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    Report of Audit
              WATER
    EPA's Great Lakes Program
         Audit Report No. 99P00212
            September 1,1999

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Inspector General Division
 Conducting the Audit:     Northern Audit Division
                         Chicago, Illinois
Regions Covered:
Region 2, 3 and 5
Office Involved:
Cover Photograph
Office of Research and Development

Region 2
 Division of Environmental Planning
 and Protection

Region 3
 Water Protection Division

Region 5
 Great Lakes National Program Office
 Water Division
 Regional Lake Teams

Indiana Dunes National Lakeshore
 National Park Service

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                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           OFFICE OF THE INSPECTOR GENERAL
                                 NORTHERN DIVISION
                             77 WEST JACKSON BOULEVARD
                                 CHICAGO, IL 60604-3590

                                   September 1, 1999
MEMORANDUM

SUBJECT:   OIG Report No.  99P00212
             Improving EPA's Great Lakes Program
FROM:      Anthony C. Carrollo
             Divisional Inspector General for Audits
             Northern Division

TO:          Francis X. Lyons
             Regional Administrator, Region 5
             Great Lakes National Program Manager

       Attached is the final report on our evaluation of EPA's Great Lakes Program.  The
evaluation was done at the request of Region 5 management to provide advice and assistance to
(1) improve processes for developing lakewide management plans (LaMPs) and remedial action
plans (RAPs), and (2) negotiate and implement a U.S. strategy for the Great Lakes. The report
contains recommendations and actions the Agency has taken or plans to take to address both of
these areas.

       Since the report includes issues in the Great Lakes and Region 5, it is addressed to you as
both the Regional Administrator and Great Lakes National Program Manager. However,
throughout the report, we only use the title of Regional Administrator.

       We appreciate your staffs' efforts in working with us during this evaluation and the
prompt action that you are taking to  correct the problems.

       This audit report contains findings that describe problems the Office of Inspector General
(OIG) has identified and corrective actions the OIG recommends. This audit report represents the
opinion of the OIG and the findings contained in this audit report do not necessarily represent the
final EPA position.  Final determinations on matters in this audit report will be made by EPA
managers in accordance with established EPA audit resolution procedures.

ACTION REQUIRED

       In responding to the draft report, your office provided corrective actions, with milestone
dates, for each recommendation.  Therefore, no further response is required, and we are closing

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this report in our tracking system.  Please track all corrective actions in the Management Audit
Tracking System.

       We have no objections to the further release of this report to the public.

       If you or your staff have any questions regarding the report, please contact Audit Manager
Kimberly O'Lone at 312-886-3186.

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                                                    Improving EPA's Great Lakes Program
                          EXECUTIVE SUMMARY
INTRODUCTION
AND OBJECTIVES
In March 1998, Region 5 senior management requested advice and
assistance on how to (1) improve processes for developing
lakewide management plans (LaMPs) and remedial action plans
(RAPs), and (2) negotiate and implement a U.S. strategy for the
Great Lakes. The Office of Inspector General's (OIG) plan for
auditing Environmental Protection Agency (EPA) water programs
also called for a evaluation of the Great Lakes program.  To meet
both of these needs, the OIG performed a evaluation with the
objective of determining what the Regional Administrator, Region
51 can do to:
BACKGROUND
                           •      improve the LaMP and RAP processes, and

                           •      develop and implement effective national strategies and
                                 agreements.
                           The Great Lakes Water Quality Agreement (Agreement) between
                           the U.S. and Canada, was originally signed in 1972, and amended in
                           1978 and 1987.  The stated purpose in the agreement is to restore
                           and maintain the chemical, physical, and biological integrity of the
                           Great Lakes basin ecosystem. The 1987 amendments established
                           LaMPs and RAPs as systematic and comprehensive ecosystem
                           approaches to address the Great Lakes as a whole and specific
                           areas of concern throughout the lakes, respectively. The LaMP and
                           RAP documents also provide an historical record of the assessment
                           of critical pollutants, proposed remedial actions and their method of
                           implementation, changes in environmental conditions  as a result of
                           remedial actions, and significant milestones in restoring beneficial
                           uses of the lakes.

