the Great Lakes, but
the United States has experienced  difficulty in meeting its
water quality agreement commitments.   A variety of factors has
hindered U.S. efforts, but  if the  United States is to meet its
commitments to protect the  Great Lakes, greater and more compre-
hensive efforts will be needed. Municipal sources of water
pollution will not be controlled by the December  31, 1982, agree-
ment goal and it may be many years before such sources are com-
pletely controlled.  Agreement phosphorus control objectives are
not being met for both municipal and  nonpoint sources, and deter-
gent phosphorus limitations have met  with controversy.  At the
same time, however, the need for greater phosphorus controls is
clouded by possible uncertainties  about phosphorus inputs to the
lakes and the target phosphorus loadings established  for the
lakes.  Research needed to  resolve these potential uncertainties
has not been pursued and coordinated.

     Although the water quality agreement emphasizes the need  to
control nonpoint sources of water  pollution, which may be the
largest contributor to pollution in the lakes, such sources have
received little attention.   Nonpoint  planning efforts under EPA's
areawide water pollution planning  program have not been completed,
Federal program funding has been terminated, and  the  primary

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coordinating mechanism—the Great Lakes Basin Commission—has
been abolished.  Actual nonpoint control efforts in the basin
have generally been experimental and an overall  control strategy
or plan has not been developed.   Likewise,  although the 1978
water quality agreement emphasized the control of toxic pollu-
tion and set forth specific objectives, an  overall toxic control
strategy has not been developed.  The nature,  extent,  and sources
of toxic pollutants in the lakes remain relatively undefined,
and little is known about the effectiveness of the few control
efforts implemented to date.

     Given the many uncertainties and the lack of information
about many eutrophication, nonpoint sources, and toxic pollution
issues included in the water quality agreement,  an overall  Great
Lakes surveillance and monitoring plan is needed.   Despite  the
importance placed on the need for a basic framework for monitor-
ing activities in the water quality agreement, an overall plan
has yet to be approved.  Also,  EPA's monitoring  efforts have been
hampered by funding constraints and, in some instances, the ade-
quacy of the efforts has been criticized.  Unless an adequate,
scientifically valid plan is developed and  implemented, many
questions about Great Lakes pollution matters will likely remain.

RECOMMENDATIONS TO THE CONGRESS

     The United States and Canada are not required to  make  a com-
prehensive review of the operation and effectiveness of the 1978
agreement until the IJC issues its third biennial  report in 1986.
Given the lack of U.S. progress in meeting  its commitments  under
two water quality agreements, we recommend  that  the Congress, in
consultation with the Secretary of State and the Administrator,
EPA, determine (1) whether the 1978 Great Lakes  Water  Quality
Agreement objectives and commitments are overly  ambitious and
(2) whether sufficient funding to meet agreement objectives and
commitments can be provided given current economic and budgetary
conditions.

     In view of the need to resolve the many uncertainties
associated with the Great Lakes water quality issues and agree-
ment objectives, we further recommend that  the Congress pass
legislation currently pending which would amend  the National
Ocean Pollution Research and Development and Monitoring Planning
Act of 1978 to require NOAA to establish a  Great Lakes research
office.

RECOMMENDATIONS TO THE
ADMINISTRATOR, EPA

     We recommend that the Administrator,  EPA,  direct  GLNPO to
develop a comprehensive plan and strategy to address phosphorus,
nonpoint, and toxic pollution problems  in the Great Lakes Basin.
In developing such a plan and strategy,  the  Administrator should
direct GLNPO to:
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     —Revise its interagency agreement with the Army Corps of
       Engineers and SCS to include other  Federal  agencies
       with responsibilities for nonpoint  programs affecting
       the Great Lakes.

     —Serve as the coordinating mechanism for  Great Lakes Basin
       water quality plans being developed by areawide  agencies
       and the States; work with the States and areawide planning
       agencies to ensure completion of the nonpoint portions of
       the plans; and consolidate the individual State  and area-
       wide plans into an overall basin plan.

     —Enter into an interagency agreement with NOAA to define
       the duties and responsibilities of  EPA and  NOAA  concerning
       Great Lakes research activities, including  specific respon-
       sibilities for (1) developing an inventory  of needed
       research on phosphorus and toxic pollution  control issues,
       (2) setting priorities on identified research- needs and
       incorporating such needs in NOAA's  Federal  ocean pollution
       research and development plan, and  (3) coordinating the
       research efforts  of agencies involved in Great Lakes
       matters to ensure that work undertaken addresses identi-
       fied needs.

     We also recommend that the Administrator,  EPA, direct GLNPO
to develop a surveillance and monitoring plan for  the U.S. por-
tion of the Great Lakes.  Such a plan should (l) delineate the
roles and responsibilities of various Federal,  State, and local
agencies involved in Great Lakes surveillance and  monitoring
activities, (2) include  methods and procedures  to  ensure that
monitoring activities are carried out promptly  and that the
data gathered is complete and consistent in order  to provide
meaningful evaluations and comparative analyses, and (3) include
procedures to ensure that U.S. and Canadian monitoring  efforts
are consistent.

     We recognize that the actions recommended  will  significantly
affect GLNPO.  Chapter 3 discusses GLNPO's role in the  efforts
of the United States under the water quality agreement  and the
need to provide GLNPO with the authority to assure that U.S.
commitments are met.

AGENCY COMMENTS AND OUR  EVALUATION

     We provided a draft of this report to EPA, the  Departments
of State, Agriculture,  and Commerce, and the U.S.  Section of IJC
for review and comment.   The Department of Commerce  provided
comments on the draft, but the comments were not received in
time to be included in this final report.   The  comments of EPA,
the Departments of State and Agriculture,  and the  U.S.  Section of
IJC are included in appendixes IX to XII.   The  agencies' comments
on the matters discussed in this chapter are summarized below,
along with our evaluation of the comments.


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EPA comment.s

     EPA had a number of comments about our understanding  of the
ambitious scope of the 1978 agreement,  phosphorus control  activi-
ties, research, toxics, water quality monitoring,  and  the  organi-
zational level of GLNPO.  EPA's comments are included  in appen-
dix IX.  EPA comments and our evaluation of the  comments on
matters discussed in this chapter are set forth  below.   The com-
ments on the organizational level of GLNPO and our evaluation of
these comments are included in chapter  3.

     Scope of agreement objectives

     EPA is concerned that we do not recognize the scope of the
ambitious objectives of the 1978 water  quality agreement,  which
does not directly control the water quality programs used  to sup-
port the agreement objectives.  EPA pointed out  that Great Lakes
programs are not separately funded under Federal law.   EPA
stated that it realizes pollution problems have  not been solved
but the necessary plans, mechanisms, and facilities are generally
in place and the cleanup is progressing.

     We believe we have fully recognized that the agreement
objectives are ambitious and that U.S.  efforts to meet agreement
objectives are implemented through domestic laws.   For example,
in chapter 1 we state that the 1978 agreement objectives are
comprehensive and stringent and a variety of remedial  programs
and measures are required to meet the objectives.   Chapter 1 also
recognizes that EPA implements Great Lakes activities  through
existing Federal legislation.  Furthermore, in the recommendation
to the Congress we specifically suggest a review of whether the
agreement objectives and commitments are overly  ambitious.

     Phosphorus

     EPA is concerned that we failed to acknowledge the compre-
hensive nature of the agreement's phosphorus objectives and the
numerous Federal and State efforts taken to meet the terms of
the agreement.  EPA also is concerned about our  characterization
of the role of phosphorus in the eutrophication  process and the
subsequent mix of measures to control its input  into the Great
Lakes.  More specifically, EPA stated that:

     --Point sources of pollution produce far more bioavailable
       phosphorus than nonpoint sources and are  relatively more
       important to the control of eutrophication.

     —It should be pointed out that only 15 percent of the total
       phosphorus from major municipal  plants will not be  con-
       trolled by December 1982.
      -The agreement does not define  phosphorus  compliance
       terms of a daily average of 1.0 mg/1.
in
                                45

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     —Detergent phosphate bans,  which must be voluntary in
       nature, have not met with "resistance" by  Great  Lakes
       States.

     —Nonpoint controls,  particularly for phosphorus,  can be
       transferred to other areas.

     We believe we have recognized  the comprehensive nature of
the phosphorus objectives  and the efforts taken to meet them,
as well as the role of phosphorus in  the  eutrophication process.
The report (see pp. 15 to  26)  presents a  comprehensive  picture
of the importance of controls for both point and  nonpoint sources,
the extent to which agreement objectives  for point and  nonpoint
sources are being met, and the extent to  which uncertainties
about phosphorus exist and continue to cloud the  question of the
most effective mix of controls to meet agreement  phosphorus
objectives.

     With respect to the control  of phosphorus from municipal
plants, the agreement objectives  are  not  being met.  The 1972
agreement requires all major municipal plants on  the two lower
lakes to meet a 1.0 mg/1 daily average.   As discussed in this
chapter, the 1972 agreement remains in effect until the Govern-
ments allocate the target  loadings  in the 1978 agreement and
this has yet to be done.  Even using  a 1.0 mg/1 annual  average,
which seems to be the accepted EPA  measurement criteria in
recent years, not all major municipal plants are  meeting this
objective.  Because of demonstrated operational difficulties,
we also question the ability of many  U.S. municipal plants to
meet an annual average of  1.0 mg/1  phosphorus, let alone more
stringent limits which could be imposed in the future to meet
overall phosphorus objectives set forth in the 1978 agreement.

     We do not deny that,  based on  current knowledge, point
sources of phosphorus have a high degree  of bioavailability and
need to be addressed.  Progress in  controlling point sources has
been made.  However, the control  of nonpoint sources of phos-
phorus, as recognized by EPA,  is  an essential part of any phos-
phorus strategy.  But, as  stated  earlier, target  phosphorus
loads have a wide error range and have yet to be  allocated by
the Governments.  In addition, too  many uncertainties exist about
phosphorus inputs to the lakes and  the extent to  which  such in-
puts contribute to algae growth (bioavailability).  The resolu-
tion of such uncertainties could  have dramatic effects  on optimum
phosphorus control strategies, including  the need to meet strin-
gent point source controls.  Consequently, we continue  to believe
that agreement objectives  for both  point  and nonpoint sources of
phosphorus are not being met and  the  overall effectiveness of
U.S. phosphorus control efforts is  not known.

     With respect to "resistance" by  key  Great Lakes States to
detergent phosphorus bans, we believe our overall characteriza-
tion of such bans as "controversial"  is appropriate.  Undoubtedly,
Ohio and Pennsylvania, which cover  a  significant  portion of the

                               46

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U.S. part of Lake Erie (the lake most heavily polluted with
phosphorus) and which have yet to enact detergent phosphorus
bans, are key States.  To this extent,  Ohio and Pennsylvania  have
resisted such bans.  In addition, just because the other  Great
Lakes States have enacted such bans does not mean they are  not
controversial.  In fact,  we believe the higher Canadian limit
on detergent phosphorus contributes to even greater controversy.

     Finally, we agree that our characterization of the tech-
nology for nonpoint control measures as being site specific was
not correct.  As the Department of Agriculture and IJC pointed
out, the technology for nonpoint sources can be transferred but
the implementation of the technology is site specific. We  have
revised the report to correct this matter.

     Research

     EPA strongly supports the need for more effective coordina-
tion of Great Lakes research activities, but is concerned that
H.R. 3600 will fragment EPA's already established mechanisms  for
addressing Great Lakes problems.  EPA points out that it  is
already the primary source of technical and policy expertise  for
the Department of State in its Great Lakes-related diplomatic
negotiations and that it plays key roles on international boards
which advise IJC and the Governments on various research  matters.
EPA believes that H.R. 3600,  if passed, would place responsibility
for research coordination with another agency which has neither
the authority nor the ability to link research needs or the
results with water quality trends or the remedial actions neces-
sary to correct or abate identified pollution problems.   EPA
believes that such action could jeopardize  current efforts  to
develop compatible and coordinated Great Lakes management pro-
grams which are responsive to both domestic mandates and  inter-
national commitments.

     We applaud EPA's strong endorsement for a coordinated  Great
Lakes research program, but we do not agree that only EPA can be
charged with this responsibility.  EPA has  had Great Lakes
research responsibilities in the past and its efforts to  develop
a coordinated program have been limited. Also,  as pointed  out
in this chapter and chapter 3, EPA's own actions in not funding
Large Lakes Research Station at Grosse Isle,  Michigan, raise
questions about its willingness and ability to develop and  carry
out a comprehensive,  coordinated research effort in the future.

     Concerning EPA's belief that separating the research
coordination responsibility from remedial actions to correct  or
abate pollution problems could jeopardize its efforts to  develop
Great Lakes management plans, we note that  EPA's own internal
organization separates the research function from the pollution
abatement and control functions for all of  its programs.  We  con-
tinue to believe that a coordinated Great Lakes research  program
is needed if the many unknowns about Great  Lakes pollution  are


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to be resolved and effective remedial programs implemented.  We
believe H.R. 3600 meets that need.

     Toxics

     EPA generally concurs with our discussion of toxics,  except
for three points.  First,  EPA cites that some evidence indicates
that controls over toxic pollutants can be effective.   Second,
EPA points out that the Food and Drug Administration  sets  allow-
able limits of toxic levels in fish.   And finally,  EPA believes
that the issue of laboratory capacity and capability  is not  an
issue peculiar to t:he Great Lakes.

     We concur with EPA that controls over toxic  pollutants  can
be effective, as evidenced by the declining levels of  PCB's  in
some areas"and the decrease in levels of DDT in Great  Lakes  fish.
However, as discusser1, in the report,  the major problem is  that
too little is known about the overall nature,  extent,  and  source
of toxic substance pollution in the Great Lakes.   The  level  of
control achieved with PCB's and DDT is largely due to  the  fact
that these toxic substances have been carefully studied and  regu-
lated for some time, and consequently more is known about  them.
Further, our report discussion shows that the lack of  information
about toxic substances make it difficult to assess the effective-
ness of control programs currently  in place.

     EPA correctly points out that  the Food and Drug Adminis-
tration, and not EPA, sets allowable limits of toxic  levels
in fish, and we have revised our discussion accordingly.   EPA's
comment that limited laboratory capacity and capability is a
national and worldwide problem may  be true.   It does not alter
the fact, however, that the need for such capacity and capability
is both real and necessary to adequately address  toxic pollution
problems on the Great Lakes and meet agreement objectives.

     Water quality monitoring

     EPA stated that it had serious reservations  about the water
quality monitoring discussion.  Specifically,  EPA stated that:

     —IJC never stated that GLISP  is biased and  incomplete  and
       lacks scientific validity, and IJC has taken no action
       to approve or disapprove the plan.
               — -*
     —GLISP is a framework to be used to determine overall
       program priorities and should not be a rigidly prescribed
       set of activities and timetables.

     —The discussion on tributary  monitoring appears  to be  a
       series of opinions, which do not reflect a full under-
       standing of either the site  selection process  or the
       purpose of tributary monitoring.
                               48

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     —Toxic substances monitoring is  quite  different  from
       phosphorus monitoring and  EPA's strategy is  to  look  for
       toxics in the most probable source  areas, to locate
       hot spots, and to warn the public of  any acute  concentra-
       tions in local fish.

     —The report leaves the reader with the impression that
       much of the data collected through  monitoring is useless
       because it cannot be  compared or verified, and  this  is not
       the case.

     —The discussion of the adequacy  of the Great  Lakes
       Atmospheric Deposition Network  data is not a true  reflec-
       tion of the current situation because at the time  we were '
       gathering our data for the report,  the upgraded network
       was not implemented.

     We agree that IJC never stated that the GLISP  is  biased and
incomplete or lacks scientific validity and  that IJC has  taken no
action to approve or disapprove the plan.  Before sending the
draft report to EPA, we inadvertently  failed to revise the  report
everywhere this language was used.   We have  revised the report
to reflect the actual situation.

     We agree with EPA's position that the GLISP is a  framework
to be used to determine overall program priorities  and should be
responsive to changing environmental conditions and other factors.
But we believe that the report clearly shows that the  GLISP per-
mits wide latitude for a variety  of monitoring activities,  in-
cluding sample timing and location, which  can have  a substantial
effect on consistency.  Inconsistent monitoring makes  data  com-
parisons difficult and creates problems in evaluating  the causes
of pollution and the effectiveness of  various control  measures.

     We disagree with EPA's  comment that the report gives the
impression that much of the  data  being collected is useless
because it cannot be compared. We recognize that EPA  has quality
assurance guidelines and that laboratories participate in perform-
ance reviews, and we are not saying that the data is useless.
Our point is that data is difficult to compare if the  sampling
methods, timing, locations,  and circumstances are not  similar.
We believe that EPA needs to develop a surveillance and monitor-
ing plan for the U.S. portion of  the Great Lakes that  is  consist-
ent with Canadian efforts and which, among other things,  ensures
that the data gathered can be used to  provide meaningful  evalua-
tions and comparative analyses.

     We also do not agree that our discussion of monitoring
reflects a misunderstanding  of either  the  site selection  process
or the purpose of tributary  monitoring.  While the  discussion
does contain opinions, they  are the opinions of environmental
advisors to IJC and a water  quality consultant who  has reviewed
the GLISP and believes it needs improvement.


                               49

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     EPA states that tributary monitoring sites  were selected  to
avoid lake effects, which greatly complicates monitoring  at  river
mouths, and by adding point source loadings  entering the  tribu-
tary downstream from the monitoring sites to the loadings deter-
mined at the monitoring sites,  total loadings to the lakes can
be determined.  This comment,  however,  does  not  consider  nonpoint
contributions to tributaries between the monitoring  site  and the
lakes.  As discussed in the report, nonpoint sources contribute
substantially to total pollution loadings to the lakes and adding
direct discharges between the  monitoring site and the lakes  will
not account for total tributary pollution loadings to the lakes.

     Likewise, we do not agree that effluent monitoring alone
will determine tributary sources of pollution.   Knowing the
source of pollution is important to determining  how  to control
pollution, and failure to sample secondary tributaries could lead
to erroneous assumptions about the source of pollutants.   Also,
the nature of specific pollutants can change as  tributaries  flow
to the lakes, the pollutants may settle out  or combine with  other
pollutants only to be released by a storm or other events, or
they may be masked by other pollutants.  Therefore,  we believe
that improper sampling locations can result  in inaccuracies  in
the identification of both quantities and sources of pollution.

     We agree with EPA's position that  toxic monitoring is
different from phosphorus monitoring and we  agree with EPA's
stated toxic monitoring strategy.  As pointed out, however,  EPA's
toxic monitoring efforts have  been hampered  by a lack of  funding
and the GLISP does not provide for consistent monitoring  in  terms
of location, species, sample timing, and types of samples.   In
addition, although EPA identifies the sampling of sediments  as
an important auxiliary monitoring medium, the GLISP  does  not pro-
vide for the sampling of tributary sediment, which may release
pollutants to the lakes.

     With respect to EPA's comment about its Atmospheric  Deposi-
tion Network, we agree that the upgraded network was not  imple-
mented at the time we gathered our information for the report.
The information provided by EPA indicates that the upgraded  net-
work corrects many of the problems associated with the old
network, and therefore we have deleted  our discussion of  the
Atmospheric Deposition Network from the report.

Department of State comments

     The Department stated (see app. X) that the draft report  did
not include reference to its recent work in  developing a  proposed
supplement to the 1978 agreement on phosphorus control or new
initiatives and cooperative efforts to  deal  with toxic pollution
in the Niagara River.  The Department stated that including
material on these subjects would make the report more useful.

     At the time we conducted  our fieldwork, the phosphorus
supplement was being developed and negotiated and little

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information on the subject was available.  Also, as the Department
noted, the Niagara River cooperative efforts are recent and were
taken after we completed our fieldwork.  We agree, however, that
these matters are important, and we have included them in this
report.  (See p. 23 and pp. 35 and 36.)

Department of Agriculture comments

     The Department's comments (see app. XI) related primarily to
its role in nonpoint pollution activities and the Rural Clean
Water Program.  The Department noted that the coordination of
nonpoint programs in the Great Lakes Basin is a persistent prob-
lem because no formal agreements exist between the Department
and EPA regarding who is responsible for implementing agricul-
tural nonpoint control programs.  The Department also noted that
the primary coordinating mechanism for the lakes—the Great Lakes
Basin Commission—has been abolished and that the Department has
no formal representation on UC boards.  The Department also
stated that good communication exists at informal staff levels
but that no formal arrangements exist.  The Department stated
that it would welcome the opportunity to participate in a coor-
dinated program to correct agricultural nonpoint sources of water
pollution in the Great Lakes.

     We agree with the Department's position on the problem of
coordination of Great Lakes nonpoint activities and the need for
a coordinating mechanism and formal interagency arrangements.
Our recommendations to the Administrator, EPA, address this
matter.

     With respect to the transfer of nonpoint source control
technology, such as minimum or no-tillage farming methods, the
Department stated that although individual water sheds have dif-
ferent characteristics which must be recognized and considered,
such technology can be transferred.  The Department pointed out,
however, that implementation of the technology must be tailored
to the specific site.  The Department also pointed out that
technology such as minimum or no-tillage farming is adopted
slowly because it requires new management skills and increased
technical assistance.

     We agree with the Department's comments on this matter and
have revised the discussion in the report (p. 33) to clarify that
the implementation of technology is site specific, rather than
the technology itself.  We have also included in the discussion
the need for new management skills and increased technical
assistance.

     The Department also suggested some changes to the report to
correct or clarify several matters on its program or activities.
The report has been changed where appropriate to reflect the
Department's suggestions.
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U.S. Section of IJC comments

     The U.S. Section provided detailed comments  on our draft
report.  Most of the comments were technical  and  suggested  clari-
fications of IJC positions or provided additional information on
matters discussed.  Appendix XII  contains the U.S. Section  com-
ments and our evaluation.   Changes have been  made to  the  report,
where appropriate.
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                           CHAPTER 3

              EPA SHOULD GIVE GREATER VISIBILITY

                TO ITS GREAT LAKES ACTIVITIES

     EPA, the lead U.S. agency for carrying out water quality
activities and implementing the Great Lakes Water Quality Agree-
ment, has broad and complex responsibilities requiring it to work
and cooperate with a variety of Federal,  State, and local agen-
cies as well as IJC and Canadian environmental agencies.   EPA's
Great Lakes National Program Office has had difficulty obtaining
the cooperation needed from other EPA offices, other Federal agen-
cies, and the States because it does not have the visibility,
authority, and resources needed to assure that its Great  Lakes
water quality program can compete with other important national
issues.

GREAT LAKES RESPONSIBILITIES
ARE BROAD AND COMPLEX

     Article VI of the 1978 agreement and the attached annexes
call for over 50 programs and other measures to deal with virtu-
ally the entire spectrum of environmental concerns.   In addition
to EPA, many other Federal agencies administer programs or activ-
ities directly affecting the Great Lakes.  (See app. I.)   Three
Federal agencies—the Departments of Agriculture,  Commerce
(National Oceanic and Atmospheric Administration), and Defense
(Army Corps of Engineers)—have major responsibilities for pro-
grams and activities specified in the agreement.  EPA is charged
with coordinating these Federal efforts,  as well as  working with
the eight Great Lakes States which are responsible for implement-
ing and administering many of the Federal environmental programs.
In addition, EPA must work through IJC to coordinate with
Canadian Federal and Provincial environmental agencies.

     The chart in appendix VIII illustrates the tangled network
of interrelationships among EPA, other major Federal participants,
and the Great Lakes States involved in carrying out  agreement
commitments.

     Within EPA, virtually every major program office is respon-
sible for activities covered under the agreement.  In addition to
region V (Chicago), EPA's regions II (New York) and  III (Phila-
delphia) are involved in Great Lakes activities.  Region II is
especially important because it covers the entire U.S.  border on
Lake Ontario and a significant portion of Lake Erie.

     The numerous programs and measures called for in the agree-
ment, and the multitude of entities involved in carrying them
out, require that a high-level office have the authority and the
resources needed to oversee and coordinate the activities of the
various agencies involved.  The EPA office responsible for


                               53

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overseeing and coordinating Great Lakes activities—GLNPO—does
not meet this critical need.

PROBLEMS LIMIT EPA EFFORTS
TO MEET AGREEMENT OBJECTIVES

     Though its lead agency responsibilities  are heavy and
require a high level of visibility,  through the years  EPA has
placed Great Lakes program responsibilities at a relatively low
level within the organization;  thus,  GLNPO lacks the authority
to carry out the broad U.S. mandate  under the water quality
agreement.  In addition, EPA funding of the Great Lakes program
has been erratic.  As a result,  GLNPO has had difficulty carrying
out the Great Lakes program.

Great Lakes responsibilities are
handled at a low organizational level

     The Great Lakes Initiative Program (started in 1973) was
EPA's first attempt to centrally manage an EPA program for  the
Great Lakes.  The program was to serve as the focal point for
coordination of program planning and budgeting within  EPA to
carry out its assigned responsibilities under the agreement. The
program was delayed in fiscal year 1973, however, because (1) EPA
transfered research funds to a higher priority program, (2) not
enough research staff were assigned  to the program, and (3) the
administration impounded $3.5 million in program funds in fiscal
years 1973 and 1974.

     The program relied on a coordination committee made up of
representatives from various EPA headquarters and regional
offices, with the region V administrator serving as the national
program manager.  Under the region V administrator, a  Great Lakes
coordinator with a small staff was responsible for carrying out
program activities.  Most program functions,  however,  continued
to be conducted by other EPA divisions.

     In fiscal year 1978 EPA established GLNPO to administer the
Great Lakes program.  Located in region V, GLNPO was to integrate
and consolidate EPA Great Lakes activities and to provide coordi-
nated support to the IJC Great Lakes Water Quality Board.  GLNPO
is headed by a director reporting to the region V administrator,
who reports to the Administrator of EPA.  The region V administra-
tor is the Great Lakes national program manager and the U.S.
cochairman of the IJC Water Quality Board.

     According to the GLNPO Director, GLNPO was located in  region
V for several reasons.  GLNPO was intended to support  the U.S.
cochairman of the IJC Water Quality Board, who is also the
region V administrator, and such support could be best provided
if GLNPO was a region V office.  Also, because region  V carries
out the major Great Lakes activities, locating GLNPO in region  V
would allow it to work closely with region V  program staffs.


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     According to the U.S. Section of IJC,  the relatively low
priority given to Great Lakes program responsibilities has
caused many of the problems related to fulfilling the require-
ments of the agreement.  Further, the U.S.  Section believes that
there is no incentive for the involved regional offices or asso-
ciated laboratories to attach any particular significance to
agreement activities if a similar commitment is not evident at
the EPA headquarters level.

     Although we understand the rationale for the organizational
location of GLNPO, we agree that the situation has created ser-
ious problems.  GLNPO,  as an EPA national office not administered
out of headquarters, has had difficulty in carrying out some of
its functions and in gaining attention for Great Lakes issues at
the national level.  A 1979 internal EPA evaluation found that
GLNPO

     —lacked a written strategy to tie together all EPA programs
       dealing with the Great Lakes,

     —suffered from uncertainties regarding staff and resource
       levels from one year to another, and

     —needed to further integrate the program with the other
       regions.

     Although GLNPO has prepared documents for fiscal years 1980
and 1981 outlining its goals, objectives, and work plans, we
found that these documents have not been used to assess GLNPO's
effectiveness in achieving the objectives of the agreement.  Had
EPA management compared GLNPO's objectives and accomplishments,
we believe the comparison would have revealed that GLNPO was hav-
ing difficulties achieving coordination and cooperation within
EPA and with other Federal agencies and the States.  These diffi-
culties are discussed below.

Lack of authority frustrates GLNPO's
ability to carry out responsibilities

     In addition to low visibility,  GLNPO lacks the authority
to ensure that those responsible for developing and implementing
agreement programs and measures focus sufficient attention on
them.  As noted previously,  EPA implements nationwide environ-
mental protection activities in accordance with specific Federal
legislation covering air, water, toxic substances, and other
programs.  Great Lakes agreement activities generally are not
funded separately under Federal law, and therefore Great Lakes
agreement activities and programs must take place within the
context of existing Federal legislation.

     Without the authority to specifically direct EPA's, States',
and other Federal agencies'  Great Lakes activities, GLNPO has
been frustrated in its attempts to carry out its responsibilities
for meeting water quality agreement objectives.   The following

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examples of GLNPO's problems in carrying out its responsibilities
were provided by GLNPO officials and staff.   Although we did not
analyze the examples to determine if the decisions  ultimately
made were justified, we do believe the examples demonstrate  the
frustrations GLNPO has experienced.

     In one case, GLNPO attempted to obtain revisions to a
State's annual water quality program plan to provide greater
detail on what the State planned to do to address Great  Lakes
issues.  GLNPO's objective was to determine the adequacy of  the
State's efforts in meeting water quality agreement  objectives.

     The GLNPO director first expressed concerns about the
State's fiscal year 1981 program plan in an August  1980  memoran-
dum to the region V Water Division director.  The memorandum
characterized the State's draft plan as being overgeneralized,
inaccurate, and incomplete.  Specifically,  the memorandum stated
that the plan did not summarize program objectives  and program
outputs or performance measures for Great Lakes activities as
requested in GLNPO guidance.  In January 1981 GLNPO again com-
mented on the specific inadequacies in the State's  program plan
and the corrective actions needed.  Despite GLNPO's objections,
the Water Division director approved the program plan on the
basis of the State's financial needs and what he considered  to
be an inconsequential part of the plan over which GLNPO  expressed
concern.

     The controversy between GLNPO and the region V Water Divi-
sion about the adequacy of the State's program plan resulted in
delays in EPA's approval and funding of the State plan.   State
officials told us that the plan was submitted to EPA 6 months
before the start of fiscal year 1981 but was not approved until
9 months into the fiscal year (June 1981).   As a result, several
Great Lakes project completion dates had to be extended  and  some
State monitoring activities (which needed to be carried  out  in
the spring) had to be written out of the 1981 program.

     In another case GLNPO experienced problems in  obtaining
region V Water Division cooperation in developing a strategy for
controlling pollution from nonpoint sources.  In 1980 GLNPO
requested that the region V Water Division develop  a nonpoint
source regional strategy for both urban and rural pollution
sources, including criteria for priority ranking and funding
for Great Lakes geographic areas with significant nonpoint
source water quality problems.  According to GLNPO  officials, it
emphasized the importance of developing this strategy by making
it an objective in both the fiscal year 1980 and 1981 Great  Lakes
strategy documents.

     To date the Water Division has not developed such a strategy.
The Chief of the Division's Water Quality Management Branch  told
us that the region does not consider this objective to be a
high-priority issue.  He said that the region is relying on  the
States to develop individual nonpoint strategies, but for various

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reasons, including financial limitations,  political constraints,
and low priorities, the States may not develop timely,  complete,
or otherwise acceptable nonpoint strategies.   Michigan  water
quality officials told us that, while EPA has requested the State
to develop a strategy for controlling nonpoint pollution,  they
believe the State has far more serious problems such as toxics,
hazardous wastes, and municipal discharges.   As a result,  the
State has put most of its effort into addressing these  higher
priority concerns.

     Interregional cooperation has also created frustrations for
GLNPO.  Although it has responsibility for Great Lakes  agreement
activities, GLNPO is located within region V  and is not on the
same organizational level as the other two Great Lakes  regions—
regions II and III—and has no authority over these regions.
Effective cooperation with region II is especially important
because it includes significant portions of the two most polluted
Great Lakes (Erie and Ontario) and the toxic  laden Buffalo Harbor/
Niagara River.

     Both the administrator of region V and the GLNPO director
told us that regions II and III are reluctant to commit resources
to Great Lake activities because they are not specifically funded
for such purposes.  According to these officials,  GLNPO and the
region V program divisions have had to carry  out most of the work
directed to Great Lakes agreement objectives  without assistance
from regions II and III.  For example,  the 1980 Great Lakes
strategy documents prepared by GLNPO did not  designate  any agree-
ment responsibilities to regions II and III.   Only 2 of 59 objec-
tives in the 1981 strategy require a minor amount of involvement
by regions II and III,  and GLNPO continues to carry most of the
burden for activities involving Lake Ontario.

     Regions II and Ill's lack of involvement in Great  Lakes
activities also affects State efforts under the agreement.   State
of New York officials told us that the lack of EPA guidance is a
major reason the State has not directed its attention toward Great
Lakes issues.  Also, three States (Michigan,  Wisconsin,  and Ohio)
are responsible for gathering fish samples from Lakes Erie,  Huron,
and Michigan as part of the total effort to assess toxic pollution
problems.  Although the strategy document also focuses  on  problem
areas in Pennsylvania and New York, these  States are not involved
in fish sampling or analysis activities .

     GLNPO has also experienced problems in directing and  coordi-
nating the efforts of other Federal agencies  involved in Great
Lakes activities.  As discussed in chapter 2,  GLNPO has not
developed a comprehensive nonpoint control strategy which  in-
cludes the Department of Agriculture and has  had research  coor-
dination problems with NOAA.  (See pp.  29-31  and 24-26.)
                               57

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Funding problems limit. Great Lakes act.ivit.ies

     The resources necessary for EPA to function as the lead  U.S.
agency under the 1978 agreement have not been  provided.  As noted
on page 54, the scheduled 1973 start of EPA's  Great Lakes  Initia-
tive Program was delayed until 1974 because  funds earmarked for
the program were transferred to a higher priority program.  A
proposed major cut in fiscal year 1979 funding for Great Lakes
activities,was avoided only when the Office  of the Vice President
raised concern about the impact of funding reductions.

     The table below for fiscal years 1977-82  shows that funding
and staff positions for GLNPO have declined  since 1978.

                             Full-time
                             positions              Funds

                                                  (millions)

      1977                       27                  $4.0
      1978                       36                   7.5
      1979                       22                   6.4
      1980                       15                   6.5
      1981                       18                   6.1
      1982 (proposed)            15                   3.9

     Funding cutbacks have affected and will continue to affect
Great Lakes activities.  For example,  as discussed on pages 38
and 39, monitoring has been reduced or will  be eliminated  by
budget cuts.  EPA travel cutbacks occasionally have limited
employee attendance at important IJC functions.  Also,  congres-
sional committee intervention was required to  prevent the  fiscal
year 1982 closing of EPA's Large Lakes Research Station at Grosse
He, Michigan.  This station has been "zeroed  out" in the  fiscal
year 1983 budget.  According to the research station director,
closing the station would eliminate station  contributions  to
eutrophication issues and toxic substance problems and eliminate
participation by the station's staff on six  IJC work groups or
committees, one of which—the Toxic Substances Control Committee—
is studying toxic control measures and their effectiveness.   In
addition, the U.S. Section of IJC believes that closing the sta-
tion not only would result in the loss of a  major Great Lakes
research activity but would also make the IJC  work related to
the agreement more difficult to accomplish.

     According to its director, GLNPO may also be eliminated  in
fiscal year 1983 because of budget cuts.  Should this occur,  EPA
may no longer have an office entity to oversee and coordinate
Great Lakes Water Quality Agreement activities within EPA  or  with
other Federal agencies, IJC, or Canadian ministries and agencies.
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CONCLUSIONS

     EPA's responsibilities as the lead U.S.  agency for matters
under the water quality agreement are broad and complex and
require the cooperation and assistance of a variety of EPA divi-
sions, offices, and regions as well as other Federal agencies  and
the Great Lakes States.  Yet EPA has assigned Great Lakes program
responsibilities at a relatively low level within  EPA.  As a
result, GLNPO does not have the authority to specifically direct
the Great Lakes activities of other EPA divisions,  offices, and
regions much less the Great Lakes activities of other Federal  and
State agencies.  GLNPO has been frustrated in its  attempts to
ensure that U.S. Great Lakes Water Quality Agreement commitments
are met.

     Funding cuts have also hampered GLNPO's and EPA's efforts
to meet agreement responsibilities.  Great Lakes activities have
had difficulty competing with other EPA programs for funding.
GLNPO funding and staffing have been reduced over  the last
several years and may be terminated in fiscal year 1983.  Should
this occur, EPA will not have an office to oversee and coordinate
its lead agency responsibilities.

RECOMMENDATIONS TO THE ADMINISTRATOR,  EPA

     We recommend that the Administrator,  EPA,  raise GLNPO to  a
high level in the organization and give it the authority and
resources necessary to

     —develop and implement specific action plans to carry out
       U.S. responsibilities under the agreement,

     —coordinate internal EPA actions aimed at improving Great
       Lakes water quality,

     —coordinate with other Federal agencies and  the States to
       ensure their input in developing water quality strategies
       and their support in achieving agreement objectives, and

     —serve as the liaison with and provide input to IJC and
       EPA counterparts in Canada.

     Further, we recommend that the Administrator,  EPA, direct
GLNPO and the various EPA organizational elements  involved in
Great Lakes activities to enter into agreements specifically
delineating (1) the Great Lakes duties and responsibilities of
each entity, (2) time frames for carrying out assigned duties
and responsibilities, and (3) the resources to be  committed to
these duties and responsibilities.
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AGENCY COMMENTS AND OUR EVALUATION

     EPA and Department of State comments on the matters dis-
cussed in this chapter and our evaluation of the comments are
summarized below.

EPA comments

     EPA did not agree with our recommendation  to  elevate the
function of GLNPO to a high level in the organization.   (See
appendix IX.)  EPA stated that its experience over the years has
shown that elevating GLNPO to a headquarters function was not
conducive to sound environmental data gathering, day-to-day
coordination of remedial programs, and international working
relationships.  EPA further stated that the  question of how
regions II-and III and headquarters support  relate to GLNPO1s
authority can be resolved by an Administrator's directive to
focus operating program attention on Great Lakes problems with
coordination by GLNPO.  Also, while EPA did  not disagree with
the tasks we recommended for GLNPO, it believed such tasks will
require substantially more resources.

     We disagree with EPA's position on these matters.  This
chapter and the report in general contain numerous examples of
the frustrations experienced by GLNPO in attempting to coordinate
and direct Great Lakes matters without the authority necessary to
do so.  In addition, as discussed in this chapter, funding for
GLNPO has been declining since 1978 and GLNPO may  be eliminated
in 1983.

     The Great Lakes situation is highly complex;  involves numer-
ous Federal, State, and local organizations; and is exacerbated
by the lack of specific funding for Great Lakes activities.
Under such circumstances we believe that GLNPO's present position
within EPA and its lack of resources further fragment Great Lakes
activities and hinder attainment of Great Lakes Water Quality
Agreement objectives.  We believe that our recomendations con-
cerning GLNPO are appropriate and should be  implemented.

Department of State comments

     The Department stated that it noted with great interest the
recommendations to elevate GLNPO's functions within EPA and was
sympathetic to such a step, assuming the concurrence of EPA.
(See p. 90.)  The Department noted that the  Government of Canada
places a high priority on joint, cooperative efforts to protect
and preserve the Great Lakes and the Department has relied
heavily on EPA and GLNPO in implementating the  agreement.  We
agree with the Department's comments.
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APPENDIX I                                            APPENDIX I
         SELECTED FEDERAL ENVIRONMENTAL LEGISLATION AND

               AGENCIES AFFECTING THE GREAT  LAKES

     The principal Federal law which guides  nationwide water
pollution control efforts is the Federal Water Control Act Amend-
ments of 1972, as amended by the Clean Water Act of 1977  (com-
monly referred to as the Clean Water Act).   This comprehensive
law authorizes a variety of nationwide planning, regulatory,
financial assistance, demonstration,  monitoring, and  research
programs as well as programs specifically for the  Great Lakes.
These programs have been the primary U.S.  mechanism for meeting
the goals of the 1978 Great Lakes Water Quality Agreement.

     The U.S. Environmental Protection Agency (EPA),  established
in 1970, is the principal Federal agency responsible  for  imple-
menting both the Great Lakes Water Quality Agreement  and  the
Clean Water Act.  EPA sets environmental standards, develops  and
issues regulations and guidelines, provides  research  and  techni-
cal support, and administers grants.

     The following sections provide details  on U.S. laws  appli-
cable to and agencies involved in Great Lakes water quality
improvement efforts.  Section I describes critical U.S. Federal
legislation while section II lists the principal Federal  agencies
involved.  While State and local laws,  programs, and  agencies
also have a significant impact on Great Lakes water quality,  they
are not described in this document.

                          SECTION I

                ENABLING U.S. FEDERAL LEGISLATION

THE CLEAN WATER ACT

     The Federal Water Pollution Control Act Amendments of 1972
(33 U.S.C. 1251 et seq.) established goals to attain  water qual-
ity by 1983, wherever possible, suitable for recreational contact
and the protection and propagation of fish and wildlife,  and  to
eliminate any discharges of pollutants into  the Nation's  waters
by 1985.  Moreover, it established specific  deadlines for con-
trolling municipal and industrial discharges.   The 1977 Clean
Water Act (Public Law 95-217) amended the act to revise defini-
tions and timetables, continue funding, and  to further address
toxic substances.  The act contains various  provisions, most  of
which the States have assumed responsibility for implementing.

     The legislation addresses both point and nonpoint sources
of pollution and both conventional and toxic pollutants.   It
authorizes a number of nationwide planning,  regulatory, financial
assistance,  demonstration,  monitoring,  and research programs  and
some programs specific to Great Lakes water  quality.   These major
programs have been utilized as the primary mechanism  for  meeting


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APPENDIX I                                           APPENDIX I
some of the goals of the 1978 Great  Lakes  Water Quality Agreement.
The more pertinent programs are described  below.

Research program

     Section 104(f) authorizes special  ambient water quality and
waste treatment studies to protect Great Lakes water quality.   It
calls for research, technical development  work/ and studies of  the
lakes'  water quality, including an analysis  of the present and  pro-
jected future quality,  an evaluation of water quality needs and
disposal practices, and a study of alternate means of solving
pollution problems.

Grants for administration of
pollution control programs

     Section 106 provides for annual grants  to States to  assist
them in administering programs for the  prevention, reduction, and
elimination of pollution.  The funds are for operations and imple-
mentation activities, such as monitoring,  evaluation, enforcement,
and administration.

Pollution control in watersheds
of the Great Lakes

     Section 108(a) authorizes the Administrator  of EPA to enter
into agreements to carry out one or  more projects to demonstrate
new methods and techniques and to develop  preliminary plans for
the elimination or control of pollution within all or any part  of
the Great Lakes watershed.

     Section 108(d) directs the U.S. Army  Corps of Engineers to
develop a wastewater management program for  the rehabilitation  and
environmental repair of Lake Erie, and  under the  1977 amendments,
the Corps of Engineers was authorized additional  funds  for Lake
Erie to develop alternative waste control  measures for  point and
nonpoint sources and contaminated sediments.

Construction grant program

     Section 205 provides Federal grants  for planning,  designing,
and constructing municipal sewage treatment  facilities.   These
grants provide between 75 and 85 percent of  the facilities'
eligible costs.  The States determine the  specific  facilities to
be constructed and may provide additional  funding support.

     Section 205(g) of the act authorizes  an EPA-approved State
to use $400,000, or 2 percent of its construction grant allocation
(whichever is greater), to support State  program  administration
costs.  This grant supplements other moneys  provided  to the
States for program administration.
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APPENDIX I                                            APPENDIX I
Areawide planning program

     Section 208 provides grants to State and local agencies to
encourage and facilitate the development and implementation of
areawide water quality management plans to address all water
quality problems within a geographic area.

     Section 208(j) authorizes the Department of Agriculture,
with the concurrence of EPA, to establish and administer a Rural
Clean Water Program to enter into 5- to 10-year contracts with
owners and operators to apply and maintain best management prac-
tices on rural lands to control agricultural nonpoint source
pollution.  For fiscal years 1979 and 1980,  $200 million and
$400 million, respectively,  was authorized for the program.   Un-
der the contracts, owners and operators were to receive Federal
matching funds for up to 50  percent of the total project cost,
to an upper limit of $50,000 on the cost share to an individual.
The Department's Agricultural Stabilization and Conservation
Service was to be responsible for administering the program, and
the Department's Soil Conservation Service was to provide techni-
cal assistance to landowners.  This section of the Clean Water
Act, however, has never been funded.  In its place, an experi-
mental Rural Clean Water Program was included in the Department
of Agriculture appropriations in 1980 and 1981 with funding
levels of $50 and $20 million, respectively.

NPDES permit program

     Section 402 authorizes  the National Pollutant Discharge
Elimination System (NPDES)  permit program, which is the basic
enforcement mechanism for reducing or eliminating point source
pollution from industrial, municipal, commercial, and certain
agricultural discharges.  The eight Great Lakes States issue per-
mits for all discharges into U.S. waters within their jurisdic-
tion.  An NPDES permit generally specifies discharge limitations
for specific pollutants, establishes schedules for upgrading con-
trols to meet such limits, and requires periodic reports on
compliance.

Dredge and fill program

     Section 404 authorizes  the dredge and fill program, which is
a permit program to control  the discharge of dredged and/or fill
material into navigable waters.  This program is administered by
either the Army Corps of Engineers or the States.  The permits
are issued through the application of guidelines developed jointly
by EPA and the Corps.

THE CLEAN AIR ACT

     The Clean Air Amendments of 1970 (42 U.S.C.  1857 et seq.)
provide the basic Federal statutory provisions for control of
air contaminants.  This legislation establishes a joint Federal-
State program to protect and upgrade the Nation's air quality.

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APPENDIX I                                            APPENDIX I


Under this program, the States have primary responsibility for
controlling air pollution from stationary sources  while  EPA is
responsible for controlling pollution from mobile  sources,  such
as automobiles.

THE RESOURCE CONSERVATION
AND RECOVERY ACT

     In 1976 the Congress passed the Resource Conservation and
Recovery Act (42 U.S.C. 6901)  to protect health and the  environ-
ment and conserve valuable material and energy resources.   This
mandates a national program to control hazardpus wastes  from
their generation point to ultimate disposal and sets forth a pro-
gram to manage nonhazardous solid wastes.  The act was intended
to be implemented primarily by the States.

     Under subtitle C (hazardous wastes) of the act, EPA must
establish a national regulatory program to control hazardous
wastes, which the Federal Government will operate  and enforce
when EPA does not approve the  State program.   "Cradle to grave"
hazardous waste control is to  be achieved by (1) establishing
Federal standards for hazardous waste generators,  transporters,
and facilities for treatment,  storage, and disposal, (2) using a
nationwide manifest system to  track hazardous waste movement,
(3) issuing permits for new and existing treatment, storage, and
disposal facilities, and (4) enforcing these Federal require-
ments.  States can receive financial and technical aid to  develop
hazardous waste programs meeting EPA requirements.

     Hazardous wastes include  wastes which can be  toxic, carcino-
genic, mutogenic, or teratogenic.  This program therefore  promises
to have a significant mitigating impact on the amount of toxic
material entering the Great Lakes by establishing  a national
management system designed to  control waste handling and preclude
the entry of hazardous wastes  into surface waters, groundwater,
and air.  In addition, the disposal of any material dredged from
the lakes, if found to be hazardous, would need to comply  with
the act.

THE SAFE DRINKING WATER ACT

     In December 1974 Congress passed the Safe Drinking  Water Act
(42 U.S.C. 300f, et. seq.) to  ensure that public water supply
systems throughout the Nation  meet minimum national health stand-
ards.  This act was the first  national commitment  to safeguard
all public drinking water supplies.  Another major provision of
the act addresses the protection of underground water sources by
controlling subsurface fluids  injection.

     The emphasis of the act for the Great Lakes is on control-
ling the use of the lakes, and the act deals mainly with standards
for water supplied to consumers rather than the raw water  supply.
Under the act, sources contributing to elevated toxicant levels
affecting drinking water systems can be ordered to limit their

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APPENDIX I                                           APPENDIX I
discharges.  It was intended that the individual  States  would
assume primary responsibility for implementing  the act.   However,
EPA continues to be responsible for monitoring  State  implementa-
tion efforts and is either responsible or has assumed responsi-
bility for implementing the provisions of the act in  those  States
which have not assumed the lead role.
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APPENDIX I                                            APPENDIX I
                         SECTION II
                 FEDERAL EXECUTIVE AGENCIES

ENVIRONMENTAL PROTECTION AGENCY

     The Environmental Protection Agency,  established in 1970,
is charged with the basic mission of mounting an integrated,
coordinated attack on the environmental  problems of air  and water
pollution, solid waste management, pesticides,  radiation,  and
noise.  Generally, EPA is responsible for  establishing environ-
mental standards, developing and issuing regulations and guide-
lines, providing research and technical  support/ awarding and
administering grants, and enforcing various  environmental laws.
These laws usually provide for State implementation of air, solid
waste, pesticide, and water pollution programs  within bounds
established by EPA and for EPA to carry  out  the programs when a
State elects not to do so.  The congressional intent is  clearly
that EPA and the States act in partnership to implement  these
programs.