                           In April 1992, the Great Lakes National Program Office (GLNPO)
                           issued a joint Federal/State 5-year strategy (strategy)  for protecting
       1 The Region 5 Regional Administrator also serves as the National Program Manager for the Great Lakes
National Program Office. For reporting purposes, we are only using the Regional Administrator title.
                                                                        Report 99P00212

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                                                    Improving EPA's Great Lakes Program
                           the Great Lakes.  The strategy represented a commitment by
                           Federal agencies, states and tribes to achieving specific
                           environmental goals through a full range of coordinated activities.
AREAS FOR
IMPROVEMENT AND
RECOMMENDATIONS
EPA needs to improve two key processes for protecting and
restoring the Great Lakes: LaMPs and RAPs. LaMPs and RAPs
are taking longer than expected to complete.  For example, while a
draft LaMP for Lake Michigan was first published in 1992, the
LaMP was never finalized, thereby not meeting the statutory
deadline of January 1, 1994. Officials currently plan to  issue a
LaMP document for Lake Michigan by April 21, 2000.  To date, no
U.S. RAPs have had all of their beneficial use impairments
corrected.

To improve the LaMP process, EPA needs to (1) place  a priority
on issuing written plans for Lakes Michigan, Erie and Huron during
FY 2000; and (2) propose to Great Lakes partners and the
International Joint Commission (UC) revising the LaMP process to
address issues that have hindered completing the plans.  To improve
the RAP process, Region 5 needs to establish a coordinator to
better organize the RAP liaisons. Finally, Region 5's work on
LaMPs and RAPs would benefit from clarifying the organizational
roles and responsibilities of the offices, divisions and teams. These
actions are needed to reach the goal of restoring and maintaining
the chemical, physical, and biological integrity of the Great Lakes.

GLNPO does not have official agreements with other EPA offices
that work in the Great Lakes.  These offices include Regions 2, 3,
5, and the  Office of Research and Development (ORD). As a
result, relationships between Region 5 offices working in the Great
Lakes have suffered, and GLNPO and ORD did little coordination
on research planning.  GLNPO should enter into agreements with
all of these entities to identify the roles and responsibilities  of each
in the Great Lakes.

GLNPO officials can learn from problems they encountered
creating and implementing the 1992 strategy. In developing the
next strategy, GLNPO should strive to (1) obtain buy-in and
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                                                     Improving EPA's Great Lakes Program
                           commitment from all parties, (2) focus on goals, (3) include
                           performance measures, and (4) provide accountability for
                           implementation which will result in a meaningful strategy that helps
                           bring together Great Lakes efforts and activities. From this,
                           GLNPO can design a new strategy that will fulfill a new purpose
                           for the Great Lakes and help carry efforts forward to the
                           millennium.

                           Details on each of these findings and recommendations are
                           contained in Chapters 2 through 4.
AGENCY COMMENTS
AND ACTIONS           In response to the draft report, the Regional Administrator, Region
                           5, agreed with the recommendations or proposed alternative actions
                           to address the findings. Action plans, with milestone dates, were
                           also provided.  A summary of the response and action plans is
                           included throughout the report, and a complete copy of the
                           response is included in appendix 1.  The response includes details
                           on the resources and other support needed to implement the
                           report's recommendations.

                           The Regional Administrator outlined plans to accelerate the LaMP
                           and RAP processes. At the April 1999 Region 5 and State
                           Environmental Directors meeting, the states issued a challenge to
                           complete LaMPs for Lakes Michigan, Erie, and Superior by April
                           21, 2000 (Earth Day).  LaMP groups have prepared detailed plans
                           for meeting the challenge. For Lake Huron, a report describing the
                           environmental problems and actions that need to be taken will also
                           be issued by April 2000. To accelerate the RAP process, Region 5
                           will work with the states on roles, schedules, and grant funds to be
                           devoted to RAPs. The liaison function will be reorganized to
                           devote resources towards those RAPs most in need of EPA
                           assistance.

                           The Regional Administrator also plans to issue a new Great Lakes
                           Strategy by April 2000. In developing the strategy, the Regional
                           Administrator has agreed to consider how best to implement the
                           recommendations in the report. The issue of roles and
                                           in
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                                                    Improving EPA's Great Lakes Program
                           responsibilities of EPA offices working in the Great Lakes will be
                           addressed when developing the Great Lakes strategy.
OIG EVALUATION
                           The Agency's actions, when completed, will address the findings
                           and recommendations in the report.
                                           IV
                                                                        Report 99P00212

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                                             Improving EPA's Great Lakes Program
                            Table of Contents