     The Great Lakes National Program Office (GLNPO), located in
Chicago, is responsible for planning, coordinating, and  oversee-
ing EPA's pollution control programs as  they affect the  implemen-
tation of the U.S. portion of the 1978 water quality agreement
between the United States and Canada. GLNPO's  primary responsi-
bility is to work with other EPA divisions and  the States to
identify Great Lakes problems and recommend  solutions.  It also
is EPA's focal point for coordinating and  communicating  with
other agencies and the public.

     The Large Lakes Research Station, located  on Grosse lie,
Michigan, studies pollutants in the Great  Lakes.  It determines
what those pollutants are and finds out  where they go and how
they affect water quality.

DEPARTMENT OF AGRICULTURE

     Several agencies within the U.S. Department of Agriculture
administer programs which relate to and/or involve nonpoint  source
pollution.

Agricultural Stabilization and
Conversation Service (ASCS)

     ASCS administers the Agricultural Conservation Program which
provides cost sharing assistance to farmers  and ranchers to  carry
out conservation measures on their land, such as practices to
control erosion and sedimentation and pollution from animal wastes.
ASCS also administers the Rural Clean Water  Program authorized
under the Clean Water Act.
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APPENDIX I                                             APPENDIX I


Soil Conservation Service (SCS)

     SCS is responsible for developing and carrying out a national
soil and water conservation program and assists in agricultural
pollution control and environmental improvement.   SCS assists
local units of government (208 planning agencies)  in implementing
soil and water quality management plans and provides financial
and technical assistance for watershed projects to improve water
quality and reduce soil erosion.   SCS also cooperates with ASCS
in administering the Rural Clean Water Program.

Farmers Home Administration (FmHA)

     FmHA provides credit for those in rural America who are
unable to get credit from other  sources at reasonable rates and
terms.  Its loan coverage includes water conservation, watershed
protection, and resource conservation projects and efforts.

Science and Education Administration (SEA)

     SEA conducts and funds research programs in agricultural
sciences and communicates and demonstrates the research results to
farmers.  The agricultural research staff administers a basic,
applied, and developmental research program which  includes cover-
age of "the use and improvement  of soil, water, and air."  The
cooperative research staff administers Federal grant funds for
agricultural research.  The extension service staff administers
Federal funds for constructing cooperative extension education
programs.

DEPARTMENT OF DEFENSE

Department of the Army, Corps of Engineers

     The Corps of Engineers is involved in the entire field of
water resources planning and development, including commercial
navigation, shore and beach erosion protection, water quality
management, and wastewater management.  In the basin the Corps
has

     —administered the permit programs for discharge or place-
       ment of fill or dredged material in navigable waterways
       and for creation of alternatives to obstructions in
       navigable waterways,

     —studied the feasibility of winter shipping  on the lakes,
       and

     —carried out a wastewater management study under sec-
       tions 108 (d) and 108(e)  of the Clean Water Act aimed
       at developing a plan for managing phosphorous inputs
       into Lake Erie.
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APPENDIX I                                            APPENDIX I
DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric
Administration (NOAAl

     NOAA provides Federal leadership in promoting wise  and
balanced management of the Nation's coastal  zone, including  the
award of grants to States for developing and carrying  out  plans
for the management of their coastal zones.

     In addition,  NOAA provides satellite observations of  the
environment by establishing and operating a  national environ-
mental satellite system and conducts an integrated program of
research and services relating to the oceans and inland  waters.

     NOAA also administers and directs the National Sea  Grant
program by providing grants to institutions  for marine research,
education, and advisory services, and promotes  the development
of technology to meet future needs of the marine community.

     In the basin NOAA operates a Great Lakes Environmental
Research Laboratory in Ann Arbor, Michigan.   The laboratory  con-
ducts research directed toward understanding the environmental
processes and solving problems in research management  and  environ-
mental services in the Great Lakes and their watersheds.

DEPARTMENT OF TRANSPORTATION

Coast Guard

     The Coast Guard has major responsibilities in implementing
the Nation's policies for protection of the  marine environment.
The program objectives are to maintain or improve the  quality of
the marine environment and to minimize the damage caused by  pol-
lutants discharged into it.

     The functions conducted include boarding tank vessels,
monitoring transfer operations, and inspecting  liquid  bulk
facilities to ensure compliance with the laws,  executive orders,
and agreements that constitute the legal mandate for the marine
environmental protection program.  A national strike force also
has been established to respond in the event of a major  pollution
incident.

DEPARTMENT OF THE INTERIOR

U.S. Geological Survey

     The U.S. Geological Survey provides the hydrologic  informa-
tion and understanding needed for optimum use and management of
the Nation's water resources.  This is accomplished through
cooperation with other Federal and non-Federal  agencies  by
(1) collecting systematically data needed to continually deter-
mine and evaluate the quantity, quality, and use of the  Nation's

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APPENDIX I                                            APPENDIX I
water resources, (2) conducting water resource appraisals
describing the occurrence,  availability,  and the physical,
chemical, and biological characteristics  of surface and ground
waters, (3) conducting basic and problem-oriented research in
hydraulics, hydrology, and related fields,  (4) disseminating
water data and research through reports,  maps, computerized
information services, and other public releases,  (5)  coordinating
the activities of other Federal agencies  concerning water  data
for streams, lakes, reservoirs, estuaries,  and ground waters,  and
(6) providing scientific and technical assistance in  hydrologic
fields to other Federal, State, and local agencies, licensees
of the Federal Energy Regulatory Commission,  and international
agencies on behalf of the Department of State.

U.S. Fish and Wildlife Service

     In the area of resource management,  the Fish and Wildlife
Service provides leadership for the protection and improvement
of land and water environments (habitat preservation)  which
directly benefit the living natural resources and add quality
to human life.  Activities include

     —biological monitoring through scientific research;
       surveillance of pesticides,  heavy  metals,  and  thermal
       pollution; studies of fish and wildlife population;
       and ecological studies; and

     —environmental impact assessment through river  basin
       studies, including hydroelectric dams,  nuclear power-
       sites, stream channelization, dredge and fill  permits;
       associated research; and environmental  impact  state-
       ment review.

     The Great Lakes Fishery Laboratory located in Ann Arbor,
Michigan, carries out research on the fish resources  of the Great
Lakes.  Laboratory research concentrates  on the effects of pollu-
tion, lamprey predation, and habitual changes of food and  game-
fish.  Research results are given to State  and Federal agencies
to help them develop fishery management plans.
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Appendix II                                        Appendix  II


               SELECTED AND ANNOTATED BIBLIOGRAPHY

                   OF GAP REPORTS  INVOLVING

                  WATER QUALITY ISSUES IN THE

                         UNITED STATES
"Better Monitoring Techniques Are Needed  To Assess the  Quality
of Rivers and Streams," Volumes I and II  (CED-81-30, Apr.  30,
1981) .

          This report describes how the Environmental
     Protection Agency and the Geological Survey use sam-
     pling networks,  which generally sample once a month
     at widely spaced sites,  to assess the quality of the
     Nation's rivers and streams.  It concludes that water
     quality is far too complex to be monitored by these
     networks and nationwide  reports based on data from the
     networks are unreliable.

"Cleaning North America's Inland Seas: Study of Federal Water
Pollution Research Demonstration Programs on the Great  Lakes"
(B-166506, Jan. 16, 1974).

          This report describes how certain factors have
     limited EPA's efforts to meet the lakes' research  and
     development needs.  It concludes that greater Federal
     agency coordination and  teamwork with EPA leadership
     are needed if the U.S. contribution  under the water
     quality agreement is to  be effective.

"Cleaning Up the Great Lakes:  United States and Canada Are  Mak-
ing Progress in Controlling Pollution from Cities and Towns"
(RED-75-338, Mar. 21, 1975).

          This report describes how the United States and
     Canada are progressing in controlling pollution  from
     cities and towns.  It concludes that the United  States
     will substantially meet  1972 water quality agreement
     requirements for construction of municipal waste treat-
     ment facilities by 1978; however it  will take many years
     and cost millions of dollars before  combined sewer over-
     flows are controlled.

"Combined Sewer Flooding and  Pollution—A National Problem.   The
Search For Solutions in Chicago," Volumes 1-6 (CED-79-77,  May 15,
1979).

          This report describes the combined sewer and
     flooding problems in the Chicago metropolitan area.
     It questions the project's continuation because  of its


                               70

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Appendix II                                         Appendix  II


     high cost (estimated at $11 billion by 1983)  and  its
     uncertain impact on water quality.

          Volume 1,  an executive summary, synopsizes infor-
     mation in the other volumes.  Volume 2 describes  the
     current status and impact of the Chicago Tunnel and
     Reservoir Plan;  Volume 3 profiles the extent  and
     location of flooding and damage in  the Chicago metro-
     politan area? Volume 4 summarizes the limited availa-
     bility of funds to correct the problems; Volume 5
     describes several alternatives for  local communities
     and individual citizens to consider; and Volume 6
     contains summaries of the flooding  experienced by each
     of the 54 Chicago area communities,  actions planned or
     taken to alleviate or mitigate the  problem, and the
     anticipated impact of the Tunnel and Reservoir Plan.

"Congressional Action Needed To Provide  a Better Focus on Water-
Related Research Activities" (CED-81-87,  June 5, 1981).

          This report describes how water-related  research
     and development activities are fragmented among 28
     Federal organizations that planned  to spend about $380
     million during fiscal year 1981. It concludes that
     more effective use of these funds is needed.

"Continuing Need for Improved Operation  and Maintenance of
Municipal Waste Treatment Plants" (CED-77-46,  Apr.  11,  1977).

          This report found that operational and mainte-
     nance problems at treatment plants  have caused ineffi-
     cient plant operation and discharging of unnecessarily
     high pollution loads into the Nation's waterways.  It
     concludes that EPA must strengthen  its regional office
     and State efforts to improve plant  operation  and  mainte-
     nance and that EPA, the States, and local communities
     must place a higher priority on plant operation and
     maintenance.

"Costly Wastewater Treatment Plants Fail To Perform as Expected"
(CED-81-9, Nov. 14,  1980).

          This report describes how despite a Federal  in-
     vestment of $25  billion, plus several billion more in
     State and local funds to construct  new wastewater
     treatment plants or to modify and expand existing
     plants, many are not treating wastewater at the effi-
     ciency levels they were designed to achieve.   These
     treatment plant failures were usually the result  of a
     combination of often overlapping problems.  It con-
     cludes that a change to the construction grants
     funding program is needed to assure that wastewater
     treatment plants, once constructed  and paid for,  will
     operate as intended.

                               71

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Appendix II                                       Appendix II


"Federal-State Environmental Programs—the State  Perspective"
(CED-80-106,  Aug.  22,  1980).

          This report describes how the  States, which
     are primarily responsible for carrying out Federal
     environmental programs, overwhelmingly believe  that
     Federal requirements—legislative,  regulatory,  and
     administrative—and the uncertainties of Federal
     funding impede their management of  these programs.
     It concludes  that because of these  obstacles the
     Federal-State partnership envisioned by the  Congress
     for administering Federal environmental programs has
     not materialized.

"Large Construction Projects To Correct  Combined  Sewer Over-
flows Are Too Costly" (CED-80-40,  Dec. 28, 1979).

          This report describes how neither the Federal
     Government nor local communities can supply  the
     billions of dollars required for the large construc-
     tion projects usually needed to stem pollution  and
     flooding caused by combined stream  sewer and sewage
     systems.  It  identifies a number of new control
     techniques which offer promise and  are far less
     expensive than the construction projects.

"Many Water Quality Standard Violations  May Not Be Significant
Enough To Justify  Costly Preventive Actions" (CED-80-86, July 2,
1980).

          This report describes how advanced waste-
     water treatment for municipal sewage, with few
     exceptions, may not be worth the tremendous  costs—
     estimated by  the Environmental Protection Agency at
     $10 billion.   Although it recognizes there may  be
     times when advanced treatment is justified,  such
     as phosphorus removal from the Great Lakes to comply
     with water quality agreement commitments, it con-
     cludes that funding of these projects should be
     curtailed.

"Millions of Dollars Could Be Saved by Implementing  GAO Recommen-
dations on Environmental Protection Agency Programs" (CED-81-92,
May 5, 1981)  .

          This report discusses opportunities to
     realize substantial savings through legislative and
     administrative changes in the Environmental  Protec-
     tion Agency's water pollution control and hazardous
     and solid waste programs.  It focuses on the recom-
     mendations to the Congress and to the Agency con-
     tained in seven reports on these two programs.
                               72

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Appendix II                                        Appendix II
"National Water Quality Goals Cannot Be Attained Without More
Attention to Pollution from Diffused or 'Nonpoint1  Sources"
(CED-78-6, Dec. 20, 1977).

          This report describes how nonpoint pollution,
     which currently produces more than half of the pollu-
     tants entering the Nation's waterways,  will prevent
     the achievement of 1983 water quality goals.   It con-
     cludes that there is a need for a greater  Federal,
     State, and local effort to control nonpoint sources
     of pollution.

"River Basin Commissions Have Been Helpful,  But Changes  Are
Needed" (CED-81-69, May 28, 1981).

          This report describes how river basin commissions
     (including the Great Lalces Basin Commission),  which
     spend $3 million annually, contribute toward water
     resource planning and development.  It concludes that
     the commissions, as they are now operating,  do not
     accomplish optimum planning.   While they have  provided
     a forum for Federal and State members to exchange views
     and have assisted States in various water  studies,  they
     have fallen short of meeting some of their legislative
     objectives.

"Water Quality Management Planning Is Not Comprehensive  and
May Not Be Effective for Many Years" (CED-78-167, Dec. 11, 1978)

          This report describes how the Environmental
     Protection Agency has administered a planning  program
     for geographic areas with substantial water quality
     control problems.  It points out the problems  that  have
     hindered the effectiveness of the program  and  the
     problems being experienced by the States and areawide
     agencies which do the planning.  It concludes  that
     although the program has had a number of accomplish-
     ments in a relatively short period of time,  planning
     has not been comprehensive and it may take many years
     before the program can be fully effective  in cleaning
     the Nation's waters.
                               73

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APPENDIX III
                                             APPENDIX III
                       ESTIMATED CONSTRUCTION COMPLETION
                        DATES FOR MAJOR U.S. MUNICIPAL

                      TREATMENT PLANTS, LOWER GREAT LAKES
Jurisdiction

Lake Erie:
    Ohio (69)
    Mich. (22)
    Ind. (4)
    Pa. (2)
    N.Y. (9)
                                  Year

1981*
35
19
3
1
6

1982*
6
0
0
1
2

1983*
5
3
0
0
0

1984*
12
0
1
0
1
1985*
or later
11
0
0
0
0
      Total (106)  64
Lake Ontario
    N.Y. (44)
                      14
              11
                                       Total not  Percent
                                        meeting   not meet-
                                         1982     ing 1982
                                       deadline   deadline
24
13
28
 3
 1
 0
J.

33
14
41
14
25
 0
11

31
32
      Total (150)  88      15      21    14
                              12
                          47
           31
*Completed or abandoned during given year (1981 includes previous years totals)
() denotes total number of plants.
                                      74

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APPENDIX IV
APPENDIX IV
                         GREAT LAKES BASIN FUNDING
                   FOR MUNICIPAL SEWAGE TREATMENT PLANTS
                        Period
     State
EPA
region State
V Ind.
Mich.
Minn.
Ohio
Wis.
Total (note b)
II N.Y.
Ill Pa.
Total
(fiscal year)
(note a)
1973-81
1972-81
1973-80
1972-81
1972-81
1973-79
1977
Number of
projects
114
756
44
275
269
1/458
123
2
JLjrSjtt
Eligible
costs

$ 304.7
1,855.4
127.2
947.0
482.7
3,717.0
1,136.6
1.8
$4,855.4
Federal
share
- (millions) -
$ 231.5
1,374.7
95.5
700.0
360.0
c/ 2,761.8
852.7
1.4
$3,615.9
and local
share

$ 73.2
480.7
31.7
247.0
122.7
c/ 955.2
283.9
0.4
$1,239.5
a/Covers period July 1, 1971, through February 1981.  Gaps in fiscal years
  shown for the States indicate that EPA did not approve any grants in that
  State's portion of the Great Lakes basin during those years.

b/Although Illinois is in region v, the cost of sewage treatment plants in that
  State are excluded because none of the plants discharge wastes directly into
  the Great Lakes or their tributaries.

c/Columns do not total due to rounding.
                                     75

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APPENDIX V                                            APPENDIX V
                ADDITIONAL UNCERTAINTIES  ABOUT

                GREAT LAKES PHOSPHORUS  CONTROLS

     Four areas of uncertainty remain to  be resolved concerning
phosphorus control measures on the Great  Lakes:

     —The extent to which different phosphorus  forms contribute
       to algae growth.

     —The contribution of tributaries  to phosphorus loads.

     —The contribution of shoreline erosion to  lake phosphorus
       inputs.

     —The extent to which the atmosphere contributes phosphorus
       to the lakes.

Resolution of these four relative unknowns could drastically
affect the types and extent of programs needed to control  the
lakes'  phosphorus problems.

EXTENT TO WHICH DIFFERENT PHOSPHORUS
FORMS CONTRIBUTE TO ALGAE GROWTH

     According to experts from IJC and  the Great Lakes Basin
Commission, phosphorus bioavailability remains one of the  most
critical considerations in assessing the  desirability and
effectiveness of phosphorus control programs on  the Great  Lakes.
(The term bioavailability refers to phosphorus that is immediately
available for algae growth or that can become available for  algae
growth over a short time period.)  Some forms of phosphorus, such
as those in sewage treatment plant effluent, are more readily
available or harmful than other forms,  such as those in urban  and
rural runoff.

     Although recent studies have focused on different phosphorus
forms, much still remains to be learned.   Still  unresolved are
questions about which sources contribute  the largest amount  of
harmful phosphorus, what conditions affect the amount and  rate
at which phosphorus is used in the lakes, and how different
sources should be controlled to achieve water quality objectives
in the most cost-effective way.  In its 1981 annual report to  IJC,
the Great Lakes Science Advisory Board concluded that techniques
to provide a meaningful assessment of the bioavailability  problem
do not exist and that such techniques would not  likely be  developed
without a significant increase in research efforts.

     Management practices for controlling Great  Lakes eutrophica-
tion historically have been directed toward all  phosphorus (total
phosphorus) whether harmful or not.  The  target  phosphorus loads
developed for the 1978 agreement have been based on total  phospho-
rus values, because little information exists on the inputs  of
different forms of phosphorus from various sources.  However,  the

                              76

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APPENDIX V                                             APPENDIX V


importance of the bioavailability issue is widely recognized by
EPA, IJC, and others within the Great Lakes scientific  community
and deserves particular attention when evaluating phosphorus
management strategies for the lakes.   It makes little sense
to design an expensive strategy for controlling total phosphorus
if the possibility exists that only some unknown part of the
total phosphorus load is actually harmful.

CONTRIBUTION OF TRIBUTARIES
TO PHOSPHORUS LOADS

     Tributaries carry phosphorus from both wastewater  treatment
plants and urban and rural runoff, but uncertainty exists concern-
ing when and how much phosphorus in tributary sediment  is released
to the lakes after it has originally settled to the bottom.  To
minimize the impact of the backwater of the lake on the measure-
ments taken, tributary loads are estimated from measurements made
in rivers and streams at a point upriver from where the tributary
flows into the lake.  However, the 1980 final report of the  IJC
Phosphorus Management Strategies Task Force indicated that much
could happen to the phosphorus before it reaches, if it ever
reaches, the lakes.  The phosphorus could, for example,  settle  in
river bottoms and either never be released or be released little
by little over time and with no assurance of how much would  be
harmful.  The Phosphorus Management Strategies Task Force
believes that tributary phosphorus loads to the Great Lakes
could be underestimated by 10 to 30 percent because traditional
methods for estimating tributary phosphorus loadings also do
not adequately take into account periods of high flow,  such  as
those that occur after a storm.  According to the task  force, no
consistent or comprehensive data base with associated analysis
exists concerning the effect of storm runoff on phosphorus inputs
to the Great Lakes.

SHORELINE EROSION CONTRIBUTIONS
TO PHOSPHORUS INPUTS

     Erosion from the thousands of miles of Great Lakes shoreline
contributes a potentially large share of the total phosphorus
loadings to the lakes.  Yet,  shoreline erosion has not  been  fac-
tored into current phosphorus input estimates and target loads.
The Phosphorus Management Strategies Task Force concluded that
any development of target loads based on total phosphorus for
the Great Lakes should include any source, such as shoreline
erosion, which could affect lake eutrophication.   The task force
admits that excluding shoreline erosion may result in overesti-
mating the benefits from controlling phosphorus from tributaries
and other sources.  If these benefits are overestimated,  the
most cost-effective control measures may not be selected.

     The amount of total phosphorus that shoreline erosion contrib-
utes to the Great Lakes is significant, especially when compared
to the amount of total phosphorus inputs contributed by all  other
sources.  The following table, taken from the final report of the

                               77

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APPENDIX V                                            APPENDIX V
Phosphorus Management Strategies Task Force,  issued July  1980,
shows this relationship.

                 Shoreline Erosion as a Source

                 of Lakewide Total Phosphorus


         Total sediment  Total phosphorus
         from shoreline  from shoreline      1976  total phosphorus
 Lake        erosion        erosion          from  all  other  sources
                         (metric tons per year)- ---------
Superior   11,279,000         3,800                  4,200
Michigan   21,778,000         3,800                  6,400
Huron       1,763,000           794                  4,900
Erie       11,131,000        10,536                 18,400
Ontario     3,206,000         1,280                 11,800


     In calculating the target loads for the lakes,  the task force
assumed that phosphorus from shoreline erosion settles  near  the
shore and does not enter lakewide processes.  If it  does settle
rapidly, the impact of this source of pollution would be lessened,
but no data base exists to determine what percentage of these
loads actually does settle and is not available to the  lakes.
According to a 1981 Great Lakes Basin Commission report, some
experts have estimated that anywhere from 1 to 40 percent of
the total phosphorus from shoreline erosion actually contributes
to eutrophication.  Because of the potentially large amount  of
phosphorus that could be available to the lakes, the exclusion
of shoreline erosion raises serious questions about  the integrity
of the target loads proposed to direct future control efforts on
the Great Lakes.

CONTRIBUTION OF ATMOSPHERIC
DEPOSITION TO PHOSPHORUS LOADS

     Phosphorus is one of several inorganic but biologically
active elements deposited in significant quantities  from the
atmosphere.  While the atmospheric waste was suspected  of being
of major importance in the movement and behavior of  pollutants
in previous years, the atmospheric deposition of pollutants  like
phosphorus to the Great Lakes had not really been addressed.
Studies to date indicate, however, that the atmosphere  may con-
tribute a large percentage of the phosphorus loads to Lakes
Huron, Michigan, and Superior and to a much lesser extent to
the loads for the two lower lakes.  The upper lakes  are partic-
ularly susceptible to atmospheric inputs because of  their large
surface areas and air mass circulation patterns.
                               78

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Appendix V                                           Appendix V


     In a January 1981 interim report under the  water quality
agreement, IJC recommended that the Governments  act  to overcome
the lack of sufficient monitoring data and to fulfill the  need
for a well-designed,  coordinated,  efficient sampling network
and monitoring study to identify and measure the atmospheric
deposition occurring thoughout the Great Lakes Basin.  As  of
February 1982, the U.S. Section of IJC continues to  believe that
more accurate information on the quantities and  types of phosphorus
entering the lakes by air is needed.   We agree and can only
conclude that the lack of understanding surrounding  atmospheric
inputs of phosphorus to the lakes adds to the uncertainty  about
what the overall U.S. phosphorus control strategy should be for
the Great Lakes.
                               79

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 APPENDIX VI
                                     APPENDIX VI
                          FEDERAL GRANT OUTLAYS FOR
                      POLLUTION CONTROL PROGRAMS AND
                            ACTIVITIES IN THE GREAT
                              LAKES BASIN, 1978-1980
     750-
CO
rr
O
Q
g

I
     500-
     250-
                              967.7
                              941.6
                                                      753.2
                                                      672.5
1978
                                                      1979
                                                                             874.4
                                                                             801.8
1980
        EPA CONSTRUCTION GRANTOUTLAYS FOR GREAT LAKES BASIN

        FEDERALOUTLAYS FOR OTHER GREAT LAKES BASIN PROGRAMS
SOURCE: The Geographic Distribution of Federal Funds Reports for fiscal years
       1978 through 1980 compiled by The Community Services Administra-
       tion.
                                         80

-------
APPENDIX VII
                                                            APPENDIX VII
 oo

 O
 -
 OS
 
-------
APPENDIX VIII
                                                    APPENDIX VIII
                                                               I
                                82

-------
APPENDIX IX                                              APPENDIX IX
  v,to si-*,

                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                            WASHINGTON, D.C. 20460

                            MAR   51982
                                                            OFFICE OF
                                                    POLICY AND RESOURCE MANAGEMENT
      Mr. Henry Eschwege
      Director
      Community and Economic
       Development Division
      U.S. General Accounting Office
      Washington, D.C.  20548

      Dear Mr. Eschwege:

           The Environmental Protection Agency (EPA) has reviewed the
      General Accounting Office (GAO) draft report entitled "Great
      Lakes Cleanup Efforts Need More Focus and Direction".  Public Law
      96-223 requires the Agency to submit comments on the report for
      consideration prior to publication of the final report.  We
      believe that our corrections, clarifications and comments,
      presented in this letter and its enclosure, would improve the
      final report and should be addressed in the report to Congress.

           We are concerned that GAO does not fully recognize the
      scope of the ambitious objectives of the 1978 Great Lakes Water
      Quality Agreement, which does not directly control the water
      quality programs used to support these objectives.  Great Lakes
      programs are generally not separately funded under federal law,
      and therefore, specific water quality activities usually take
      place only within the context of existing and broadly targeted
      federal pollution control legislation.  Such water quality programs
      include National Pollutant Discharge Elimination System (NPDES)
      Permit and Construction Grants Programs.  We realize that the
      pollution problems, both point and nonpoint source, have not
      been solved; however, pollution control plans, mechanisms and
      facilities are generally in place and the cleanup is progressing.

           In addition, we believe the draft report is deficient in a
      number of areas.  First, its major emphasis on phosphorus control
      measures and Great Lakes monitoring fails to acknowledge both
      the comprehensive nature of the Agreement and the numerous Federal
      and State actions undertaken to meet the terms of that Agreement.
      We are also concerned with the apparent lack of technical and
      scientific expertise expressed in the draft regarding the role
      of phosphorus in the eutrophication process and the subsequent
      mix of measures to control its input into the Great Lakes system.
                                   83

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APPENDIX IX                                              APPENDIX IX


                                 -2-

      We do not concur with the GAO recommendation that H.R.3600 should
  be enacted to better coordinate Great Lakes research.  We strongly
  support the  general goal of this bill, i.e., the more effective
  coordination of U.S. Great Lakes research activities.  However, we
  seriously doubt that the goal will be achieved if the bill,  as
  written, is  enacted.

      EPA representatives co-chair and provide staff assistance to
  the two principal joint U.S.-Canada Boards created by the Agreement
  to advise the International Joint Commission (IJC) and the governments
  on research  needs, program policies and Agreement progress.   In
  addition, EPA is the primary source of technical and policy
  expertise for the State Department in its Great Lakes related
  diplomatic negotiations with the Canadian government.  If H.R.3600
  is passed, this established mechanism for addressing Great Lakes
  problems would be fragmented  by placing responsibility for research
  coordination in a separate office which has no authority or ability
  to link research needs or the results with water quality trends or
  the remedial actions necessary to correct or abate identified
  pollution problems.  This separation of research from monitoring
  and pollution control programs would, in our opinion, seriously
  jeopardize current efforts to develop, with the States, compatible
  and coordinated Great Lakes management programs which are responsive
  to both domestic mandates and international commitments.

      The draft report notes that the organization and funding for
  Great Lakes  research and surveillance merits close examination.
  In many respects, the present system for administering these
  programs has been ineffective.  This situation can be attributed
  to the complexity of organizations involved in the Great Lakes
  pollution control programs, as cited in the draft report.  We
  also do not  agree that the Great Lakes National Program Office
  (GLNPO) has  to be "elevated within the Agency" to exercise more
  authority over U.S. programs  affecting Great Lakes water quality.
  The Agency has found, through experience over the years, that
  elevation of GLNPO to a Headquarters' function was not conducive
  to sound environmental data gathering, day-to-day coordination
  of remedial  programs and international working relationships.
  The question of how Region II and Ill's and Headquarters' support
  relate to GLNPO authority can be positively resolved by an
  Administrator's directive to  focus operating program attention
  to Great Lakes problems under the coordination of GLNPO.

      While we do not disagree  with the tasks GAO recommends be
  undertaken by GLNPO, we believe GAO is calling for an unnecessarily
  resource-intensive effort to  carry them out.

  Phosphorus

       One important reason both the U.S. and Canada have emphasized
  control of municipal sewage discharges as the first and major
  component of their control strategies is that these point sources,
  in general,  produce far more  bioavailable phosphorus than other
  sources and, therefore, are relatively more important in the
  control of accelerated eutrophication.  This is not to diminish
                                  84

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APPENDIX IX                                              APPENDIX IX
                                  -3-

   the current emphasis  on the  control  of  nonpoint  sources,  but
   rather to put  the  control  of point sources  of  phosphorus  into
   its proper scientific context and to suggest  that  future  phosphorus
   control strategies, as contemplated  in  the  current U.S.-Canada
   negotiations,  will emphasize the most cost-effective means  of
   further reducing phosphorus  inputs.

        We do not disagree with the statement  that  the December 31,
   1972 Agreement goal for adequate treatment  of  all  municipal
   sewage discharges  to  the Lower Lakes will not  be met.   However,
   it is the amount of phosphorus entering the Lakes  which will
   ultimately determine  the success or  failure of control programs,
   not the number of  small facilities in or out  of  compliance.  Hence,
   we believe it  is significant to point out that the plants not
   in compliance  by December  1982 will  represent  only 15% of the
   total major plant  flow and that 85%  of  the  sewered flow from
   these facilities will be complying with 1.0 mg/1 phosphorus
   limits.

        The Agreement does not  define 1.0  mg/1 compliance in terms
   of a daily average.   The IJC has been tracking plant performance
   on the basis of an annual  average.   State NPDES  permits,  with
   the exception  of those in  Indiana, have required compliance on
   a  monthly average  basis.  Indiana permits have required compliance
   with a daily maximum  of 1.0  mg/1.  As a result,  the annual  Indiana
   average  for phosphorus removal facilities in  the Great Lakes Basin
   is below 0.8 mg/1.

        On the matter of detergent phosphate limitations,  we find
   the statement  regarding "resistance" by key Great  Lakes States
   to be misleading.  We believe  the fact  that six  out of eight
   Great Lakes States have voluntarily  adopted detergent phosphate
   limits is evidence of strong State support  of  just one of many
   measures available to control  the input of  excessive phosphorus
   into the Great Lakes  system.   It also should be  noted  that  it is
   EPA policy that any ban should be voluntary.

        We  concur, as stated  earlier, that the control of nonpoint
   sources  is an  essential part of any  phosphorus strategy.  But
   we do question several of  the  conclusions relative to  technology
   transfer.   Our experience  with the section  108(a)  demonstration
   program leads  us to the opposite conclusion,  i.e., technology
   can and  has been transferred to other areas.   We are also unaware
   of  the  "EPA and IJC Reports"  mentioned  on page 29  which also
   refer to the lack  of  technology transfer.   We  view section  108(a)
   as only  one of  the available  programs to actually  implement and
   test new nonpoint  source control techniques.   However,  it is our
   policy to  use  this program to  continue  that testing of  innovative
   practices  and  look to our  cooperative efforts  with the States
   and  other  Federal  agencies to  carry  out any long-term  program.
   While we  agree  that no formal  and official  U.S.  nonpoint  source
   strategy has been  adopted, we  again  point to the current  bi-lateral
   negotiations on Annex III, which should address  this question in
   more detail.
                                  85

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APPENDIX IX                                              APPENDIX IX
                                 -4-

  Toxics

  Concerning the  toxic pollution discussion, we generally concur,
  but  three items should be noted.  First, we do have some evidence
  that controls can be effective.  For example, there has been a
  90%  decrease in the levels of DDT in Great Lakes fish since
  that ban was imposed, and there is evidence that levels of
  PCBs are declining in some areas.  Secondly, on page 31, the
  report  should read that the Food and Drug Administration, not EPA,
  is responsible  for setting allowable limits in fish.  And finally,
  the  issue of laboratory capacity and capability is not limited
  to the  Great Lakes.  It is both a national and worldwide problem.

  Water Quality Monitoring

      We  have serious reservations about the water quality monitoring
  discussion, especially as it relates to the Great Lakes International
  Surveillance Plan (GLISP), tributary monitoring, toxics monitoring
  and  quality assurance.  To our knowledge, the IJC has never stated
  that the GLISP  is "biased, incomplete and lacks scientific validity."
  In fact, the IJC has taken no action to approve or disapprove the
  Plan.   Moreover, it is the Parties' responsibility, ultimately,  to
  adopt such a Plan.  From our Agency perspective, the current GLISP
  is a framework  which the jurisdictions use in determining their
  overall program priorities.  It is not, nor do we believe it should
  be,  a rigidly prescribed set of activities and timetables which
  are  unresponsive to changing environmental conditions, knowledge
  gained  through  past experience, and the use of advanced modeling
  techniques.

       The discussion of tributary sampling appears to be a series
  of opinions.  The comments do not, we believe, reflect a full
  understanding of either the site selection process or the
  purpose of tributary monitoring.

       For example, the location of tributary monitoring sites have
  been carefully  selected to avoid lake effects.  Each stream has  an
  estuary near its mouth with complex intermixing of river and lake
  water.  This greatly complicates any river monitoring program at
  these sites.  The plan clearly states that the point sources located
  downstream from tributary monitoring sites are to be treated as
  direct  discharges to the lakes and simply added to the river loadings
  monitored upstream.

      The comments regarding sampling of secondary tributaries lose
  sight of the fundamental purpose of sampling the tributaries,
  which is to determine loadings and not to find sources.  Effluent
  monitoring is a far more efficient method of determining sources
  of nutrients and metals.  Sediment and fish sampling is much more
  efficient for determining sources of most trace organics accumulating
  in the  environment.  Effluent monitoring is not covered by GLISP
  and  is  the responsibility of the discharger under self-monitoring
  requirements of the NPDES permits and the jurisdictions.
                                  86

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APPENDIX IX                                              APPENDIX IX
                                  -5-

      In regard to toxic substances monitoring,  the problem is quite
  different from phosphorus.   We must determine  where they are, where
  they come from, and what threat they pose.   We know relatively well
  where phosphorus comes from and the threat  it  poses.   Toxics are
  not a problem to human health unless the human is exposed to them.
  Humans will be exposed in nearshore areas and  by eating fish.  Toxics
  are most likely to be found near their sources which,  except for
  atmospheric deposition,  are in nearshore areas.  Therefore,  our
  toxics monitoring strategy must concentrate on most probable source
  areas and on fish, both  local and lakewide. Since many toxics
  accumulate in sediments, and sediments can  be  associated with
  sources far more easily  than fish,  sediments are a very useful
  auxiliary monitoring medium.  Our strategy, therefore, is to look
  for toxics in the most probable source areas,  which are harbors and
  rivermouths, and to look at fish from both  the open waters and
  harbors and rivermouths.  Immediate objectives are to  locate hot
  spots, if they exist, and warn the public of any acute concentrations
  in local fish.  Longer-term objectives are  to  establish the  general
  pattern of organic contamination in the basin  and to monitor trends.

       The question of quality assurance and  data comparability is
  also of serious concern  to us, other U.S. jurisdictions and
  Canada.  The draft report,  however, tends to leave the reader
  with a sense that much of the data collected is useless because
  it cannot be compared or verified.   This is not the case.  For
  example, all EPA Great Lakes monitoring grants or contracts
  include requirements for adherence to Agency quality assurance
  guidelines and require that laboratories participate in the
  Water Quality Board's review of both U.S. and  Canadian laboratory
  performance.

       Specifically, the discussion of the adequacy of the the
  Great Lakes Atmospheric  Deposition (GLAD) network data is not a
  true reflection of the current situation.

       When the basic data for the GAO report was being  gathered,
  the upgraded atmospheric deposition network was not implemented.
  The report correctly cited inadequacies of  the old network,
  i.e., lack of equipment, poor collection location, and different
  collection techniques.   The Great Lakes National Program management
  also recognized these deficiencies  and is implementing a plan to
  correct the noted deficiencies.

       "State of the Art"  collection equipment was purchased and
  deployed to the field.   The heart of the collection equipment is
  the Aerochemic Metric Collector,  which is identical to that  used
  in the national acid rain studies.   The bulk collector was
  redesigned to eliminate  leakage,  evaporation,  sample degradation
  and contamination.   The  bulk collector is also capable of collecting
  organic toxics data.   The GLAD network is using the basic equipment
  that has been recognized by the scientific  community with reliability
  for collecting precipitation samples.
                                  87

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APPENDIX IX                                              APPENDIX IX
                                  -6-
        The  GLAD network was  sited  to collect  data from a  variety of
   demographic and  land  uses.   Topographic maps,  emissions data and
   meteorological data were used  to select the network sites.   The
   collectors were  installed  using  EPA guidelines for installing
   ambient air quality monitors.  Thus, local  contamination and
   influences are minimized.   In  many cases,  the  deposition collectors
   are co-located with conventional ambient pollution monitoring.
   While the National  Acid Rain Program is contemplating the additions
   of gaseous monitors,  the GLAD  network is collecting its second
   year of gaseous  pollution  data at selective sites  to determine the
   impact of gaseous deposition.  Collectors on the lakes  are  impractical
   for several reasons.   The  most important reason, disclosed  in a
   recent GLNPO study, is that collectors  on  the  lakes are collecting
   significant amounts of lake water which may mask the atmospheric
   deposition.

         We  appreciate the opportunity to  comment on  this  draft
   report prior to  its publication.  We hope  that you find our
   comments  useful  in  clarifying  the report and its analysis.

                           Sincerely yours,
                                    »*• (SI
                                >h  A.  Cannon
                     ActingXkssociate  Administrator
                   for Policy and Resource  Management
   Enclosure
                                   88

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APPENDIX IX                                            APPENDIX IX
     Corrections, Clarifications and  Comments on GAP Draft Report
     'lTGreat~ Lakes Cleanup Efforts Need More Focus and Direction" ~


    Page ii/  Digest, second paragraph

The first sentence indicates that little funding has been directed
to controlling discharges from combined sewers.  As a matter of
fact, construction grant priority systems do not distinguish between
sanitary and  combined sewer discharges.

Combined sewer overflows continue to  be a problem because utilization
of available  funds for facilities to  treat the more concentrated
portion of these wastewaters has been more effective in improving
water quality.  With achievement of secondary treatment goals and
requirements  on phosphate removal, efforts will be directed toward
treatment of  combined sewer overflows where necessary to achieve
water quality standards.  Increasing  consideration is being given
to nonpoint source pollutants in the  development of wasteload
allocations and effluent limits for publicly owned treatment works
(POTWs) to determine the most overall cost effective solution.  It
may prove to  be more cost effective in some cases to control nonpoint
source phosphorus discharges than to  treat small POTW wastewaters
or provide very high levels of treatment to achieve additional
removal at major treatment plants.


     [GAO Comment:   State construction grant  priority
     systems very often distinguish between sanitary and
     combined sewer discharges and, as discussed on p. 14,
     the States have given combined sewers low priority
     compared to other treatment needs.   We have,  however,
     revised the report (see  p. 14) to state  that available
     funds have been used to  treat more concentrated por-
     tions of wastewater.  Also we agree that  increased
     consideration  should be  given to nonpoint sources
     of pollution,  such as combined sewer overflows, to
     ensure that pollution control efforts are the most
     cost effective.]


The Municipal Wastewater Treatment Construction Grant Amendments of
1981 recognize the problem of combined sewer overflows  by providing
for Step 3 grants after October 1, 1984,  upon request by the Governor,
where such discharge is a major State priority.
     [GAO  Comment:  The  report (see p.  14)  has been  revised
     to  reflect the combined sewer provisions of the 1981
     amendments.]

     GAP Note;   page numbers in this appendix have been
     changed to refer to the final report.
                                89

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APPENDIX IX                                              APPENDIX IX
     Page ii,  Digest, third paragraph

 The statement regarding 41 major U.S. treatment plants  is ambiguous
 with language such as  "may not meet the 1972 agreement  phosphorus
 limitation because the plants may not have the  necessary equipment
 and/or may have  operational difficulties."  This conclusion on
 operation of  treatment plants is not substantiated  in the report
 (page 12)/ but is based on use of a percentage  value derived from a
 1980 report "Costly Wastewater Treatment Plants Fail to Perform as
 Expected".  Such percentage values derived on a national basis do
 not justify this conclusion on water basins. It is suggested this
 statement be  revised to cover only equipment deficiencies.
     [GAO Comment:   We did not use a percentage value
     derived from our  1980 report.   We specifically reviewed
     the  performance of 26 Great  Lakes Basin  plants included
     in the 1980 report and found that 24 of  the 26 plants
     are  not making  permit requirements.]

  Page iii, Digest,  third  and fourth paragraphs

 We  agree with the principal thoughts expressed throughout  the  draft
 report that much needs to be done to further clean up pollution  in
 the Great Lakes Basin.  Considerable effort has already been exerted
 by  EPA, however, to initiate the development and implementation  of
 State and local control  programs, particularly with regard  to  the
 nonpoint sources of pollution.  State and local Agencies have  the
 prime responsibility for control of  these sources.  Under  authority
 provided by the Clean Water Act, the Agency has provided grant
 funds, institutional guidance, and technical assistance to  these
 water quality management agencies throughout the United States,  as
 well as to other Federal and State organizations,  for development
 of  these programs, many of  which are now being implemented.  Although
 other Federal agencies deal with portions of the pollution  problem,
 EPA's water quality management program  is the only Federal  program
 with a mandate to comprehensively address the nonpoint sources.

     [GAO Comment:   We believe the  discussion (see pp.
     26-33)  on nonpoint sources comprehensively sets
     forth  the status  of nonpoint planning and control
     efforts.  While EPA and others have provided funding
     for nonpoint efforts, much remains to be done.]


   Glossary

 The third sentence defining the  term "toxic  substance" should be
 deleted.  Oxygen-consuming substances such  as organic matter are
 not considered  "toxic substances"  by the  Agency.



       [GAO Comment:   The  report  (see glossary) has been
      revised as suggested.]
                                 90

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APPENDIX IX                                               APPENDIX  IX


   Page 5

 The chart omits the  USDA Cooperative Extension Service.   It
 should be included due  to  its major role in providing education
 and assistance for agricultural practices needed to control nonpoint
 sources.  This comment  also applies to Appendix I pages  53  and 54.


      [GAO Comment:  The  Extension  Service  is part of  the
      Science and Education Administration.   As suggested
      by  the  Department of Agriculture, a discussion of
      the Extension Service has been added  to appendix I.
      (See p.  67.]                                 **
   Pages 11  and 12

 While  current estimates indicate that 31%  of  the  larger municipal
 facilities  (flowj> 1 MGD) discharging to the Lower Lakes will not
 have  finished construction to meet phosphorus limits, these plants
 represent only  15% of the total major plant flow.   In other words,
 85% of the sewered flow from these facilities will  be complying
 with  1.0 mg/1 phosphorus limits.  Since the effluent of many U.S.
 plants, having  completed and operating phosphorus removal facilities,
 averages significantly lower than 1.0 mg/1 of phosphorus, it can
 be expected  that the aggregate U.S.  municipal flow  would be at
 1.0 mg/1 or  less at the end of 1982.  This effect was noted in the
 1981 Great Lakes Water Quality Board's Report to  the International
 Joint  Commission.  The report states on page  51  "The Board notes,
 with gratification...these efforts have resulted  in initial achieve-
 ment of an average phosphorus effluent limitation of 1.0 mg/1 at
 all municipal treatment facilities in the  Lower  Lakes Basin, as
 called for in the 1972 Agreement."  The report goes on to note, that
 in Lake Michigan (which lies wholly within the United States) the
 gross  municipal plant effluent averaged 0.96  mg/1 phosphorus in
 1980.   This  was achieved despite the fact  that not  all municipal
 treatment facilities in the Lake Michigan  Basin  have finished
 their  construction programs.


      [GAO Comment:   We do not agree with  EPA.  The discussion
     refers to construction completion dates,  not to  whether
     the  plants will comply with the discharge limits.   We
     do agree, however, that EPA's comment about aggregate
     flow is important and  have revised the  discussion
     (see  p. 12) to  include the information  on flow.]

   Page 12,  first paragraph

  The  attempt of the GAO report to extrapolate its earlier findings
  regarding national plant performance  to Great Lakes plant  performance
  for phosphorus removal is not valid.   As  noted on  pages 15 and
  16,  123 facilities of 240 Great Lakes municipal  facilities discharge
  treated effluent at 1.0 mg/1  or less.  There are 16 facilities
  as per the  cited GLNPO report, whose  1980 loading  data showed
  levels in excess of 1.0 mg/1.  These  16 facilities include:
  A) 2  facilities that completed plant  start-up in FY 1980;  and
  B) 4  facilities experiencing  start-up and/or operational problems.
                                91

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APPENDIX IX                                               APPENDIX  IX


Thus, of the total  139  facilities that should have  been in compliance
only 4 or 2.2% were out of compliance due to poor performance.
It should also be noted that the report does not acknowledge the
existence of interim measures and treatment systems installed by
municipalities having facilities under construction.

This has resulted in a  large number (22) of facilities in early
compliance or discharging at near compliance levels.  Their
effluent levels average well below the 4-7 mg/1 range associated
with municipal effluent not treated for phosphorus.

     [GAO  Comment:  As  discussed  in our evaluation of a
     previous EPA  comment (see p.  90), we did  not  extrapolate
     the  findings  from  our report.   We have, however, revised
     the  report (see  pp.  18 and 19) to more clearly show
     the  status of the  performance of Great Lakes  municipal
     facilities,  as suggested by  EPA.  Also, although munic-
     ipalities with facilities under construction  may have
     installed  interim  measures and treatment  systems,  the
     plants are still not meeting the agreement objectives
     as  discussed  in  the  report.]


    Page 13,  first paragraph

  It is  stated that lack of  funds "has  not been an obstacle  to
  meeting the Agreement  requirements  for  constructing waste  treatment
  facilities." While it  is true  that many other factors  operated  to
  limit  the  pace of construction, funding limits have slowed  municipal
  compliance in several  respects.

  1.  With  the advent of a program for  large Federal grants,
     communities were no  longer willing  to construct facilities
     using  only local funds.

  2.  States have not had  sufficient  funds to provide grants  to  low
     priority projects  which  are typically the small plants  which
     constitute the large number of  plants that will fail to  meet
     the December 31,  1982  deadline.

  3.  During 1973 and 1974,  EPA  attempted to shift funding to  munic-
     ipalities discharging  to the Great Lakes by calling  upon the
     States to give them  added  priority within the  state  priority
     systems.  Congress responded with language prohibiting  such
     priority and in the  Clean  Water Act of 1977 (section 216)
     assigned authority for setting priorities to the States.


     [GAO  Comment:  The report has been revised (see p. 13)
     to  include the matters suggested.]


   Page  14, second  paragraph

 The report under combined sewer overflows cites the 1981
 IJC reports as identifying 51 problem areas.  The  1981
 Water Quality Board report to the IJC identifies 39 areas of
 concern in Canada  and  the United States.  We are unable to
 find a reference to 51 areas.
                                   92

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APPENDIX  IX                                             APPENDIX IX


   [GAO Comment:   The IJC report  was issued  in  1981
   but contains  calendar year  1980  data.  The report
   (see p. 14) has been revised  to  clarify this matter.]

  Page 6,  first  paragraph,  Discharge limits  not being met;

The decision  to reduce the 1 mg/1 limit to 0.5 mg/1  in  the lower
lakes as  per  the 1978 agreement  is pending.

    [GAO Comment:   The remainder  of the discussion (see
    p. 16) sets  forth the status  of this matter.]


  Page 16, last paragraph

The characterization  of large  quantities of "harmful" sludge
generated as  a result of phosphorus  removal process  is incorrect.
The additional sludge being generated  is in no way more harmful
than  that generated by the normal treatment processes.   Second,
at some facilities  the same chemical would be added  for solids
control,  although not in such  quantities.


    [GAO Comment:   The term "harmful"  has been  deleted.
    (See p.  16.)]

   Page 15, second paragraph

 U.S.  municipal facilities  are not required to  achieve as a body
 a 1.0 mg/1 daily  average  limit by the  end  of  1982.


     [GAO  Comment:   The  report (see p.  16)  has been revised
    to show  that the agreement pertains to major dischargers.]