EXECUTIVE SUMMARY                                                    i

ABBREVIATIONS                                                         vii

CHAPTERS
1     INTRODUCTION	1
           Purpose 	1
           Background	1
                 LaMPs 	2
                 RAPs 	3
           Scope and Methodology	5

2     KEY GREAT LAKES ACTIVITIES NEED STRENGTHENING  	6
           Improving the LaMP Process	6
           Improving EPA Involvement in RAPs	12
           Clarifying Organizational Roles and Responsibilities	15
           Conclusion	19

3     RESPONSIBILITIES OF EPA OFFICES  IN THE GREAT LAKES NEED
      DEFINITION 	20
           Conclusion	21
           Agency Comments and Actions  	21

4     GREAT LAKES STRATEGY NEEDS IMPROVEMENT  	22
           Buy-in and Commitment Needed 	23
           Focus on Goals	25
           Include Performance Measures	26
           Ensure Implementation	26
           Conclusion	27
           Agency Actions 	27
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                                                 Improving EPA's Great Lakes Program
EXHIBITS

1     Background	29
2     Status of LaMPs  	32
            Lake Erie	32
            Lake Huron  	33
            Lake Michigan	34
            Lake Ontario  	34
            Lake Superior	35

3     Status of RAPs 	36

4     Scope, Methodology, and Prior Audit Coverage  	38
            Scope and Methodology	38
            Prior Audit Coverage	39

APPENDICES

1     Region 5 Regional Administrator's Response
       to the Draft report	40

2     Distribution 	55
                                        VI
                                                                   Report 99P00212

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                                                  Improving EPA's Great Lakes Program
                                ABBREVIATIONS
Act




Agreement




EPA




GLNPO




IJC
Clean Water Act
Great Lakes Water Quality Agreement




U.S. Environmental Protection Agency




Great Lakes National Program Office




International Joint Commission
Lake Teams   Region 5 teams for Lake Michigan, Lake Superior, and Lake Erie




LaMPs       Lakewide Management Plans




OIG         Office of Inspector General




ORD         Office of Research and Development




RAPs        Remedial Action Plans




Strategy      1992 Joint Federal/State 5-year Strategy
                                        vn
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                                                    Improving EPA's Great Lakes Program
                                   CHAPTER 1
                                   Introduction
PURPOSE
BACKGROUND
                           In March 1998, Region 5 senior management requested advice and
                           assistance on how to (1) improve processes for developing
                           lakewide management plans (LaMPs) and remedial action plans
                           (RAPs), and (2) negotiate and implement a U.S. strategy for the
                           Great Lakes. The Office of Inspector General's (OIG) plan for
                           auditing EPA water programs also called for a evaluation of the
                           Great Lakes program.

                           We have met with the Deputy Regional Administrator, the Region
                           5 Senior Leadership Team, the Water Division Director, the Great
                           Lakes National Program Office Director, and the Region 5 Lake
                           Team Managers, to evaluate our preliminary recommendations for
                           improvement. Since there was an acknowledgment of the issues
                           and that corrective action was needed, the report focuses on
                           recommended improvements.
                           The Great Lakes - Superior, Michigan, Huron, Erie, and Ontario -
                           are an important part of the physical and cultural heritage of North
                           America. Spanning more than 750 miles from west to east, they
                           provide water for consumption, transportation, power, recreation,
                           and a host of other uses. Environmental challenges within the
                           Great Lakes include: contaminated sediments, the effects of exotic
                           species, and loss of habitat. Impacts on people include fish
                           advisories and beach closings. The  Great Lakes basin is home to
                           more than one-tenth of the U.S. population, and has some  of the
                           world's largest concentrations of industrial capacity.

                           The Great Lakes region has a long tradition of interjurisdictional
                           cooperation on key regional issues.  Four of the Great Lakes are
                           directly shared with Canada.  The Great Lakes basin includes all
                           land area that is drained by, or drains into, the Great Lakes. This
                           includes all or part of eight states: Michigan, Minnesota, Wisconsin,
                           Illinois, Indiana, Ohio, Pennsylvania, and New York; and two
                           Canadian provinces.
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                                                    Improving EPA's Great Lakes Program
                           The 1987 amendments to the Clean Water Act (Act) established
                           EPA as the lead Agency for working with Federal, state, and local
                           agencies to meet the goals of the Great Lakes Water Quality
                           Agreement (Agreement). Within EPA there are several
                           organizations with an interest in the Great Lakes. Regions 2, 3, and
                           5 all have at least one state bordering a Great Lake.  ORE) conducts
                           some research related to the Great Lakes.  GLNPO coordinates
                           EPA's efforts in the Great Lakes as the national program office.