   Page 17 , Table

This  table is potentially misleading in its evaluation of progress
made  in achieving 1.0 mg/1 Total Phosphorus limitation.  This table
 should list total flow presently treated,  not  number of facilities.

      [GAO  Comment:  Information  on  flow has  been added  to
     the report  (see p. 17) as suggested.]

   Page 18,  first  paragraph

 This  same  Task Force report indicated  that existing  treatment
 technologies would not  achieve effluent levels in the range
 0.1-0.5 mg/1.  As GAO's own analysis on page  16  shows,  31% of
 the  facilities meeting  1.0 mg/1 are discharging  effluent having
 0.5 mg/1 phosphorus or  less.

      [GAO  Comment:   We agree that the  technology exists,
     but,  as  the  discussion points  out, many plants are
     having  problems meeting the  discharge limits.   It
     is not  a question of technology,  but performance.]
                                 93

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APPENDIX IX                                            APPENDIX  IX
  Page 18, last paragraph

We do not concur with the GAO  conclusion.  We believe that the
aggregate U.S. municipal flows will reach 1.0 mg/1 and that
interim noncompliance of remaining smaller plants will be
compensated by greater than expected performance of larger
facilities.  Plant performance reviews  in the past year have
shown that many facilities using  existing phosphorus and solids
removal facilities can,  with good operation and maintenance,
remove phosphorus to low levels consistently without new technology.


     [GAO  Comment:  We do not agree.  While good operation
     and maintenance of municipal facilities  is needed  to
     help  achieve the  discharge limits,  we continue to
     believe  that achieving  the 1.0  mg/1 limit  is unlikely,
     as discussed in the report.]


  Pages 20 and  21

The pertinent concern should be whether uncertainty about phosphorus
target loads and inputs  has been  sufficiently reduced to allow the
selection of a logical and reliable course of action.  This question
underlies the summary items which begin in Chapter 2 on page 9
and a series of items on pages 18, 19 and 20.  The first phrase
on page 18 states, "the  Task Force also reported that all that
may now be necessary for phosphorus control on the Lower Lakes
is municipal treatment at 1.0  mg/1" this is substantially repeated
in the first paragraph of page 20.  This is accurate only in the
sense that the extreme range of probability reported by the Task
Force included the possibility that no  further abatement would be
needed.  This is an extremely  remote possibility.  Further work was
reported during the public hearing on the Task Force reportl that
clearly shows that such  action will not be adequate without
further measures.  This  evidence  showed a substantial reduction
in the range of target loads predicted  by the models for Lake Erie.
The result is that the range of load reductions necessary to
meet the targets was also narrowed, thus showing a need to achieve
further load reductions  even under the  full range of possible
outcomes from current control  efforts.

     [GAO Comment:   The report (see pp. 19  and 20)  has been
     revised to  show that additional information made avail-
     able since  the task force report suggests that further
     controls may be needed, rather than maintaining the
     status quo  or even less controls.]


 We agree with the stated need to further reduce uncertainty; but,
 we know that it cannot  be eliminated entirely.  Thus, a prudent
 management strategy includes  the use of low cost measures to
 address nonpoint sources while further efforts are made to reduce
 uncertainties before pursuing higher cost measures, if these prove
 necessary.  This is the central  theme  of the Phosphorus Management
 Strategies Task Force and the informally accepted strategy within
 EPA.  This is also the  approach  developed with the U.S. Corps
 of Engineers Lake Erie  Wastewater Management Study nearing
 completion under section 108(d)  of the Clean Water Act.
                                   94

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APPENDIX  IX                                            APPENDIX IX
     [GAO Comment:  EPA has no assurance  that its approach
     of low-cost controls is really the needed strategy.
     The uncertainties  discussed, if and  when studied,
     could have a dramatic effect on the  U.S.  strategy.
     As stated in the report, we are concerned that efforts
     needed to resolve  the uncertainties  and  their implica-
     tions for future control strategies  may  not be undertaken
     and coordinated.]

  Page  21,  first paragraph

The paragraph  states that the  Task Force included  representatives
from industry.  They were not  actually members of  the Task Force.


     [GAO Comment:   The report  (p.  21)  has been revised
     as  suggested.]

  Page  26

It should be acknowledged that resources available to GLNPO have
been used in a very logical and systematic manner  over the past
ten years in evolving an  agricultural nonpoint source strategy
that is now reflected in  the coordinated EPA/USDA/USCOE projects
in western Lake Erie.

      [GAO Comment:  We do not agree.  We believe that the
      report clearly shows that EPA efforts have been slow;
      have not been comprehensive; and, to a  large extent,
      they have not been coordinated.  EPA, Agriculture, and
      Corps of Engineers efforts in Western Lake Erie are
      discussed in the  report (see pp. 29 to  33)  and the
      discussion shows  that  the efforts have  been limited.
      Also,  the Department of Agriculture stated in its
      comments that coordination with EPA has been hampered
      by a lack of formal agreements between  EPA and the
      Department. ~]

  Page 26,  third paragraph, Nonpoint Pollution Sources Have Received
Little Attention;

    This statement fails to recognize efforts to  control
agricultural and  urban nonpoint sources of pollution.  For
instance, seven out of eight States  bordering the Great Lakes
have developed their agricultural  nonpoint source control priorities
sufficiently to participate in the Department of  Agriculture
administered Rural Clean Water Program.  This pollution control
implementation program requires that State priority  lists for
agricultural nonpoint source problems be developed similar to
the Construction  Grants priority lists.
 1 V.J. Bierman, Jr., Presentation  to the International Joint
  Commission  November 19, 1980
                                  95

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APPENDIX IX                                            APPENDIX IX
 Wa?er S^f J^M* "^ usually Developed as  part of the statewide
              Man?9ement plans.  Five of the seven States which
                       n                 have
            n           Gu6at Lakes t0 represent their most
            pollution problems.

     [GAO Comment:   We believe our assessment  is correct.
     The 1972 agreement  objectives for nonpoint controls
     for agriculture,  forestry, and other  land use  activities
     were not met.   The  1978 agreement nonpoint objectives
     are much broader  and include matters  such as  soil
     losses, land  use  planning and management, and  toxic
     substances.   Little has been done in  any  of these areas,
     particularly  toxic  substances.  As discussed  at length
     in the report,  phosphorus controls for  agricultural
     sources have  been limited (primarily  to the Western
     Lake Erie Basin) , comprehensive implementation plans
     are lacking,  and  control efforts are  voluntary and
     have been slow to be accepted (only 5 to  10 percent
     of the farms  in the Maumee Basin have accepted tillage
     controls) .  The Department of Agriculture also pointed
     out in its  comments that only two projects under the
     Rural Clean Water Program have been in  the Great
     Lakes Basin.   Therefore, we believe that  much nonpoint
     work continues to be needed.]

In the area  of urban nonpoint source control,  the Nationwide
Urban Runoff Program (NURP)  is designed to provide  assistance in
the development of water quality plans and focuses  on determining
the significance of urban  runoff as a source of pollution.  Of the
28 cities participating  in the program, 6 are  located with the
Great Lakes Watershed.  They are:  Rochester,  NY; Detroit, MI;
Ann Arbor, MI; Lansing,  MI;  Chicago, IL; and Milwaukee,  WI .  These
cities, as well as the other 22, are concentrating  on problems they
have identified.  They are determining what pollutants are causing
water quality impacts and  then characterizing  these pollutants as
to concentration, loads, effects, and controllability.

     [GAO Comment:   The  Nationwide Urban Runoff Program
     is a very limited effort.  According  to the program
     director, it  covers only five pollutants, it  has
     received only $6  million in funding nationwide over
     a 3-year period,  and the projects are very specific
     to the communities  in which they are  located.   The
     program director  also stated that the future  of the
     program is  unknown  at this time.]

  Page  28

The Table and first paragraph  statements  that  nonpoint  sources
are the largest contributor of  total phosphorus  are accurate, but
misleading.  The  type of total phosphorus  from nonpoint  source
does not impact algal growth as much as the  type from point  sources
 (primarily  ortho-P).

                                 96

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APPENDIX  IX                                             APPENDIX IX


      [GAO Comment:   The report  (see p. 28) has been revised
      to add the  information  suggested.]

   Page  32

 Discussion of  the section 108(a) Great Lakes  Demonstration Grant
 Program omits  mention of several projects which have addressed
 combined sewer overflows.

      [GAO Comment:  We are aware of only  five section 108(a)
      projects which have been funded  to demonstrate  such
      technology as swirl concentrators and hydrobrakes for
      urban combined sewer  problems.   Also,  this comment
      relates  to a discussion of rural nonpoint runoff,
      not  combined sewers.]


   Page 32, next to  last paragraph

  The  last  paragraph does not  give an accurate  picture of the
  section 108(a) program or  the  GLNPO staff chief's view.  The
  section 108 agricultural  nonpoint source control  demonstrations
  began  with  implementation  and  detailed monitoring of resulting
  water  quality benefits in  the  Black Creek Project in Allen County,
  Indiana.   Based upon  those results and later  results from the
  Corps  of  Engineers project in  the Sandusky River  Basin, current
  projects  have concentrated on  tillage practices.   Careful measure-
  ment of results have  been  used to create and  verify a  computer
  simulation model (ANSWERS) which estimates the results of implemen-
  ting various practices  under various conditions.   Since it is
  far  too costly to monitor  ambient results throughout entire
  river  basins,  the predictive model is used to estimate loading
  reductions based upon information on the adoption of modified
  tillage practices.

      [GAO Comment:  The  GLNPO Chief's comments have been
      clarified  as suggested.  (See  p. 32.)]


   Page 32, last paragraph

  This statement may accurately  reflect the opinion of an EPA
  staff member;  but, it is contrary to our general  experience.
  The  statement is typical of  those made by skeptics  at the outset
  of most tillage projects.  We  do not consider no-till practices
  to be  a panacea,  but  are satisfied as to its  benefits and have
  found  that most skepticism is  reversed by the end of each
  demonstration.

  It is quite true that only 5-10% of farms in  the  Maumee River
  Basin currently use no-till  practices and is  why  demonstration
  projects  are needed.


      [GAO Comment:  Both the IJC  and  Department of  Agricul-
      ture comments on this report  support the  position
      that new technology will be  slow to be  implemented.
      Therefore, we agree that demonstration  projects are
      needed.]


                                 97

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APPENDIX IX                                              APPENDIX IX
   Page 43,  first paragraph

 The second  paragraph contains the statement, "an overall control
 strategy or plan  has not been developed" (for nonpoint sources).
 While we agree  that no formal, official overall strategy has
 been adopted for  the U.S. portion of the Great Lakes,  we submit
 that an informal  and quite workable strategy has evolved among
 the various agencies.  This strategy reflects the knowledge
 gained from studies and demonstrations supported by the IJC and
 various State and Federal agencies and the main recommendations
 of the Phosphorus Management Strategies Task Force.  The strategy
 is incremental  and adaptive in nature, emphasizing the implementation
 of low cost measures while deferring costlier measures while
 further information is gathered.

     [GAO Comment:  We do not agree that an  overall
     strategy exists.  The report  clearly points out  that
     the authority and responsibility for nonpoint  efforts
     is spread among several Federal agencies and  States
     and that the nonpoint problem will be addressed  ade-
     quately only if an  overall, comprehensive strategy
     and plan is  developed to delineate the  responsibili-
     ties of the  many parties involved.]

  Page  56

With respect to the example  of differences between GLNPO and
Region V-Water Division, we  do not dispute that  fact that there
are differences in opinion  between organizational units, usually
due to differences in  the  programs that they administer.  However,
by working closely with operating programs at the Regional Office
level, GLNPO has been  successful in redirecting  program efforts
to optimize operating  program activities to the  Great Lakes
benefit.  It should be noted that during the same time an impasse
developed over the Michigan  State program grant, substantial
modifications were successfully negotiated in the programs for
all five of the other  States in Region V.  It should also be
noted that the delay in  approving the Michigan grant was not  due
to the question of whether GLNPO's concerns would be met, but
due to disagreements between Region V and Michigan concerning
other matters.  Unfortunately, the debate over those other issues
operated to obscure GLNPO's  concern.

Also in respect to GLNPO's  relationship to Region V's operating
divisions, it should be noted that during this same timeframe
GLNPO convened and chaired  the Region V Phosphorus Committee
which has enjoyed outstanding success in obtaining standardized
compliance tracking and  acceleration  of actual compliance by
Great Lakes municipalities.  By focusing attention on key dis-
chargers, the Committee  representatives from enforcement,
construction grants,  and water quality programs  in cooperation
with the State of Ohio,  have been able  to ensure compliance with
target dates and,  in several cases, actually advance the dates
for phosphorus compliance  by as much  as a full year.
                                   98

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APPENDIX  IX                                             APPENDIX  IX
 With reference to the State nonpoint sources strategies, it
 should  also be noted that  they were funded  at the direction of
 the Water Division Director, utilized section 208 funds (funding
 source  administered by the Water Division Director) and will
 provide for priority consideration of Great Lakes impact.   Far
 from downplaying the impact of nonpoint source control, these
 funding actions taken in the face of extremely limited funds are
 solid evidence of the importance attached by Water Division to
 Great Lakes matters generally and nonpoint  source control  matters
 specifically.

      [GAO Comment:  We agree that GLNPO has  achieved  some
      success at its present  level.  But it has difficulty
      getting cooperation from other EPA program offices and
      regions for  its  Great Lakes pollution control activi-
      ties,  and it  lacks  resources to  carry out its respon-
      sibilities.   We  believe that elevating  GLNPO to  a
      higher level  within EPA will help  to ensure that  the
      water  quality agreement receives the resources and
      status it needs  to  meet the U.S. commitments.]

  Page  74

 This  table contains  an  addition error  for Pennsylvania in  the
 1981  column.

      [GAO Comment:  The  addition error  (p. 74)  has been
      corrected.]

   Page 75

 The Funding Table ignores  construction cost of Illinois
 facilities built to eliminate direct municipal discharges  to
 Lake Michigan.

      [GAO Comment:  We agree that the table  (p.  75) does
      not include Illinois facilities as noted in footnote b
      to the table.]
                                 99

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APPENDIX X                                             APPENDIX X
                          DEPARTMENT OF STATE
                                Comptrollrr
                             Washington, D.C. 20520
                                 March 8,  1982
   Mr. Frank C. Conahan
   Director
   International  Division
   U. S. General  Accounting  Office
   Washington, D. C.

   Dear Frank:

   I am replying  to your letter  of  January 26,  1982, which
   forwarded copies of the draft report:   "Great Lakes Cleanup
   Efforts Need More Focus and Direction."

   The enclosed comments on  this report  were prepared by the
   Deputy Assistant Secretary in the  Bureau of  European Affairs.

   We appreciate  having had  the  opportunity to  review and comment
   on the draft report.  If  I may be  of  further assistance, I
   trust you will let me know.
                                 Sincerely,
                                 Roger/B.  Feldman
   Enclosure:
     As Stated.
                                100

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APPENDIX X                                             APPENDIX X
   GAO DRAFT REPORT:  "Great  Lakes  Cleanup  Efforts  Need More
                      Focus  and  Direction"
       I  am pleased  to  comment  on  the  General  Accounting Office
   draft  report  on  implementation  of the  Great Lakes  Water
   Quality Agreement.

       We have noted with  interest the recommendations  of the
   report in favor  of elevating the functions  of  the  Great
   Lakes  National Program  Office to a  higher  level  in the
   Enviromental  Protection Agency.   This  Department would be
   sympathetic to such  a step,  assuming the concurrence of
   EPA.   The Great  Lakes National  Program Office  has  been the
   focus  of US work  to  comply with obligations under  the Great
   Lakes  Water Quality  Agreement with  Canada.   The  Government
   of  Canada places  a high priority on joint,  cooperative
   efforts to protect and  preserve the Great  Lakes.   This
   Department has relied heavily on the Environmental
   Protection Agency and the Great Lakes  National Program
   Office in the US  implementation of  the agreement.

       In considering the  draft report, we have noted the lack
   of  reference  to  work over the past  months  to meet
   US-Canadian responsibilities in two important  areas  under
   the Great Lakes Agreement.   The two countries  developed  a
   proposed supplement  to  the Agreement on phosphorus control
   in  a series of meetings last year.   The draft  text is in
   final  stages  of negotiation.  The US and Canada  have
   recently increased cooperative  efforts to deal with  toxic
   pollution in  the  Niagara River.  Announcement  of new US
   initiatives,  to be undertaken in cooperation with  Canada, is
   expected shortly.  The  inclusion of material on  these
   subjects would enhance  the usefulness  of the report.

       I  hope these  comments are helpful  to you.
                          Thomas M. T. Niles
                          Deputy Assistant Secretary
                           for European Affairs
                                101

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APPENDIX XI                                                   APPENDIX XI
                         DEPARTMENT OF AGRICULTURE

                              OFFICE OF THE SECRETARY

                              WASHINGTON, D. C. 2O250
                                                              MAR0 4)982
    Mr. Henry Eschwege
    Director
    Community and Economic
      Development Division
    U.S. General  Accounting  Office
    Washington, D.C.   20548

    Dear Mr. Eschwege:

    We appreciate the opportunity to  comment on  the GAO draft report entitled,
    "Great Lakes  Cleanup Efforts Need More  Focus and  Direction."

    It is noted that  several persons  from this Department were  interviewed
    during the preparation of this  report.  Agricultural water  quality
    management is a very complex area.   There are several areas covered
    within this report that  require clarification.  Our enclosed comments
    are not suggested word changes, but  comments of clarification  in three
    general areas—coordination, implementation, and  nonpoint sources.

    We hope that  these general  comments  will be  of value to you in  preparing
    your final report.

    Sincerely,
    Enclosure
                                      102

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 APPENDIX  XI                                                  APPENDIX XI

 Comments  on GAP Draft Report Entitled, "Great Lakes Cleanup Efforts Need
 More  Focus and Direction"


 COORDINATION:

 The Great Lakes Basin Commission has been the primary coordinating mechanism
 in the Great Lakes.  The U.S. Department of Agriculture (USDA) did have a
 representative from the Soil Conservation Service (SCS) on the Commission.
 This  group has gone out of existence.  Coordination with the International
 Joint Commission  (IJC) and its Boards has been on an informal  staff basis.
 There is  no formal representation of USDA on any of the Boards at  this time
 but some  informal discussions concerning this have taken place. The SCS
 has had a full-time liaison position with the U.S. Environmental Protection
 Agency (EPA) Region V since 1978.  This position includes liaison  to the
 Great Lakes National Program Office (GLNPO).  The SCS has entered  into an
 agreement (page 28) with EPA and the Corps of Engineers (C/E).  The reduced
 tillage program mentioned was not the primary focus of this agreement but
 was an early action by EPA to implement some of the findings of the
 Lake  Erie Study by the C/E.

 The USDA  Work Group on Water Quality, chaired by SCS has taken this agreement
 and is currently developing a draft departmental position paper regarding
 the Great Lakes.  The reason behind this effort is the development of common
 goals for all of the agencies in the Department as they relate to  their
 individual program responsibilities.

 The persistent problem of coordination is that no formal agreements regarding
 responsibility for implementation of agricultural nonpoint control  programs
 exist between USDA and EPA.  In relation to the Great Lakes, there is no
 mechanism now in place to include USDA representatives on any  of the Boards
 of the IJC where nonpoint source issues can be addressed.
                                                          l
 Implementation of agricultural  nonpoint source control programs must of
 necessity include many of the agencies of USDA.  USDA would welcome the
 opportunity to participate in a coordinated program to correct agricultural
 nonpoint  source water quality problems in the Great Lakes.   We do  not see
 EPA as the director of our activities (page 55) but do see their role as
 handling  coordination.

 The statement (page 57)  that GLNPO has had difficulty in dealing with USDA
 is misleading.   There is good informal staff communication as  already noted.
 The difficulty is that there are no formal arrangements for the EPA or the
 GLNPO to communicate with USDA.   The informal  communications are through SCS
 to the USDA Work Group on Water Quality.

 IMPLEMENTATION:

The implementation which has occurred in the Great Lakes has included USDA
agencies since it depended on the existing agricultural  delivery system
 including Soil  and Water Conservation Districts.  This included technical
assistance,  information  and education, and in some instances additional
cost share funds.   Most  of the  demonstration funds for implementation were
 GAP  Note;   Page numbers in  this  appendix  have  been  changed  to
             refer  to the final report.
                                     103

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APPENDIX XI                                                   APPENDIX XI

                                -2-

directed to the Soil and Water Conservation Districts.  The USDA agencies
assisting these Districts responded to these projects to supply the
necessary support.  These projects were in response to identified problems
and were generally successful.  It required the USDA agencies to respond
to the grant, and did not allow for participation in the selection of project
areas or take into account their existing manpower commitments.

RURAL CLEAN WATER PROGRAM:

The section on the areawide planning program (page 63) refers to Section 208j.
This amendment to Public Law 92-500 in 1977 has not been funded.  The
experimental Rural Clean Water Program was included in the USDA budgets
(Public Law 96-108) in 1980 and 1981 with funding levels of 50 and 20 million
dollars respectively.  It is administered by the Department's Agricultural
Stabilization and Conservation Service (ASCS) as stated.  This section and
the paragraph on ASCS (pages 32 and 57) confuses Section 208j of the
Clean Water Act and the present experimental Rural Clean Water Program.  It
should be noted that the Great Lakes area received additional consideration
in the selection of projects for 1980.  Only two projects presented a
sufficiently strong proposal for selection.

NONPOINT SOURCES:

Several references are made to the fact that technology cannot be transferred
(page 33) from one project area to another.  It is true that individual
watersheds are different from the standpoint of soils, land use, farming
enterprises, runoff characteristics, etc.  It is likewise true that not all
streams are impacted by pollution from agriculture.  It is also true that
other nonpoint sources do exist and may contribute pollution to streams
within an agricultural area.  It is the implementation program that is site
specific rather than the technology.  It is necessary to determine within each
new project area the cause or causes of the problem and to tailor the
implementation program to treat the cause.  The minimum or no-tillage program
(page 32) referred to was an effort to accelerate the adoption of the technique
in those counties where adaptable soils were present as identified by the
Lake Erie Study^ not to sites identified, as stated.  The monitoring program
mentioned is to tract the adoption rate not the water quality benefits.  This
program is designed to run for three years.

The adoption of minimum or no-till technology is slow because of the need for
new equipment and increased managerial skills.  When increased technical
assistance is made available to assist with learning these new skills,
adoption rates increase rapidly.  The programs funded by EPA in the
Lake Erie Basin are designed to provide this assistance from employees hired
by Soil and Water Conservation Districts.  The reluctance of farmers to
adopt these new practices (page 33) is not the result of higher costs or
lack of desire.  Minimum and no-till technology requires new managerial skills.
It has been demonstrated that increased technical assistance will accelerate
the adoption rate.  The present statement in the report indicates an overall
reluctance to adapt which is misleading, if not further qualified.
                                      104

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APPENDIX XI                                                   APPENDIX XI
                                - 3 -


 The  section  on  Sewage Treatment Goals  (page 11) suggests that the
 United  States is doing a less adequate job than Canada in municipal
 point source control.  It does not take into account the vast difference
 in the  magnitude of the needs of the two countries.  The 1981 Annual Meeting
 of the  International Joint Commission reported substantial progress by the
 United  States in meeting the goals of the agreement.

 The  paragraph about the Science and Education Administration (SEA)
 (page 67) does  not reflect the current agency status of the Agricultural
 Research Service (ARS), Cooperative State Research Service (CSRS) and the
 Extension Service  (ES).  The Extension Service is not listed.  A suggested
 statement for their function is as follows:  "The Extension Service staff
 administers  Federal funds for conducting Cooperative Extension education
 programs."

 The  planning efforts (page 29) referred to were authorized by Section 208(a)
 rather  than  Section 208(b).  The reference in Appendix I (page 50) referring
 to the  cost  share rate under the experimental Rural Clean Water Program should
 state that...owners and operators may receive Federal matching funds for up
 to 75 percent...
                                       105

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APPENDIX XII                                           APPENDIX XII
                     INTERNATIONAL JOINT COMMISSION
                         UNITED STATES AND CANADA
                          WASHINGTON, D.C. 20440


                         February 26, 1982
   Mr. Frank C. Conahan
   Director, International Division
   United States General Accounting Office
   Washington, D.C.  20548

   Dear Mr. Conahan:

       The International Joint Commission has received the GAO
   report entitled, "Great Lakes Cleanup Efforts Need More Focus
   and Direction" for Commission review and comment.  The
   Commission appreciates the opportunity to provide comments
   regarding the report and hopes they are of value to the GAO.

       Commission staff has been encouraged to comment on both the
   general thrust and specifics of your report.  Attached you will
   find these general and specific comments.  We hope you find
   them useful as your prepare your final draft.  Should you have
   questions regarding these comments, please do not hesitate to
   contact me at (202) 673-6222.

                                Yours very sincerely,
                                David A. LaRoche
                                Secretary
                                United States Section
   Attachment
                                  106

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APPENDIX  XII                                          APPENDIX XII
                 Comments on Draft  GAO Report:
                 Great Lakes Clean-Up  Efforts
                 Need More Focus  and Direction


 Page 4, para 4,  line  5:  The participation by  states  in Great Lakes
 cleanup activities  is  basically under the federal mandate. The state
 programs are not usually designed to specifically address Great
 Lakes concerns,  but rather are state programs  which have been
 incorporated -into the  federal Great Lakes program.  It is somewhat
 misleading, therefore, to imply that the states have  active interest
 in Great Lakes cleanup efforts, per se.  Since the Agreement does
 not have the force  of  domestic law, the main effort must rest on the
 federal level.


      [GAO  Comment:   While we agree that States'  partic-
      ipation in Great Lakes activities is under the
     Federal mandate, we do not  agree that our charac-
     terization of  the States' roles  is misleading.
     The report clearly notes that the agreement does
     not have the force of domestic law, but U.S.  environ-
     mental laws provide for a strong State role in
      implementing environmental  programs.  In particular
     the Clean Water Act, which  is a  major factor  in
     U.S.  Great Lakes cleanup efforts, provides for
     an active State role.]

 Page 4,  para 4,  line 6:  Other federal  agencies do support
 activities related  to the Agreement. It must  be recognized,
 however, that the relative efforts of the  Departments of
 Agriculture, Commerce, Defense,  Interior,  Transportation,  etc.,  in
 regard  to  Great  Lakes' matters vary considerably.

      [GAO  Comment:   We believe that appendix I clearly
     spells out the roles and responsibilities of  the
     various Federal agencies.]


 Page 5, para 4,  line  4;  It is stated that the efforts of the above
 noted groups in Agreement activities "must be  tied  to the
 International Joint Commission".  The meaning  of this statement is
 unclear.  The IJC relies heavily on the goodwill of the various
 agencies associated with the Agreement.  This  goodwill and
 cooperation is a mainstay of IJC activities in regard to Agreement
 commitments and, indeed, the work of the Commission in general.
 There is,  however,  no  mandate which requires these  agencies to work
 with the IJC.

      [GAO  Comment:   The report (see p. 5) has been
     revised to  make it clear that efforts of agencies
     and departments involved in Great Lakes activities
     should be coordinated with  IJC.]

GAP Note;   Page  numbers in this  appendix have been changed
            to apply to the final  report.


                                107

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APPENDIX XII                                          APPENDIX XII
 Page  5, Figure;  The Department of  Transportation should be added to
 the  "Canadian Agencies" box.   The Great Lakes Basin Commission and
 the Water Resource Council should be  omitted from the "U.S.
 Agencies" box, since these agencies no longer exist.

      [GAO Comment:  The Canadian  Department of Trans-
      portation has been added to  the  chart and a  footnote
      has been added to show  that  the  Great Lakes  Basin
      Commission has been terminated.   The Water Resources
      Council  continues to exist,  however.]


Page 6, para 4, 1st item in list:   It is stated  that  GAO contacted
EPA headquarters in Washington, Region V,  the Great  Lakes National
Program Office (GLNPO)  and the  Large Lakes Research  Station to
obtain information for  its report.  Was the EPA's Environmental
Research Laboratory in  Duluth,  Minnesota contacted?   Research
related to the Agreement is conducted at this laboratory.  If it  was
not contacted, this is  a noteworthy omission.

      [GAO Comment:  EPA's Environmental Research
      Laboratory was contacted during our review and
      has been added to the report.   (See p. 6.)3


Page 7, para 3, line 15;  It is  stated that EPA headquarters staff
were interviewed by the GAO.  Unfortunately, EPA headquarters
appears to have displayed  little interest  in recent  years for the
Great Lakes  Basin as an international concern.   It is unclear,
therefore,  that relevant insights can be  obtained from this source.
The IJC experience is that there is somewhat of  a "gulf" in recent
years between  the interests of  EPA's headquarters staff  and those of
EPA Region V regarding  the requirements of the Great  Lakes Water
Quality Agreement.

      [GAO  Comment:  EPA  headquarters plays an important
      role  in  carrying out U.S. environmental  programs,
      and  therefore  it was important that headquarters
      staff  be contacted  and  interviewed.3

 Page  8, para  3, line 11;   It  is stated that staff of  the Council on
 Environmental  Quality were interviewed.   It is noted, however, that
 most  of the information on the Great Lakes  in recent  CEQ reports has
 been  supplied  by  IJC headquarters  staff in  Washington.
      [GAO  Comment:  Information  provided to us by CEQ
      may have been  provided  initially by the  IJC  staff,
      but  CEQ  plays  an important  advisory role in  U.S.
      environmental  activities.   Therefore, the views
      of the CEQ staff were  important to  us.]

 Page 10, 5th item  in  list;   It is stated that  the Great  Lakes
 continue to experience problems because effective surveillance and
 monitoring  activities have not been developed and implemented.  This
 is only partially  true since  some  information is, in  fact, obtained
 as a  result of  these activities.  The major problem  is  that  such
 activities  are  not  sufficient to give a comprehensive indication of


                                 108

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 APPENDIX XII                                          APPENDIX XII
 \          	        		    	
 overall water quality^conditions and trencfs in the Great Lakes.
 Rather, attempts are made to extrapolate  overall conditions based on
 the concentrations of a limited number of conventional and toxic
1 pollutants.  This can lead to erroneous conclusions, since some
 pollutants in the lakes do not respond in the same manner nor in the
 same time frame to clean-up efforts as do other pollutants.


      [GAO Comment:  The report (see p.  10) has  been
      revised to state  that comprehensive and  effec-
      tive surveillance and monitoring  activities
      have not been developed.]

 Page 11,  para 4, line 9:  It is stated that meeting the requirements
 for secondary treatments satisfies  the 1978 Agreement requirements
 for adequate municipal treatment.   This is incorrect, at least in
 regard to phosphorus limits.  The Agreement calls for a 1 mg/L
 phosphorus effluent limit for municipal wastewater treatment plants
 discharging more than one million gallons per day.  This limitation
 usually requires some degree of phosphorus removal at the plants,
 which is not normally a component of secondary treatment.


      [GAO Comment:  A  footnote has been added to the
      report (see p. 11)  to indicate that phosphorus
      limitations are discussed separately later in
      the chapter.]
 Page 11,  para  5, line~T;  It is stated  that only 64 percent of the
 sewered population in the U.S.  portion  of the Great Lakes Basin has
 adequate  sewage treatment, compared  to  99 percent in Canada.   It
 would be  informative to point out the scale of the effort in both
 countries.  With a U.S. basin population of approximately 30 million
 people versus  about seven million in the Canadian basin, this means
 approximately  19 million people in the  United States are sewered
 versus about seven million in Canada.   Thus, if absolute numbers are
 considered, one could conclude that  the U.S. have achieved an effort
 almost three times greater in scope  than that of Canada.
      [GAO Comment:  No  doubt the U.S. effort  has been
      larger than Canada's in terms of absolute numbers,
      but as also noted  the U.S. Great Lakes Basin popu-
      lation is much larger than Canada's.  Also, although
      Canada has the right to 50 percent of the assimila-
      tive capacity  of the Great Lakes (with the exception
      of Lake Michigan),  the United States currently con-
      sumes a much greater percentage because  only
      64 percent of  the  sewered U.S. population receives
      adequate treatment.  /Therefore, we believe that the
      report accurately  reflects the U.S. contribution
      to Great Lakes pollution problems.]
                                 109

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APPENDIX XII                                           APPENDIX XII
Page 12, para 2,  line  3;  A 1980 GAO report on wastewater  treatment
plants is cited as  a basis for the observation that municipal
facilities nationwide  are experiencing severe problems  which limit
their ability  to treat wastes.  It should also be pointed  out,
however,  that  more  overall effort has probably been expended in the
Great Lakes Basin toward the proper operation of municipal
facilities, in large part because of the requirements of the
Agreement.  It may  not be appropriate, therefore, to compare or
extrapolate the results of a nationwide study (in which operation of
municipal facilities may not have the same priority)  to conditions
in the Great Lakes  Basin.

     [GAO Comment:  We did not  extrapolate the results
     of  our 1980 nationwide report.  The discussion
     clearly  shows that we specifically reviewed the
     performance of  26 Great Lakes Basin plants included
     in  our report and found that  24 are not  meeting
     their permit requirements.   Plants in the Great
     Lakes Basin may have received more attention and
     effort in terms of proper  operation, but they  are
     still not meeting their permit conditions.]

Page  13, para  3f  line  2:   It is stated that the 1978 Agreement
requires pretreatment  for  industrial wastes discharged  into
municipal treatment systems.  This is only partially correct.  The
Agreement requires  pretreatment for  industrial wastes only where
such wastes are not amenable to adequate treatment or removal using
conventional municipal treatment  processes.  The Agreement does  not
automatically  require  pretreatment of industrial wastes.


     [GAO Comment:   The report  (see p. 13) has been
     revised  to clarify this matter as suggested.]

Page 14,  para  I, lines 6 and 7; It is stated that  only "limited  progress"
has  been made  in regard to control of combined  sewage discharges.
The  title  of this  section,  however,  says  that such discharges
"continue unabated".  It is  suggested the correct  observation is
that  limited progress has been made.

      [GAO Comment:   The caption for this section
      (see p.  14)  has been changed as suggested.]


Page 15, para  I, line 1;  A 1979 GAO report is  cited as the source
of a number of innovative/alternative technologies for control of
combined sewer overflows.  It is worth  noting  the indicated
 technologies were  suggested earlier as  possible nonpoint  source
control  measures in the 1978 PLUARG Final Report to  the IJC.

      [GAO Comment:   We do not  believe that additional
      reference to the IJC report is needed.]
                                 110

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APPENDIX  XII                                           APPENDIX XII
 Page 16, para 1, line  3;;  It is stated that more accurate  data  on
 phosphorus inputs and an understanding of the eutrophication  process
 is  necessary for the United State to select the most "effective  mix"
 of  phosphorus control programs.  This is misleading.  More  accurate
 data and understanding would obviously be helpful in selecting  such
 measures.  However, various mixes of point and nonpoint measures
 have already been suggested by several Great Lakes'  groups,
 including PLUARG and Task Group III.  These suggested mixtures  have
 a considerable technical basis and should be given more serious
 considation by the Governments.

      [GAO  Comment:  This  comment  is  the same as  the  first
     comment on p. 117  and is addressed there.]


 Page 16, para 2, line  5:  It is stated that the 1972 Agreement  calls
 for a  daily average of 1 mg/L in sewage treatment plant effluents.
 It  should be indicated, however, that the annual average
 concentration has been used in recent years as the basis for
 assessing how well the jurisdictions are achieving the 1 mg/L
 effluent limitation.

      [GAO  Comment:  The Governments  may be using  an
     annual  average,  but  the 1972  agreement calls  for
     a daily average.   EPA raised  the same comment,
     which is addressed on p. 46.]

 Page 16, para 2, line 12;    it  is  stated  that  the pnosphorus
 limitations  in  the 1978  Agreement do not  take affect until the
 Governments  have determined the  allowable future phosphorus loads
 ("target loads") for the Great Lakes and  that this  has not yet been
 done.   It  should also  be mentioned  that this should have been done
 by  May 22,  1980, 18 months  after the signing of the 1978 Agreement.
 The Governments have,  in fact, extended this date twice since then
 and have still  not reached  formal agreement concerning allocation of
 the loads  between  the  two  countries.  Until this is done,  it is not
 likely that  there  will be  any  significant concern paid to  the more
 stringent  phosphorus requirements called far in the 1978 Agreement.

      [GAO Comment:  The report (see  p.  16) has been
      revised to incorporate this  suggestion.]

 Page 16, para  3,  lines 3 & 6;  Reference  is  made to the 1972
 requirement of  a  "daily  average  discharge  of  1 mg/L".  A subsequent
 reference  is made  to  a federal  requirement  of  a  "maximum phosphorus
 discharge  of 1  mg/L".   This inconsistency  should be corrected.  An
 average versus  maximum concentration are  two different concepts.  A
 maximum phosphorus discharge  of  1 mg/L can  be  considerably more
 stringent  than  an  average  concentration of  1 mg/L.   The same general
 comment regarding  the  meaning  of the word "average"  applies  to  the
 next several pages.


      [GAO Comment:  As noted above,  the 1972  agreement
      calls for a  daily average.   The report (see p.  16)
      has been revised,  however, to be consistent with the
      terms of the permits, which  with tne exception of


                                 111

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APPENDIX XII                                           APPENDIX XII
     Indiana,  require a monthly average discharge of
     1.0  mg/1.   Indiana pe-rmits require a daily maximum
     discharge of 1.0 mgl . ]

Page 16., para 4,,  line 12:   Reference  is made to large quantities of
"harmful sludge"  resulting  from  phosphorus removal efforts.  Sludge
can, in fact,  contain elevated levels of heavy metals and other
pollutants, depending on  the types  of wastes entering a waste
treatment plant.   It is not necessarily true, however, that all
sludges contain such pollutants.  If  a treatment plant receives
primarily municipal wastes  and little or no industrial wastes, the
resultant sludge is often an excellent fertilizer for crops.  Heavy
metals and pollutants in  sludge  usually become a problems only when
a sewage plant receives  significant quantities of industrial wastes,
in addition to municipal  wastes.


     [GAO Comment:  We agree that not all sludge is
     harmful  and have revised  the report as  suggested.
     (See p.  16.)]


 Page 17, para  1, line 4t     it is stated that it is unlikely many  U.S.
 municipal plants will be achieving a "daily average" phosphorus
 discharge of  1 mg/L  by December 31,  1982.   It should also be pointed
 out, however, that the 1978 Agreement does not indicate  a phosphorus
 limit  based on a daily average.   It  is the understanding of the  IJC
 that the  1 mg/L effluent limitation called for in the 1978 Agreement
 refers to a monthly  average concentration, at least in the current
 phosphorus negotiations of  the Governments.   The "daily  average"
 limitation called for in the 1972 Agreement has,  in fact, been
 ignored  in recent years and instead the annual average has been  used
 as  the basis for the limitation.
           Comment:  We agree that the daily average
     limitation called for in the 1972 agreement has
     been  ignored.  The 1972 limitation remains in
     effect,  however, because phosphorus  allocations
     called for in the 1978 agreement have not yet been
     agreed to by the Governments.  This  matter is fully
     discussed on p. 16 of the report. 3

 Page 17, para 4, line 5;    it  is stated that once the phosphorus
 target loads are agreed upon,  a 0.5 mg/L effluent limitation  for
 municipal  treatment plants  will take effect for the lower lakes.  It
 should be  noted that this effluent limit applie^       he <-*
 necessary  to achieve the proposed phosphorus ta^yet loads.  The
 particular "mix" of measures  to achieve the allocated target  loads
 is actually left to the discretion of the two countries.   The only
 requirement is that the loading allocation be met in each country.
 It is  possible, for example,  that the United States may employ some
 nonpoint source control measures in place of more stringent  sewage
 effluent limitations.  This particular aspect of the Agreement
 should be  kept  in mind when examining the effluent "requirements"  of
 the Agreement.


                                 112

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APPENDIX XII                                          APPENDIX XII
      [GAO Comment:   The report (see  p.  17)  has been
      revised to show more clearly that  the  0.5 mgl
      limitation applies only where necessary to achieve
      the proposed phosphorus target  loads.]

 Page  IB, para 2, line 4:  It is stated  that the IJC Phosphorus
 Management Task Force suggested that effluent  limitations  in  the
 range of 0.1-0.5 mg/L may be needed for the lower  lakes.   This  is
 only partially correct.   The Task Force presented  this  range  only  as
 a possibility if other suggested measures  did  not  prove effective.

      [GAO Comment:   The report (see  p.  18)  has been
      revised as suggested.]

 Page  18, para 2, line 5;  Reference is  made to the January 1981 IJC
 supplemental report on phosphorus.   It  is  stated that the  IJC
 recommended that Governments adopt an interim  strategy  requiring
 most  municipal plants on Lakes Erie and Ontario to be operated  at  a
 level below 1 mg/L.  This is not correct.   The IJC suggested
 phosphorus limitations below 1 mg/L be  implemented where  it is  found
 to  be technically and economically feasible.  It was  recommended
 that  the Governments assess the ability of plants in  the  Basin  to
 achieve  concentrations below 1 mg/L,  and where it  is  found to be
 relatively easy to do so, a more stringent limitation be  considered.


      [GAO  Comment:  The report (see  p.  18)  has been
      revised as suggested.]

 Page  19, para 2, lines 5 and 6;  It  is stated that  the 1972  and  1978
 Agreements advocate detergent pnosphate limitations.   It  should also
 be  indicated, however, that  these limitations  are advocated only as
 necessary  to achieve  the target loads.   Neither the  IJC nor the
 Governments have advocated a limitation other  than as a possible
 measure  for helping to achieve the target  loads.


      [GAO Comment:  The report (see  p.  19)  has been
     revised as suggested.]

 Page  19, para 2, line 4;  Reference is  made to the 1972 and 1978
 Agreement limitations on phosphorus in  detergents.  It  should be
 pointed  out that this requirement relates  to household  detergents
 rather than all types of detergents,  at least  in the  1978  Agreement.

     [GAO Comment:  The report (see  p.  19)  has been
     revised  as suggested.]

Page 19,  para 2,  line  8;   Reference  is  made  to  "increased costs to
consumers"  as a  result of detergent phosphate  limitations.  It  does
not appear,  however,  that any states other than Ohio  and
Pennsylvania  (where no limitations are  currently in effect) have
brought up the  issue  of  increased costs to consumers.   Where  the
detergent phosphate limitation currently exists, there has  been no
significant reference  by consumers  to increased costs.
                                 113

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APPENDIX XII                                           APPENDIX XII
     [GAO  Comment:  We believe that the discussion
     clearly shows that Ohio  and Pennsylvania  have
     opposed the ban on the basis of increased costs
     to the  consumer.  We have no knowledge  of consumer
     concerns or the lack thereof in other States.]

 Page 19, para 3f lines  4 and 6;   It is stated  that  the  Great Lakes' states
 have been  slow to  implement detergent phosphate limitations.   This
 is an incomplete  statement.  Those  states that did implement  a
 detergent  phosphate limitation did  so relatively quickly.   The real
 problem is that not all the states  have implemented a limitation
 and, therefore,  it is not a Basin-wide requirement.  This  factor has
 been the  basis for some controversy in the Basin regarding the need
 for detergent phosphate limitations.


     [GAO  Comment:  We have revised the report (see p.  19)
     to eliminate the reference to some States being
     slow  to implement the ban and have clarified the
     discussion.]


Page 19, para 3, line  12;   It  is stated that various  Great Lakes
states have enacted detergent phosphate limitations,  but that the
process took some time after controls were first believed
necessary.   Again,  this  is  an  incomplete statement  (see above
comment).   It is also  stated that Canada's limitation  is 2.2 percent
(by weight) as opposed 0.5  percent in the United States.  This
uneven limitation has  been  the  basis for some controversy in the
Great Lakes community.  The observation has made that  while Canada
enacted a detergent phosphate  limitation relatively quickly
following the signing  of  the 1972 Agreement, the Canadian limitation
is less stringent than that presently in effect in  most of the U.S.
portion of the Basin.   It  is unfair, therefore, to  directly compare
the extent and timing  of  the Canadian and United States limitations.


     [GAO  Comment:   The report (see p. 19) has been
     revised to eliminate the reference to the length
     of time needed  to implement  the phosphorus limita-
     tions and to clarify that the higher Canadian
     limitation has  been  the  basis for controversy.]

Page 19, para  4, line 3;  It is stated  that  the Soap and Detergent
Association  believes  it is more cost-effective  to remove phosphorus
at sewage  treatment plants than to  limit  its use in detergent.   This
belief  requires  some  additional discussion.   The industry  belief is
that when  all  direct  and indirect costs are  considered,  it is  more
cost-effective overall to remove phosphorus  at  sewage treatment
plants.  These costs  include the projected costs for additional hot
water,  whiteners,  water softeners,  etc.,  which the industry contends
are necessary to achieve the cleaning power  of  phosphate
detergents.   The industry position, however, does not have overall
 acceptance in the  Great Lakes community.   The IJC has itself  raised
 a concern  that the soap and detergent industry has not considered
 all the possible phosphate substitutes in its cost-analysis studies
 and, therefore,  its conclusions  may be premature.


                                  114

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APPENDIX  XII                                           APPENDIX XII
     [GAG Comment:  The discussion (see p.  19)  has
     been revised to note  that the industry believes it
     is more cost effective overall to remove phosphorus
     at treatment plants and to indicate the additional
     costs.]


  Page 19,  para 4, line 12;    Reference is made  to a  1979  Colorado State
  University  report to NOAA which states that  detergent  phosphate
  limitations would have little or no observable effect  on  overall
  Great Lakes water quality.  This is only a partial  conclusion which
  does not address the entire question.   Little or  no effect will
  likely be seen  if the waterbody is only considered  on  a whole lake
  basis.   If the  various sub-basins and  nearshore regions of the Great
  Lakes are considered, however, the results and conclusions would  not
  necessarily be  the same.   The conditions considered in the study
  have no  direct  relevance to expected conditions within the
  sub-basins or the nearshore regions.  The  effect  of "averaging" the
  effects  of a detergent phosphate limitation  across  the entire lake,
  as was done in  this study, is technically  inappropriate.  Inputs  of
  phosphorus  at specific points in a lake can  have  significant impacts
  on a regional or local basis which would be  masked  if  only the
  average  whole-lake load and response are considered.


     [GAO Comment:  The additional information  provided
     by IJC  on sub-basin and nearshore areas clarifies
     the  overall position  of the Colorado  State Univer-
     sity study, and therefore we have eliminated the
     discussion of the study from'the report.]


 Page 19, para 4,  lines  20 and 21;   it  is stated  that the iJC's  Phosphorus
 Task Force reported that  a  1 mg/L effluent limitation may be all
 that is necessary for phosphorus control in  the two lower lakes.
 This may  be true, but only  if  several assumptions regarding the
 range of uncertainties around  the input  loads  and the lakes
 responses are  correct.  There  is an equally  valid possibility,
 however,  that  more stringent control measures  may be necessary if
 the other extreme in  the  assumptions is considered   It is more
 significant, in fact,  that  the  Task Force endorsed  achievement of
 the target loads in spite  of these  uncertainties.   Assuming
 "average" conditions  exist  in  the  lakes  (as Task Group III did),
 more  stringent  control measures  may well be necessary for the lower
 lakes.


     CGAO Comment:  This matter is discussed on p. 18
     of the  report and a reference to that discussion
     has  been made on p.  20.3

 Page 20,  para 2, lines 13-18;  A number  of reasons  are given as
 rationale  for the detergent phosphate limitations.   An  additional
 rationale  not mentioned is that there are a number of "marginal"
 plants existing  in the Basin, i.e.,  plants  which barely achieve
 their 1 mg/L effluent limitation.  If the detergent  phosphate
 limitation were  suddenly  removed, these  plants may no longer be able
 to meet a  1 mg/L effluent  limitation.  As noted on page 17,


                                 115

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APPENDIX XII                                           APPENDIX XII
 detergents account for about 20-35 percent  of  the phosphorus
 entering  wastewater treatment plants.   Therefore, an immediate
 increase  of about 20 to 35 percent in  the quantity of phosphorus
 entering  municipal treatment plants would be expected if the
 detergent phosphate limitation were suddenly removed.  Under such
 conditions, marginal plants may no longer be able to achieve their
 effluent  limitation.

     [GAO Comment:   The report  (see  p. 20) has been
     revised  to incorporate the suggestion about the
     effect of detergent phosphate limitations on
     "marginal" plants.]

 Page 20f para 3, lines 6 and 7;  The suggestion is made that uncertaintj.es
 regarding the  extent oTTthe phosphorus problem exist in part because
 the Governments have not been able to  calculate  "valid" phosphorus
 target loads.   This is a misleading statement.   The methods used to
 develop the Agreement target loads have undergone refinement since
 they were first used.  However, subsequent  analyses with these
 refined methods produce target loads which  are basically the same as
 the original  target loads.  The Agreement  target loads are, in fact,
 still  the "best"  estimates that have been  developed to date.  It is
 unlikely  that  better target loads will be  developed in the
 foreseeable future.