                           For fiscal year 1999, GLNPO had a staff of about 46 and a budget
                           of almost $15 million. GLNPO sought proposals for $3.8 million in
                           grants in the areas of ecosystem indicators, contaminated
                           sediments, habitat restoration and protection, pollution prevention,
                           and LaMPs and RAPs. However, it is important to note that
                           GLNPO's Great Lakes spending is only a small portion of the
                           money EPA spends to restore and protect the Great Lakes basin.
                           For example, the entire state of Michigan is part of the Great Lakes
                           basin, and therefore most Federal and state activities in Michigan
                           that affect the water, air and land have an impact on the Great
                           Lakes.  (See exhibit 1 for additional background information.)

LaMPs
                           LaMPs are plans for each of the Great Lakes as a whole.  The
                           Agreement required that the U.S. and Canadian Governments, in
                           consultation with appropriate state and provincial governmental
                           organizations, implement LaMPs for each of the Great Lakes,
                           except for Lake Michigan which is the responsibility of the U.S.
                           Government. The Clean Water Act (Act) further required EPA to
                           issue a LaMP for Lake Michigan for public comment by January 1,
                           1992, submit it to the International Joint Commission (IJC) by
                           January 1, 1993, and publish it  in the Federal Register by January 1,
                           1994. The Act stated that there was nothing to preclude EPA from
                           developing LaMPs for any of the other Great Lakes. It did not
                           include a specific due date for any of the other LaMPs because they
                           required coordination with Canada, and therefore were not totally
                           within EPA's control. (See exhibit 2 for information on the status
                           of each of the LaMPs.)
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                                                    Improving EPA's Great Lakes Program
                           The Agreement set out a four-stage process for submitting LaMPs
                           to the IJC for review and comment (see table 1).

                                                      Table 1
                                             LaMP Document Process
RAPs
Stage
1
2
O
4
Timing of document submission
When definition and description of the environmental
problem and the causes for the use impairments
(referred to as the problem definition statement) has
been completed
When a schedule of load reductions is determined
When remedial measures are selected
When monitoring indicates that critical pollutants are
no longer impairing beneficial uses
                           RAPs are plans for specific areas of concern along the Great Lakes
                           (see figure 1). The Agreement defines an area of concern as a
                           geographic area where there is an impairment  of a beneficial use or
                           the ability of an area to support aquatic life. For example, an area
                           where there are fish advisories, beach closings, or contaminated fish
                           tissue. The Agreement states that the Federal government is to
                           cooperate with state governments in ensuring  RAPs are developed.
                           Under the Critical Programs Act, the role of EPA is to ensure that
                           states timely submit RAPs. Also in the Critical Programs Act,
                           states were required to submit RAPs to GLNPO by June 30, 1991,
                           to the IJC by January 1, 1992, and incorporate the RAPs into their
                           water quality plan by January 1,  1993.

                           There are 43 areas of concern in the Great Lakes.  The U.S.
                           contains 31  areas of concern, five of which it shares with Canada.
                           The remaining 12 areas of concern are in Canada.  To date,  one
                           area of concern in Canada has been delisted, meaning that all
                           beneficial use impairments were addressed.
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                                                         Improving EPA's Great Lakes Program
                             Toxic sediments is one of the major issues affecting all U.S. and
                             shared areas of concern.  While costs of remediating toxic
                             sediments vary widely, it can cost on average $5.6 million to
                             remediate sediments in one area of concern. In addition, Superfund
                             sites impact about half (22 of 31) of the areas of concern, further
                             complicating the issues being addressed. See exhibit 3 for a
                             detailed table on the status of RAPs.
                                            Figure 1: Forty-Three Areas of Concern
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Restoration of the
Great Lakes
Since the Agreement was signed in 1972, actions of EPA, other
Federal agencies, and states have resulted in restoration of areas of
the Great Lakes basin ecosystem.

•      Through a combination of pollution prevention and site
       restoration activities, the release of toxic substances into the
       environment has been reduced, dramatically improving the
       health of many species offish and wildlife.

•      Actions to get the lead out of gasoline have reduced the
       level of atmospheric loadings of lead to the Great Lakes.
                                                                              Report 99P00212

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                                                    Improving EPA's Great Lakes Program
                           •      Cancellation of the pesticide DDT increased the breeding
                                 populations of bald eagles, peregrine falcons, and osprey in
                                 the Great Lakes basin.