     [GAO Comment:   The report  (see  p. 20) has been
     revised  to recognize more  clearly the difficulty
     in resolving these uncertainties.  We agree that
     the  proposed target loads  are the best estimates
     developed to date and it may be unlikely that
     better target loads will be developed in the future.
     We believe these matters are fully set forth in
     the  subsequent discussion.]
 j*age 20, para 3, lines 10 and 11;  It is stated that phosphorus going into
 the lakes  is "harmful".  In this case, "harmful"  refers  to the
 excessive  growth of algal blooms which interfere  with  the beneficial
 use of the water resource by man.  Phosphorus,  per se,  is not a
 harmful pollutant  in the same sense as toxic substances.


     [GAO  Comment:  The report  (see p. 20) has  been
     revised as suggested.]
                                 116

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APPENDIX XII                                           APPENDIX XII
 Page 20, para 3, lines 14 and 14;  it is suggested that  without more
 accurate phosphorus  input  data and understanding of the
 eutrophication process,  the most  "effective mix" of control programs
 cannot be selected.  This  is a misleading statement.   Does the word
 "effective"  mean cost-effective?  If so, PLUARG, the  Phosphorus
 Management Task Force  and  the IJC have already proposed a mix  of
 phosphorus control measures which they deem to be cost-effective,
 given the present state  of  knowledge and experience.   It is not
 accurate, therefore, to  say that  the United States cannot now  select
 an effective mix of control programs.  It is also observed that a
 lake does not  care how the phosphorus load is reduced; rather, it  is
 only important that  it be  reduced.  Thus, the notion  of "effective"
 or "cost-effective" can  make a convenient smokescreen for those who
 desire no further phosphorus control measures at the  present time.


     [GAO Comment:   We  do  not  agree.  We believe that the
     resolution of these uncertainities is very important.
     If  the  uncertainties  are  not resolved,  the Governments
     could spend substantial resources on actions  which
     may later prove  to be unproductive or marginally
     productive.  EPA agrees these uncertainties need
     to  be studied,  as  we  stated on pp. 20 to 23 of the
     report, to allow selection of the most  prudent
     control strategies.]


 Page 20, para 4, line 1;     It is  stated that  the 1978  Agreement
 requires the Governments to confirm what the  future phosphorus loads
 "should  be".   It  is more accurate to use the  words "would  be".

     [GAO Comment:   The report  (see p. 20) has been
     revised as suggested.]

 Page 21, para 2, line 1;     It is stated that the IJC established its
 Phosphorus Management  Task Force  "to help the governments" meet the
 Agreement objectives.  This is not the case.  The Task Force was
 established to answer  a  number of unresolved phosphorus questions
 arising from the PLUARG  study and the Water Quality Board.  The
 Governments have, of course, subsequently used the reports of  the
 Task Force and the IJC in  their own work.

     [GAO Comment:   The report  (see p. 21) has been
     revised as suggested.]


 Page 21, para 3, line 4;     It is stated that  many uncertainties
 regarding phosphorus control must be dealt with so that future
 management decisions can be made more reliable.  It would be better
 to use the world  "should" instead of "must".  While uncertainties
 may make selection of  a  phosphorus control program more difficult,
 it is  not necessary to completely clear up such uncertainties  before
 effective phosphorus management decisions can be made.

     [GAO Comment:   The report  (see p. 21) has been
     revised as suggested.]
                                 117

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APPENDIX  XII                                          APPENDIX XII
 Page 22, Table;   Footnote C contains  a  comment  regarding uncertainty
 and error in the modelling process.   However, an  assumption inherent
 in this footnote is that all the  associated  errors are going to be
 additive in nature   This is in effect  an  assumption of worse case
 conditions.  It  is equally possible that the errors may work to
 cancel each other out,  at least in  regard  to their effect on the
 ultimate predictions of a model.  The result, therefore, may be a
 reasonably accurate estimate or prediction.  Such possibilities must
 be examined on a case-by-case basis.

      [GAO Comment:   The language used in the footnote
      is  not our  language but that of  the task force.
      The errors discussed may, as the comment suggests,
      be  additive,  but  we must present the  information  as
      set forth by  the  task force.]

 Page 22, para 1,  lines 2  and 3;  it  is stated that the two errors measured
 by the Task Force could justify management decisions ranging from
 doing no additional work to implementing massive  new control
 phosphorus programs.  The comment made  above about the additive
 nature of error  also applies here.  The extreme conditions  assumed
 in the above statement  do not necessary apply in  a given situation
 or even under normal conditions.  Managers usually plan Tor
 "average" conditions.  They would normally use  average load,
 responses, etc., in their management  calculations.  There is little
 justification, therefore, for concluding either that no additional
 work will be needed or that massive new programs  will be needed.
 The  same comment applies to the use of  "optimistic" versus
 "pessimistic" conditions discussed  in the  second  paragraph.  As a
 related example  of this possibility,  it is pointed out that the
 phosphorus control goals for Lake Erie  stated  in  Annex III  of the
 1978 Agreement are unclear.  In order to achieve  the stated Lake
 Erie control goals, a more stringent  target  load  will be needed.
 This confusion has been mentioned in  the past by  PLUARG and the
 IJC.  However, it has not yet been  clarified by the Governments.

      [GAO Comment:  As discussed above,  we are merely
      presenting  the information as  set forth by the  task
      force.  We  do not conclude that  either no additional
      work will  be needed or massive new programs will  be
      needed.  We merely stated  that the  task force  said
      actions could range between  these extremes.]

 Page 23, para 2,  line 1;      it is stated  that the Governments
 tentively  agreed  to  use  the proposed target loads in  establishing
 compliance  schedules for each country,  but that questions  have
 arisen  about  the  relative  merits of proceeding any further  at  this
 time because of  uncertainty  surrounding the target loads.   This is
 illogical  and contradictory.  It is also  stated that  the U.S.
 co-chairman of  the Phosphorus Management Task  Force described  any
 efforts to  allocate  the  target loads "as a waste of time."   It
 should  also be  pointed  out  that this comment does not reflect  the
 opinion of the  Task  Force  itself, which provided considerable  detail
 regarding  a timed,  sequential approach for achieving  the target
 loads.
                                  118

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APPENDIX XII                                           APPENDIX XII


      [GAO  Comment:  The  report (see p. 23)  has been
      revised  to delete the  U.S.  cochairman's statement.]


 Page 23, para  3, line^;	it  is stated that the Phosphorus
 Management Task Force  indicated the next major decision point for
 the lakes  will  be  in about five years.  This is incorrect.  The Task
 Force stated  was that  the  next major decision point in their
 suggested  approach should  be  in about five years.  Obviously, if
 their recommended  plan was not used, the five year "decision" period
 has no relevance.

      [GAO  Comment:  The  report (see p. 23)  has been
      revised  to clarify  the task force position.]

 Page 23, para  3, lines 15-18;  It is suggested  (in relation to Appendix
 V) that obtaining  definite information about any of the uncertainty
 issues could  drastically  effect the types and extent of programs
 needed to  control  phosphorus.  It  should also be pointed out,
 however,  that further  definite  information may not have much of an
 effect on  selecting phosphorus  control programs.  The Governments
 are already capable of providing a reasonable estimate of the types
 and extent of programs necessary to achieve the target loads.

      [GAO  Comment:  This comment is similar to the  first
      comment on p. 117.]


 Page 24, para 2, line  1;  It  is stated that since the  IJC lacks a
 single group  for coordinating research efforts in the  Great Lakes
 Basin, this responsibility is given to the EPA.  The reference to
 the IJC is a  misstatement.  The 1978 Agreement gives the IJC's
 Science Advisory Board the responsibility of advising  jurisdictions
 of relevant research needs and of  soliciting their involvement in
 promoting  research coordination.  This responsibility  is a
 coordinating  effort for research activities in the Basin within the
 structure  of  the IJC.

      [GAO  Comment:  We did not intend  to imply that
      IJC is  responsible  for coordinating research
      efforts and  have revised the report (see p. 24)  to
      clarify this matter.]


 Page 25, para  lf  lines 2-5;  It is stated that officials of the Great
 Lakes Basin Commission felt  that an overall plan for identifying
 research needs and coordinatint efforts is needed, but has not been
 developed.  There  have been  some efforts by EPA's Environmental
 Research Laboratory at Duluth, Minnesota to establish research
 priorities.  The effort,  however,  has consisted mainly of attempting
 to  identify and fund research activities related to the Great Lakes
 Basin Ecosystem,  rather than  developing an overall plan for the
 Basin.

      [GAO Comment: We believe that the report clearly
      reflects  that we are referring to an overall  research
      plan  for  the basin.]

                                 119

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APPENDIX  XII                                           APPENDIX  XII
 Page 25, para 4, line 10;   I± is stated  that  the EPA has not
 prioritized Great Lakes research projects.   It is worth noting that
 the IJC's Science Advisory Board will be  providing a report to the
 IJC on  the "state of research"  regarding  the Great Lakes Basin
 Ecosystem and the priorities which it feels  should be placed on
 research efforts in the Basin.

      [GAO Comment:  As noted,  the Science Advisory Board
     has not  yet provided  the  report.  In addition,  we have
     no  knowledge as  to whether EPA will  endorse  the priori-
     ties as  established by the board.]

 Page  26, para 2, line 1;  Reference is  made  to the Great Lakes
 Protection Act of 1981.  The Bill calls for  the establishment of a
 Great Lakes Research Office  to  identify research needs, set
 priorities, coordinate research activities,  etc.  It is noted that
 the IJC presently has a mechanism in place,  the Science Advisory
 Board,  which could attempt to perform at  least part of these
 functions.  The Board is,  in fact, the  only  group on the Great Lakes
 which would likely have knowledge of research efforts in both
 countries and such information  could be used to identify research
 needs and help set priorities in both countries.


      [GAO Comment:  We do  not  believe the use of  the
     Science  Advisory Board to perform these functions
     would be acceptable.   The board  is part of an inter-
     national organization which has  only advisory powers
     and therefore would not  be in a  position to  set
     priorities and direct research efforts.  Although
     the board could provide  valuable advice, we  believe
     a  U.S. Government organization needs to carry out
     this function.]


 Page 26, para  5, line  5;    it is stated  that nonpoint  pollutants
 enter lakes in  "a  diffused  and diluted  form".   The meaning  of  this
 statement is  unclear.  Nonpoint pollutants are  in a  "diffused
 form".   However, nonpoint pollutants would not  necessarily  be  in  a
 more  diluted  form  than if they were discharged  from  a given point
 source. It all  depends on  the specific pollutant  source  in each
 case.

      [GAO Comment:  The report (see  p.  26) has been
     revised  to eliminate  the  reference to diluted forms.]

 Page 27, para  2, line 1:   It is  stated  that  agricultural activities
 and urban stormwater  runoff  are  the major sources of nonpoint
 pollution in  the Basin. This is  true only if the unit area loads
 from these sources are being considered.  It may not be the case,
 however, when  the total load entering a lake is considered.   For
 example, the  major  nonpoint  source of phosphorus in the Lake
 Superior basin is forestry activities,  rather than agricultural or
 urban land use activities.   The  unit area loads for agricultural and
                                 120

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APPENDIX XII                                          APPENDIX XII


uroan areas in the Lake Superior basin are, in fact,  higher  than  for
forested areas.  There is  so  much more forested area  in the
watershed, however, that the  total load from forests  is greater than
the agricultural or urban  inputs.

     [GAO Comment:  The report  (see p.  27) has been
     revised to note that, with the exception of Lake
     Superior, agricultural and urban runoff are the
     major sources of nonpoint pollution when both
     unit area and total loads are considered.]


Page 27, para 2,  line  16;  It is stated that a 1981 IJC report
indicates air transport  is believed  to be a major  source of
phosphorus except for  the lower two  lakes.   The surface areas of the
lakes must be considered, however,  when examining  the significance
of atmospheric inputs.   It is true that the atmospheric inputs of
phosphorus in the lower  lakes are considerably less than in the
upper lakes.  That is  due, however,  to the  fact that the surface
areas of the lower lakes are smaller and,  therefore, there is less
opportunity for phosphorus to enter  the lakes from the  atmosphere.
The main point to be made is that the atmosphere is a major route
for phosphorus and a number of other substances to enter the Great
Lakes.


     [GAO  Comment:  The report (see p.  27) has  been
     revised  to show that air transport  is a major
     source for a number of other  substances entering
     the  lakes.]

Page 28, Table:  The  last row is entitled "Great Lakes  Average".
What is meant by the word "average"?

     [GAO  Comment:  The average has been deleted (see
     p. 28) because  it was not needed  to illustrate our
     position.]


Page 28,  para 2,  line  .L:  It is stated that although the severity of
the nonpoint problem is  not known,  nonpoint pollution contributions
are nevertheless  believed to be significant.   It is interesting that
the stated concerns about "uncertainty" do  not appear to apply in
regard  to nonpoint source pollution  as they did in regard to the
control of phosphorus.   In spite of  a stated lack  of knowledge, the
report  nevertheless calls for more  vigorous nonpoint pollution
control efforts.   This  is an inconsistency  which weakens the whole
argument regarding the need to clear up uncertainty before effective
pollution control measures can be implemented.

     [GAO Comment: We believe that our  message on this
     matter has  been  misinterpreted and  have revised the
     report (see p. 28) to  clarify  it.   While we  recognize
     that uncertainties exist over  phosphorus loadings
     to the lakes, much more is known about phosphorus
     nonpoint  sources than  other nonpoint sources,  such
     as toxic and hazardous  substances.   In addition, as
     stated later in  the  discussion of nonpoint sources,

                                121

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APPENDIX XII                                          APPENDIX  XII
     even when phosphorus from nonpoint sources has been
     identified as a problem, little  has been done to
     actually control it.  We do not  agree that the
     report  is calling for more vigorous nonpoint efforts
     where significant uncertainty  exists.  We do believe,
     however, that where data is available to pinpoint
     problem areas, control measures  should be developed
     and  instituted.  To the extent that this has not been
     done, as provided in the agreement, the United States
     is not  meeting the agreement objectives.]

 Page 29, para  2, line 6;   It  is stated that the Clean Water Act  has
 provisions for grants to  demonstrate  new  methods and techniques  for
 eliminating  nonpoint pollution  "in the Great Lakes".   Is  the Act
 this specific  as to location?   It should  be mentioned that the Soil
 Conservation  Service can  play a significant role in addressing
 nonpoint pollution in the Great Lakes Basin.  Their recognized
 expertise in  the area of  erosion control  and associated pollutant
 generation,  as well as their  long history of work with the states
 and the EPA,  suggest such a  role.


      [GAO Comment:  Section 108(a)  of the Clean Water
     Act  specifically refers  to the Great Lakes.
     Also,  the role of the Soil Conservation  Service
     is  spelled out in the  report.]

 Page 29, para 4, line 9;   It  is suggested the technical capability
 to identify cause and effect  relationships between nonpoint sources
 and water quality impacts  does not exists.  This is not the case.
 What doesn't exist is the  technical capability to accurately and
 precisely identify cause  and effect relationships between sources
 and impacts.   There are some mechanisms to identify such
 relationships, however, which do presently exist.  One such project
 is the OECD  international  eutrophication  study which  developed
 statistical  relationships  between nutrient loads and  water quality
 in lakes and  impoundments.

      [GAO Comment:   In  our  previous report we specifi-
      cally  stated  that  the  technical capability to
      identify  cause  and  effect  relationships  does not
      exist.   We continue to  stand by that  statement
      based  on  that  report  and other work  we  have  done.
      Also, we  have  no knowledge of the  OECD  report or
      the reliability  of  the statistical  relationships
      which  could  be used to prove  an actual  cause and
      effect  relationship.]


  Page 30, para 4, line 9;     The Great Lakes Basin Commission is
  called a "primary coordinating mechanism".  This description isn't
  really correct.  The Basin Commission was primarily  a planning
  agency,  not  a coordinating agency,  per se.  The same comment applies
  to page 28,  para 3,  line  5.
                                 122

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APPENDIX XII                                           APPENDIX XII
     [GAO  Comment:  We are  stating the position of SCS
     officials who were actively involved in nonpoint
     planning efforts with  the Basin Commission.  We
     believe the officials'  comment are correct based on
     our discussions with others, including representa-
     tives of the Commission.]

 Page 31, para 4,  line 4;    It is stated that little nonpoint control
 technology developed in the  Great  Lakes Basin can be transferred to
 other areas.  This is an incomplete  statement.  There is no reason
 to believe that the techniques  developed in the Basin cannot be
 applied elsewhere.  It just  appears  that nobody is making the effort
 to do so.

     [GAO  Comment:  The discussion (see p. 31)  has been
     revised based on comments from the Department of
     Agriculture concerning implementation of the tech-
     nology. ]


 Page 32, para 1, line 2:    it  is stated that nonpoint pollution
 sources "constitute  the majority of pollutants  entering  the  lakes".
 This  is incorrect  as  a general  statement.   Nonpoint sources  do  not
 constitute the majority of all pollutants entering the  lakes,
 especially in the  case of toxic substances.   Industrial  dischargers
 contribute considerably greater quantities  of many toxic pollutants
 than do nonpoint sources.   Thus, while nonpoint sources do
 contribute significant quantities of many pollutants to  the  Great
 Lakes,  they do not contribute the majority  of all  pollutants
 entering the lakes.

     [GAO  Comment:  The report (see p. 32) has  been
     revised as suggested.]

 Page 32, para 2f lines 13-15; it is again stated that little technology
 developed  in Great Lakes Basin  projects (as part of the Rural Clean
 Water Act) can be transferred to other areas.  As  noted above,  it  is
 not so much that such technology can't be transferred,  but rather
 that nobody seems to be making  the effort to do so.

     [GAO  Comment:   See first comment on this page.]


 Page 33, para 1, line  1;    It  is stated that EPA Region  V officials
 feel  minimum/no  tillage practices are not suitable for  all crops,
 soils  and  climates.   It should  also be mentioned that there  is  a
 potential  for greater use of  herbicides for the control  of weeds
 when  employing minimum/no tillage practices.

      [GAO  Comment:   The report (see p. 33) has  been
      revised as suggested.]
                                 123

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APPENDIX XII                                          APPENDIX XII
 Page 33, para 2, line 5;     it  is  stated that toxic pollutions can
 render  the lakes "useless."   Realistically, it is not  likely that
 the Governments would ever allow toxics pollution to render the
 lakes useless.  An admittedly ridiculous example is the  fact that,
 however bad conditions  might  become in the lakes, the  water could
 nevertheless always be  used to put out fires or float  ships for the
 transportation of goods.   It  is  the degree to which the  lakes are
 polluted so that it interferes with the beneficial use of the water
 resource that is the real  issue.

     [GAO Comment':   The report (See p. 33)  has been revised
     to show that  the  lakes  could be lost to a variety of
     desirable  activities.]


 Page 33, para 2, lines 1-10;    The observation  is made that toxic
 pollution is  a very  serious problem in the  Great Lakes.  At the same
 time,  it is also stated that Great Lakes toxic pollution has not
 been comprehensively addressed because "too little  is known" about
 the problem.   This  is a contradictory and illogical  statement.   It
 would seem that the  very seriousness of the problem, as implied in
 this paragraph,  suggests that toxic control programs be implemented
 as rapidly as  possible, even if the "nature,  extent  and source  of
 such pollution"  is  not precisely known.   If the problem is as
 serious as suggested  in this paragraph (and indeed  it may be),  this
 suggests massive efforts be undertaken to attempt  to control the
 problem.  Adjustments to such programs can  be  made  as more is
 learned about  the problem, not vice versa.


     [GAO Comment:  The  report discussion  (p.  33)
     states that toxic  pollution is "potentially" a
     greater threat than  eutrophication, but that the
     extent of  toxic pollution is not known and the
     problem is not being comprehensively addressed.
     We do not  find this  to  be contradictory or
     illogical  and we cannot agree that a massive
     program should be  undertaken to control toxics
     regardless of  the  state of knowledge about  toxics.
     To do so could, in our  opinion, result in massive
     resources being devoted to a potential  problem
     which may  not  exist  or  may not be as serious as
     perceived.  Such an  approach can rapidly lose  its
     credibility as additional information becomes
     available and  can result in a substantial  waste  of
     resources.  We believe  that attention  needs to be
     devoted to toxic substances, including  data gather-
     ing and research and, if justified by  reliable
     information, the implementation of specific
     control measures.  Unfortunately, little has been
     done in any of these areas.]
                                124

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APPENDIX  XII                                          APPENDIX XII
 Page 34, para 1, lines 6-10; it  is stated that if the EPA reduces
 allowable PCB  levels in  fish, commercial fishing would be "totally
 eliminated".   This  is  an  inaccurate statement.  There will likely
 always be places  in the  lakes where PCB levels in fish are not be
 exceeded.  Further, it is the FDA, not the EPA, which determines the
 allowable amounts of PCBs in fish.  It is also stated that toxic
 substances in  fish have  "already severely reduced" commercial
 fishing.  .There are fisherman who would disagree with this
 statement.  What has actually happened is that several preferred
 fish  species have basically disappeared from the lakes.   The overall
 tonnage  of fish caught in the lakes, however,  does not appear to
 have  decreased significantly in recent years.

      TGAO Comment:  The  report (see p. 34)  has been
     revised  as suggested.]

 Page 34,  para 4, lines 2-4;  it is stated that DDT,  mercury and PCBs
 "have  been carefully studied and regulated".  This is an
 overstatement.  They have probably been studied fairly well.  It is
 a matter  of opinion, however, as to whether or not these substances
 have  been "carefully regulated".

     [GAO Comment:  The  discussion (p. 34)  has been
     revised  to state that these substances have been
     studied  and control measures implemented.]

 Pay 35,  para 1, lines 5-7;  The use of fish tissue to determine "the
 lakes' status  relative to toxics" and the effectiveness of control
 programs  is mentioned here.  Some care must be used in such
 assessments.   In the case of substances which bioaccumulate, for
 example,  the use of fish  tissue may not generate much information
 about  the effectiveness of control programs.  It should also be
 pointed  out that fish and other organisms can be looked upon as
 "integrators"  of the effects of multiple inputs of toxics.  That is,
 a fish lives in an environment containing many pollutants.  The
 "state"  of the fish reflects the cumulative impacts of all these
 pollutants.

      [GAO Comment:  Analysis of fish tissue is an
     accepted  method of  measuring levels  of toxic
     substances and therefore the effectiveness of
     control measures for  specific toxics.   We do
     not  believe the comment affects the  matters
     discussed in the report.]

 Page 35,  para 2, lines 2-4; it is stated that the Chief of the GLNPO
 Surveillance and Research Staff said that the U.S. currently lacks
 the  resources  to adequately monitor for toxics.  Does this statement
 apply only to  EPA  resources or  to all the available U.S. resources
 in the Basin?  Other agencies do have personnel and equipment that
 could be  used  in toxics monitoring activities related to the
 Agreement if the U.S. chose to use them in such efforts.
                                 125

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APPENDIX  XII                                           APPENDIX XII
      [GAO  Comment:  The statement is from a key
     official  in a position  to  have knowledge  of  the
     availability of resources  from a variety  of
     agencies  and does refer  to overall U.S. resources.]

 Page 35 , para 2, lines 5-7;  it is stated that lack  of  equipment and
 personnel  would  probably be solved by "the forces of supply and
 demand".   The  meaning of this statement is unclear.

      [GAO  Comment:  We believe  that the statement is
     clear.   As the demand  for  information and labora-
     tory  capability to provide such information
     increases, the laboratory  capability and  other
     needed  resources will  become available.]

 Page 33 , para  2, line 8;  It is stated that actions  are now been
 taken  in the U.S. to improve toxics coordination  at  the state and
 federal level.   What actions are  being referred to and who is doing
 them?

      [GAO  Comment:  The report  (p. 36)  has been  revised
     to provide additional  information  as suggested.]


             2f  11in-~i;     Ifc is  stated that EPA has proposed
           *     1-~
    wnniHK  * ?  y ? ne °f  34  industries required to be regulated.
 made tnus far?   me t0  indicate why such slow Progress has been

      [GAO Comment:   We do  not believe it  is  necessary
      to go into the  detail suggested.  We have provided  a
      reference to  the  report for those interested in
      pursuing this matter  further.]