SCOPE AND
METHODOLOGY         The evaluation was conducted from July 10, 1998, to May 17,
                           1999.  Fieldwork was performed primarily in Region 5, with limited
                           work performed in Regions 2 and 3.  Except as noted in exhibit 4,
                           we performed our work in accordance with Government Audit
                           Standards, 1994 Revision, issued by the Comptroller General of the
                           U.S.

                           For further details on scope and methodology, see exhibit 4.
                                                                        Report 99P00212

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                                                   Improving EPA's Great Lakes Program
                                  CHAPTER 2
             Key Great Lakes Activities Need Strengthening

                          EPA needs to improve two key processes for protecting and
                          restoring the Great Lakes: LaMPs and RAPs. LaMPs and RAPs
                          are taking longer than expected to complete.  For example, while a
                          draft LaMP for Lake Michigan was first published in 1992, the
                          LaMP was never finalized, thereby not meeting the statutory
                          deadline of January 1, 1994.  Officials currently plan to issue a
                          LaMP document for Lake Michigan by April 21, 2000.  To date,
                          no U.S. RAPs have had all of their beneficial use impairments
                          corrected.

                          To improve the LaMP process, EPA needs to (1) emphasize issuing
                          written documents for Lakes Michigan, Erie and Huron during FY
                          2000; and (2) propose revising the LaMP process to address issues
                          that have hindered the issuance of written plans. To improve the
                          RAP process, Region 5 needs to better organize the RAP liaisons.
                          Finally, Region 5's work on LaMPs and RAPs would benefit from
                          clarifying the organizational roles and responsibilities of the offices,
                          divisions and teams.  These actions are needed to reach the goal of
                          restoring and maintaining the chemical, physical, and biological
                          integrity of the Great Lakes.
IMPROVING THE
LaMP PROCESS          Progress of LaMPs varied widely, as measured by issuance of
                          documents to the IJC (table 2). The LaMPs for Lakes Ontario and
                          Superior were the furthest along, a stage 1 problem definition
                          document had been issued for both. Federal and state officials have
                          been working on the stage 1 problem definition document for Lakes
                          Michigan and Erie for nine and six years respectively, and expect to
                          take at least another year. The LaMP process for Lake Huron has
                          not been started yet.  (Background information on LaMP status is
                          included in exhibit 2.)
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                                                   Improving EPA's Great Lakes Program
                                                   Table 2
                                           Status of Stage 1 LaMPs
Lake
Erie
Huron
Michigan
Ontario
Superior
- Chemical
- Non-chemical/ecosystem
Year
Started
1993

1990
1996
1991
1994
ToIJC
Actua
1



1998
1995
Estimat
e
2000

2000

2000
                          Much of the delay in issuing LaMPs was due to the complexity of
                          the LaMP development process, which (1) addressed broad issues
                          such as toxics and the ecosystem; (2) involved many stakeholders at
                          all levels of governments, as well as non-governmental
                          organizations; and (3) often required international coordination.
                          However, EPA can take some actions to improve the LaMP
                          development process.
 Issue LaMP Documents
 and Address Lake Huron
We recommend that by September 2000 the Regional
Administrator, Region 5, work with other appropriate
Federal, state and Canadian government organizations to:

•      Issue LaMP documents for Lakes Michigan and Erie
       describing what is known about the extent of the
       problem and load reductions and remedial measures
       that are needed (2.1).

•      Decide what action to take on the Lake Huron LaMP,
       and when activities will begin (2.2).
        While a LaMP has not been issued, a discussion paper, Ecosystem Principles and Objectives, Indicators
and Targets for Lake Superior, was issued in 1995.
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                          Improving EPA's Great Lakes Program
Completing plans for each of the Great Lakes is an important part
of ensuring that Federal and state activities are adequate to protect
and restore the Great Lakes. The Agreement requires written plans
describing the problem, the reductions in chemicals that are needed,
and the remedial measures that are needed. While activities to
restore and maintain the Lakes were ongoing, these activities were
taking place without such written plans, except for Lake Ontario
and some components of Lake Superior. Without a plan or LaMP,
there was no single document that (1) provided a guide for future
work, (2) identified who needed to be involved, (3) established lines
of accountability, and (4) served as a basis for measuring progress.
The lack of plans also raises questions whether EPA was doing the
right,  and highest priority, activities needed to protect the Great
Lakes. Without written plans describing the problems and what
needs to be for a Lakes, there is also a question of whether the
activities being done are the most cost effective.