 Page 37 , para 3, line 7;    Reference is made to  the Great  Lakes
 International Surveillance  Plan  (GLISP) as  "the basic framework  for
 monitoring activities in the Great Lakes Basin  required by the 1978
 Agreement".  This  is  an incomplete statement.  GLISP is mentioned in
 the Agreement only as a model, not as the required monitoring
 program.  The Governments themselves must provide the required
 monitoring program.   The degree  to which GLISP  will play  a role  in
 the development  and implementation of the required monitoring
 program is not clear  at present, even though GLISP is being  touted
 by some as the program  called  for in the Agreement.


      [GAO Comment:  The discussion  (p. 37) has been
      revised  to clarify that GLISP  is  intended to be
      a model. ]

 Page 37 , para 3, lines 9  and 10;  it is stated that "the Commission  believes
 that the plan (GLISP)  is biased, incomplete and  lacks  scientific
 validity".  This is incorrect.  While advisors to the  IJC have
 presented  their personal technical critiques on  the scientific
                                 126

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APPENDIX XII                                          APPENDIX XII


 validity of GLISP, the IJC itself has  not yet come to any
 conclusions regarding GLISP.  As an information item, it should be
 pointed out in the GAO report that the opinions of individual IJC
 staff members do  not necessarily reflect the official opinion of the
 IJC on any given  issue,

      [GAO  Comment:   The report  (p. 37) has  been revised
     as  suggested.   Another reference to  this matter was
     revised  in the  draft report  before  it  was sent to IJC,
     but the  appropriate revision to this passage was
     inadvertently not made.]

 Page 38, para  5, line 4;     It is stated that in a January 1981
 interim report, the IJC reported "substantial concerns cloud  the
 governments abilities to meet the intent of the Agreement".   It
 would be informative to expand on this observation.

      [GAO  Comment:   The discussion (pp.  38  and 39) has
     been  revised to delineate  the specific concerns.]

 Page  39, para  2, line 4;    Reference is made to a cooperative  effort
 among nine state  and three federal agencies.  There are only  eight
 states in  the Basin.

      [GAO  Comment:   Ohio is  represented  by  two agencies,
      thus  the total of nine.]

 Page  39, para  4, lines 2, 5, and 7;Reference is made to the EPA's  open
  water and nearshore monitoring efforts and their associated
  inadequacies.  It would be  informative to indicate why the EPA has
  experienced  such difficulty with its  monitoring efforts related to
  the  Agreement.

      [GAO  Comment:  The previous sentence states
      reasons—funding constraints.]

Page  40, para 2;   The statement is made  that "the  IJC
believes  the EPA's Atmospheric Deposition Network  is  inadequate
This is not correct.  The IJC has made  no comment on the EPA
Atmospheric Deposition Network.

      [GAO  Comment:  The reference to EPA's Atomspheric
      Deposition Network has  been deleted from the  report.
      In its comments, EPA  agreed with our assessment that
      the network was plagued by problems such as  lack of
      equipment, poor collection location, and different
      collection techniques.   However, EPA also  pointed out
      that  substantial changes have been made to the  network
      since we made our assessment and that our  report dis-
      cussion was not a true  reflection of the current
      situation.  We applaud  EPA's efforts to upgrade its
      atmospheric deposition  monitoring system for  the lakes
      and have deleted our  assessment of the old system.]
                                 127

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APPENDIX  XII                                          APPENDIX XII
 Page 40,  para 2;  It  is  stated that because differences
 exist  in the way  the U.S.  and Canada collect samples, no
 international  comparison of data can be made.  This is not correct.
 Comparisons can be made, although such differences require careful
 interpretation of the data by those making the comparisons.

      [GAO Comment:  The discussion has  been eliminated
     because  it was part  of the discussion of the  air
     deposition network  (see previous comment).]


 Page 40, para 4, lines 3-10;    it  is stated that the rationale  for
 much  of which  is  included  in GLISP is unexplained.  An unexplained
 rationale, however, isn't  necessarily a bad rationale.  It is worth
 mentioning here that in spite of what may be shortcomings in  GLISP,
 when  the large extent of the area being monitored is considered,
 GLISP  probably represents  one of the best cooperative surveillance
 plans  in the world at the  present time.  GLISP is also the only
 cooperative monitoring  program in the Basin between the two
 countries.


      [GAO Comment:  The  statement  is  a  direct quote by
     an IJC official.   Also, for the  reasons discussed at
     length in the report, we do not  believe that  GLISP
      is a good plan or model.]

 Page  40, para 5, line 1;     It  is  stated that "knowing when and where
 to take water  samples  is important".  It should also be pointed out,
 however, that  no  one "knows"  unequivocally when and where to take
 samples in all situations.  There are always differences of opinion
 as to what constitutes  the best  locations and frequencies for
 sampling in a  monitoring program.


      [GAO Comment: We  agree, but,  as  discussed  subsequently,
     GLISP provides a  wide range of  latitude which could
      have substantial  effects  on the  monitoring  results.]


 Page 40, para 5, 1 ine 6;     it  is  stated that GLISP does not specify
 month, day, or hour for sampling.  Such "specifying" can lead to
 problems in some  cases. It may  result in an inflexible monitoring
 program in which  a waterbody  is  sampled in a more or less mechanical
 manner, regardless of whether or not the sitution calls for it.  An
 inflexible program, for example, might not allow for sampling during
 storm events  if  such events do not happen to occur in accordance
 with  the schedule incorporated  in the sampling program.  It is also
 stated that monitoring  activities may be scheduled on the basis of
 the availability  of vessels or other resources.  This  is obviously
 not an ideal  situation. Such occurrences, however, may represent an
 unfortunate economic reality  in  some cases, and this possibility
 should be considered in developing monitoring programs.  It is also
 noted that the last sentence  in  this paragraph could be reworded for
 clarity.
                                  128

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APPENDIX XII                                          APPENDIX XII


      [GAO Comment:   We agree that rigid specificity  can be
     detremental  and some latitude must be provided.   But
     as discussed above,  the GLISP provides a great  deal
     of latitude  which can have a substantial effect on
     consistency  and comparability.  Consistency  is  important
     for comparison  purposes.  Also, the remainder of the
     discussion does note that sampling needs to  take place
     at critical  times.]

 Page 41, para 2, line 7;    It  is stated that failing to sample above
 a "meeting point"  prevents one from assessing where specific
 pollutants originated.  This  is not necessarily the case.  The
 origins can sometimes be identified simply by looking at Upstream
 dischargers.  If a specific pollutant is detected in a stream and
 there is only one  or  a few possible dischargers upstream of the
 meeting point, such sources are likely to be the pollutant source.
 Some  common sense  obviously must be involved.

      [GAO Comment:   We do not agree.  As discussed in
     the nonpoint pollution section, all pollution does
     not come from dischargers.  Knowing the source  of
     pollution  is important in determining how to control
     the pollution.   Therefore, failure to sample above
     the meeting  point could lead to erroneous assumptions
     about the source of the pollution.]

 Page 41, para 2, line 12;     It is stated again made that  sampling in
 "improper locations"  can result in an inability to accurately
 quantify pollutant inputs  to  lakes.  One can most accurately
 quantify inputs of pollutants to lakes by sampling at tributary
 mouths, whereas the identification of specific sources of a
 pollutant may require sampling upstream from the tributary mouth.

      [GAO Comment:   This is the opinion of one of IJC's
     own environmental advisors.   The nature of specific
     pollutants can  change as the tributary flows along
     and the  actual  amount of a pollutant can be  masked
     by other pollutants if sampling is done only at the
     mouth.   We continue to believe that improper sampling
     locations can result in inaccuracies in both quantity
     and source.]

Page 41, para 3,  line 3;   It is stated that sampling  sites may be
located too far from cities and industries to identify loadings  to
the lakes.  Again, this is not necessarily the case.   Sampling at
the tributary mouth  might be sufficient to quantify  pollutant
inputs.  It is just  a question of the desired accuracy.   The easiest
way to attempt to quantify inputs to the  lakes from  municipal and
industrial sources is to  directly sample the discharges  themselves,
rather than attempting to sample  the contents of the  tributaries.

      [GAO Comment:   We believe that the statement is
     correct.  Many  things can happen to a specific


                                129

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APPENDIX XII                                        APPENDIX XII


     pollutant as it moves to the lakes in tributaries.
     The pollutant may settle out, change composition,
     or combine with other pollutants.  Therefore, it is
     important to know the source of the pollutant and
     only sampling discharges may not identify such
     sources . ]

Page 41 , para 3, line 10;  Two cities on the Maumee and Sandusky
rivers are used as examples of problems related to sampling
i^,,, 4- ,-«„,,   Tne pOint beina ma^o in this sentence is unclear.
     [GAO Comment:  The discussion (p. 41) has been
     changed to clearly state that the cities are
     located at the river mouth, much below the tribu-
          sampling location.]
Page 41, para 4, line 1;  It is stated that samples have to oe taKen
in exactly the same manner to allow for data comparisons.  This is
not necessarily the case, although the data comparisons would
obviously be more difficult under such circumstances.  It is also
suggested that if data are not exactly comparable, an overall basin
perspective can not be gained.  Again, however, this is a question
of the specific information being sought.

     [GAO Comment: The discussion (p. 41) has been
     revised to state that data comparisons are facil-
     itated by similar sampling methods.]

Page 41 , jaara 5, line 6;  It is stated that the specific times for
monitoring nearshore conditions were not defined in GLISP.  While
such omissions obviously make it difficult to critically assess
GLISP, it is remarked again that not defining the monitoring times
does not mean that bad data will necessarily be obtained.  Also,
item 2 says that "species sampled and number of samples made
differ".  The word should be "may".

     [GAO Comment:  The point being made is not that
     the data is bad, but that data will be difficult
     to compare if the methods, timing, etc., are
     not similar.  The typographical error has been
     corrected. ]

Page 42. para 4. ling 11; It is stated that the detergent phosphate
limitations have been met with controversy.  It should also be
pointed out,  however, that with the exception of two states in the
Basin, the limitations have been in effect in both countries for a
number of years.  The "controversy" over this issue comes primarily
from the soap and detergent industry and the two concerned states,
not the Basin population, per se.

     [GAO Comment:  The point remains that the ban is
     controversial at least in Ohio and Pennsylvania.
     The ban may, in fact, also be controversial else-
     where because of the higher Canadian limitations.]

                               130

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 APPENDIX XII                                        APPENDIX XII


Page 42, para 4f  lines 12 and 13;   It  is stated that the need  for  qreater
phosphorus  controls "is clouded  by uncertainties"  about  phosphorus
 inputs and  other  factors.   The point  is  made  again,  however,  that
the existence  of  uncertainties does not  mean  that  basic  errors have
been made  in the  identification  of overall phosphorus  control
programs  needed  in the Basin.  It would  be better  to call them
 "possible"  uncertainties when  discussed  in relation  to Great  Lakes
phosphorus  control programs.

       [GAO Comment:  The report  (see p.  42) has been
       revised as suggested.]

 Page 43, para 2, lines 3 and 4; It  is  stated  that  "an overall  Great Lakes
 surveillance and  monitoring plan  is needed".  It  is worth noting
 that  this is precisely  what the Agreement says.   It is pointed out
 again that  it is  the  responsibility of  the Governments,  not  the IJC
 or  the Water Quality Board, to develop  this  plan.

       [GAO Comment:  The report clearly  recognizes these
      matters.3

Page 43, para 3, line_l;  It is stated that the current (1978)
Agreement expires  in 1983.   This is incorrect.  According to Article
14 of  the Agreement, it  remains in force for  a period of  five  years
and  thereafter, until terminated by one  of the Parties,.  Therefore,
if neither Party objected to the Agreement,  it presumably would
remain  in effect indefinitely.   It is also pointed out  that Article
10 of  the Agreement requires the  Parties to conduct a comprehensive
review of the operation and effectiveness of  the Agreement following
the third biennial  report of the  Commission.   The third biennial
report of the Commission will be  presented to  Governments in 1986.
Therefore, the Governments  may  not be assessing the Agreement  until
then.

       [GAO Comment:  The discussion of the agreement in
      chapter 1 (see p. 4)  has been expanded to clarify
      this matter, and the report has been revised
      appropriately.]

Page 43, para  3,  lines  5-11;  ,It  is recommended that Congress, in
conjunction  with  the Secretary of  State  and the EPA Administrator
review the Agreement when  it "expires".  Other organizations  should
also be included  in this review.   One of the  biggest problems with
achieving the  requirements  of  the  Agreement is a lack  of
coordination between the various  involved agencies.  It seems
sensible, therefore, to  include other groups  in the review.   Logical
groups to be consulted  include the Soil  Conservation Service, the
Fish and Wildlife  Service,   the Corps of  Engineers and  NOAA.   They
all  carry out  some  functions related to  the Agreement.

      [GAO Comment:  The reference to the agreement's
      expiring has been revised as discussed above.  We
      have specifically identified the need for EPA and
      the Department of State to be involved in such a

                                131

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APPENDIX XII                                        APPENDIX  XII


     review because of their key roles  in Great Lakes
     activities.  Other agencies would  not be precluded
     from being  involved  in the suggested review.]

Page 53, para 4,  line 1;   It is stated that "virtually every major
program office" in EPA is responsible for activities covered under
the Agreement.  It is unclear what is meant here by a "major program
office", as only Regions  II, III and V are subsequently discussed.

     [GAO Comment:  EPA's various programs are defined
     in chapter  1.   (See  p. 4.)]

Page 54, para  I, line 2:  it is stated  that the GLNPO has not met a
critical need  for overseeing and coordinating Great Lakes
activities.  However, this  is not entirely the fault of the GLNPO.
It has  been operating in  recent years without much visible
cooperation from EPA national headquarters or the Great Lakes'
states.  There appears to be a lack of  commitment by EPA, especially
on the  national headquarters level, to  fulfill its role as the lead
implementing agency for the Agreement in the U.S.

      [GAO Comment:  The discussion  in the  chapter  clearly
     points  out  the problems GLNPO  has  experienced.]


Page 54, para 2, lines 2 and 4; it is stated that the EPA has placed Great
 Lakes program responsibilities at a relatively low level.  It should
 be pointed out that this action (or inaction)  appears to rest
 primarily in the Washington headquarters office and not necessarily
 in the Regional Offices.   Great Lakes program responsibilities under
 the Agreement appear to  have a relatively high profile within Region
 V •

      [GAO  Comment:   Chapter 3  of  the report  specifically
     discusses this  matter.]


Page 54,  para 3, line 7;   Item 2  in this paragraph states that not
enough research  staff were  assigned to  the Great Lakes initiative
program.   It should  be pointed out  that neither Region V or the
GLNPO  consider.research  to  be  a primary activity within their sphere
of^activities.  Other EPA facilities within  the Basin are more
logical research components than  Region V.

      [GAO Comment:   The  discussion (p.  54)  refers  to
     matters which  predate  the establishment of GLNPO
      and  the management  of  the Great Lakes program out
      of region V.   Therefore the  comment is not germaine.]
                                132

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 APPENDIX XII                                         APPENDIX XII


Page 55, para  4,  line  8;  It is stated that the Great Lakes Program
11 is generally  not separately funded under federal law".  This  is a
major continuing problem in regard to the U.S. meeting its
responsibilities under the Agreement.  The Agreement  identifies the
Great Lakes as a special resource of both countries, deserving of
special attention and  funding.  Therefore, Agreement
responsibilities should not be viewed as activities to be done, if
possible, after normal domestic concerns are addressed.  Unless
Great Lakes funding regarding Agreement responsibilities is
identified separately  by the U.S. Government, it is unlikely the
difficulties experienced thus far in meeting Agreement requirements
will improve.

      [GAO Comment:  This matter is fully discussed in
      the report.  In  addition, our recommendation  to the
      Congre'ss emphasizes that it must decide if sufficient
      funds can be provided for Great Lakes activities
      given current budgetary and economic conditions.]

Page 56, para  5, line  3;  Reference  is made  to a 1980  request by
GLNPO concerning development of  nonpoint  source  regional
strategies.   It is noted that the nonpoint recommendations  contained
in this paragraph are basically  the  same  as  those  PLUARG  made
several years earlier.

      [GAO Comment:  We agree, but see no need to expand
      the discussion further. ~]

Page 57, para 2, lines 7 and 8; Lake Erie  is described as "the most
 polluted of  the  Great  Lakes", while  Lake  Ontario  is described as the
 second  most  polluted.   This is actually an oversimplification of the
 condition of these  two lakes.  Lake  Erie  is  the most  polluted of the
 Great  Lakes  with regard to  nutrients.  In regard to toxic
 substances,  however, Lake  Erie  is in  better  condition than Lake
 Ontario..

      [GAO Comment:  The discussion (p. 57)  has been
      revised  to state that both lakes are the two  most
      polluted of all the Great Lakes.

Page 57. para  4, line  3:  It is stated that  New York officials have
not directed attention toward Great Lakes issues because  of a lack
of EPA guidance.  As pointed out earlier,  however,   it must also be
recognized that there  is no mandate requiring Great Lakes Basin
states to participate  in Great Lakes cleanup efforts.   The mandate
exists on the  federal  level.

      [GAO Comment:  This matter is fully set forth in
      the report.  (See p. 4.)]
                                133

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APPENDIX XII                                        APPENDIX XII


Page 57, para 5, line 5;  It is stated that GLNPO has experienced
difficulties in dealing with the Departments of Agriculture and
Commerce.  This is surprising if this remark applies to the Soil
Conservation Service.  The Soil Conservation Service, via its
Conservation Districts, has a long history of working with local and
state governments and with EPA.  It is surprising, therefore, if
GLNPO has experienced difficulties in dealing with them.

      [GAO Comment:   At the local level coordination
     may be good, but high-level coordination has been
     missing in the  development of a  comprehensive non-
     point strategy.  Also,  the Department  of Agriculture
     agreed (see app. XI) that there  are  no formal arrange-
     ments for EPA or GLNPO  to communicate  with  the
     Department.]

 Page 58,  para  3,  line  4;   it is  stated  that EPA  travel  cutbacks have
 occasionally limited employee  attendance  at IJC  functions.   This is
 correct  and, unfortunately,  there  is  every  indication that the
 problem  is getting worse.  Several  states are also  restricting  their
 employee  attendance  at  IJC functions.  It is also noted in this
 paragraph that  the FY  82  budget cutbacks  could  result  in closing
 EPA's Large Lakes Research Station.   This did not occur only because
 of  specific congressional  intervention.   This station,  however, has
 been "zeroed out" in the  FY  83 budget.  As  a result, a  major Great
 Lakes research activity related to the Agreement will be lost,
 making the work of the Commission  related to the Agreement more
 difficult to accomplish.

      [GAO Comment:   Travel problems  are discussed  in
      the  report.  The  suggested discussion  of the con-
      gressional  action  needed  to  keep the research  station
      operating  also  has been included in  the report.  (See
      p.  58.)]

 Page 59, para 1,  lines 3 and 4; It is  stated that the EPA "has assigned
 Great Lakes  Program responsibilities at a low  level".   This  should
 be emphasized  as a  very significant problem.  This  "relatively low
 priority" has  caused many of the  problems related to fulfilling the
 requirements  of the Agreement.  The situation  may not get  any  better
 unless EPA assigns  a higher  priority to its Agreement
 responsibilities.   Obviously,  there is no incentive for the  involved
 Regional Offices or associated laboratories to  attach any  particular
 significance  to Agreement activities if a similar commitment is not
 evident at the EPA headquarters  level.

      [GAO Comment:   This  matter  is emphasized.   The IJC
      position  on this  matter has  been added to  the  discus-
      sion (p.  55).]

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APPENDIX XII                                        APPENDIX XII


Pages  61-65;  Appendix 1 lists the environmental legislation and
agencies affecting the Great Lakes.  It should also be stated,
however, that the U.S. has commitments under the Agreement which are
extraordinary in nature, relative to U.S.  domestic laws.  That is,
the U.S. has commitments under the Agreement which it has pledged it
will attempt to accomplish.  To do so may require that the U.S.
initiate some activities which are basically outside the structure
or requirements of U.S. domestic laws regarding the environment.
Therefore,  simply assessing the existing U.S.  legislative base may
not give an accurate picture of what the U.S.  actually can or cannot
do in regard to its Agreement commitments.

     [GAO Comment:  We are not aware of any instances
     where the United States has carried  out activities
     outside of domestic law.  Furthermore, we believe
     that the report  clearly states  that  the United States
     has made commitments  under the  agreement which
     are not being met and the Congress will need  to
     decide the extent to  which these agreement  commit-
     ments can be funded.]

Page 76, para 1;  This paragraph has a list containing three
"important uncertainties"  remaining to be resolved concerning
phosphorus control."  The  implication is that unless these
uncertainties can be  resolved, it will not be possible to implement
appropriate phosphorus control measures.  The uncertainties,
however, may not be as formidable as one might otherwise believe.
For example, in regard to  the second uncertainty concerning
tributary loads, a tributary is a transport mechanism for water and
the chemicals carried in it.  Tributaries, per se, do not contribute
to the phosphorus load to a waterbody.  It is principally the
activities of man within the watershed which result in excessive
phosphorus inputs to waterbodies.  In regard to  shoreline erosion
contributions of phosphorus, it is unclear whether or not this even
warrants a label as a major uncertainty.  It is  true that there are
large inputs of phosphorus from shoreline erosion at certain times
of the year.  Most current scientific evidence,  however, suggests
this phosphorus is largely unavailable for algae growth.  Therefore,
it is of little consequence in regard to  eutrophication control
measures .  One item  that  should be added to this listing, however,
is the atmospheric inputs of phosphorus to the lakes.  More accurate
information on the quantities and types of phosphorus entering the
Great Lakes via atmospheric deposition is needed.

     [GAO Comment:  A discussion on  atmospheric  imputs  of
     phosphorus has been added to  the report.   (See pp.  78
     and 79.)  With respect to the other  uncertainties,
     we merely state  what  IJC's own  task  force  identified
     as uncertainties which need to be resolved.]
                               135

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APPENDIX  XII                                         APPENDIX XII


Page 16, para 2, lines 2 and 3; it is stated that bioavailability  is one
of "the mo,st critical considerations" in assesssing the desirability
and effectiveness of phosphorus control programs.  In fact,  the
quantities of biologically available phosphorus can be used  now  to
set control priorities.  Control efforts should concentrate  on those
sources contributing the greatest quantities of biologically
available phosphorus.  Also, it is more correct to indicate  that
bioavailability refers to phosphorus that is immediately available
for algae growth or that can become available for algae growth over
a short time period.

      [GAO Comment:  The definition of bioavailability
      has  been clarified {see p. 76).  While we  agree
      that controls  can be established where  information
      is definitive, we believe  that  further  research
      is needed  to resolve the uncertainties  which do
      exist  so that  optimal  control efforts can  be
      devised.]

Page  77, para 2, lines 11-19;  It is stated that phosphorus could
settle in river bottoms and may never be released back to the water
column.  On the other hand, it is also subsequently stated that
tributary contributions of phosphorus may be underestimated  because
storm events are not considered.  These are contradictory statements
whose implications  require further discussion.

      [GAO Comment:  We do not agree  that  the  statements  are
      contradictory.  Phosphorus can  settle and  never be
      released or  it can be  released  during storm  events.
      The  point  is that no one knows,  and  this needs  to  be
      determined.]

Page  78, para 2, line 8;  It is stated that anywhere from one to 40
percent of  shoreline phosphorus is in a biologically available
form.  The  upper end of this range, however, is not normally
encountered in  the  environment.  A more realistic range is on the
order of one to ten percent, with even the ten percent value being
relatively  high.  Therefore, to conclude that exclusion of shoreline
erosion phosphorus  raises serious questions about the integrity  of
the target  loads is misleading.  Because of its low bioavailability,
shoreline erosion phosphorus likely has little impact on the
eutrophication  status of a lake.


      [GAO Comment:  We believe  that  the discussion
     clearly points out that this is a range.  Also,
      IJC's  own  task force has stated that this  is
      a question which needs to  be resolved.]
                               136

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  APPENDIX XII                                          APPENDIX  XII


Pages  i-v,  DIGEST;   Where appropriate, the Digest  should  be changed
to  reflect  the  concerns raised above.  For example,  page  ii states
that the  IJC  believes that GLISP is "biased, incomplete,  and lacks
scientific  validity"; page 126 of  this critique ("Page 32, para 3,
lines  and 10")  contains a comment  addressing this statement.


       [GAO Comment:  The digest has been revised where
       appropriate.]
                                                 U.S. GOVERHENT PRINTING OFFICE 1982-0- 3&l-843/'H3
(089153)

                                 137

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