Besides the environmental impact, the length of time that it had
taken to produce LaMP documents resulted in frustration and
skepticism about the LaMP process.  Region 5 and state staff who
worked on the LaMPs expressed frustration with the process, the
amount of time involved, and the lack of progress in completing
documents. Also, state officials were hesitant to start the LaMP for
Lake Huron because of the problems they saw with the other
LaMPs.

Due to the lack of progress on LaMPs and the problems the lack of
a plan has created, EPA needs to place renewed emphasis on
issuing initial LaMP documents during the remainder of FY 1999
and 2000.

•     For Lakes Michigan and Erie, EPA needs to work with its
      partners to issue a document describing what is known
      about the extent of the problem, and the needed load
      reductions and remedial measures. Region 2 successfully
      used this  approach in completing the Lake Ontario LaMP.

      In working on the Lake Michigan and Erie LaMPs, Region
      5 should consider the methods used for completing the Lake
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                                                    Improving EPA's Great Lakes Program
                                  Ontario and Superior LaMPs.  Region 2 used a technical
                                  writer and a dedicated staff member, who consulted with
                                  other staff, to write the Lake Ontario LaMP. For Lake
                                  Superior, members of the LaMP committee, which include
                                  EPA, other Federal agencies, states and Canadian
                                  representatives, wrote the LaMP. EPA did have a person
                                  serving full-time as the LaMP writer, but had also been
                                  temporarily serving as the Lake team manager. Region 5's
                                  team structure, where staff spend 10 to 30 percent of their
                                  time on team activities, had not been effective because the
                                  time spent on team activities was taken up in meetings,
                                  leaving little time for actually writing the document.

                           •       For Lake Huron, EPA needs to decide how it will restore
                                  and maintain the chemical, physical, and biological integrity
                                  of the lake.  EPA should also let the public know what it
                                  plans to do for Lake Huron, and when it plans to start.

Agency Comments         The Regional Administrator agreed with recommendation 2.1.  At
and Actions                the April 1999 Region 5 and State Environmental Directors
                           meeting, a challenge was issued to complete stages 1 through 3 of
                           the LaMPs for Lakes Michigan,  Erie,  and Superior by April 21,
                           2000 (Earth Day).  Workgroups have developed plans for
                           accelerating completion of the LaMPs, and the state representatives
                           are in general agreement with the proposed schedules. The
                           workgroups will work with the LaMP Management Committees
                           and Canada (for Lakes Erie and Superior) to reach agreement on
                           the schedules.

                           State and regional commitment is an important part of the Agency's
                           strategy to accelerate LaMP development. For Lakes Michigan and
                           Erie, state commitment is needed to write documents and to
                           expedite the review and  approval process.  All Region 5 offices and
                           divisions must stand ready to support acceleration of LaMP
                           development. Regional  resources have been allocated to the goal.
                           There also needs to be a short-term focusing of existing program
                           staff with needed expertise to assist with the LaMPs.

                           The Agency's action plan for the Lakes Michigan, Erie, and
                           Superior LaMPs is:
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                          Improving EPA's Great Lakes Program
                           Table 3
       Action Plan For Lakes Michigan, Erie and Superior
Action
Detailed schedules through LaMP
Management Committees
US Policy Committee Meeting to ensure
progress on meeting schedule deadlines
LaMP documents issued (see appendix 1
for details on what will be included in
the documents)
Finalized LaMP documents
Date
Summer 1999
November 1999
Spring 2000
April 2000
December 2000/2001
The Regional Administrator agreed with recommendation 2.2.
Regarding Lake Huron, the state of Michigan developed a draft
Lake Huron Initiative report. While the initiative is not currently a
LaMP, it contains many elements of a LaMP. The state of
Michigan would like to use the initiative as a way to reinvent
lakewide management planning.

Completion of the Lake Huron Initiative report will require
Canadian approval. Environment Canada has informed EPA that
they will not be able to take up the issue of a LaMP for Lake Huron
until the year 2000, due to resource constraints. During the year
2000, EPA will work with Michigan and Environment Canada
regarding progress and the future of the initiative.
                10
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                                                   Improving EPA's Great Lakes Program
Revise the LaMP Process
                         EPA's action plan for Lake Huron is:
                                                     Table 4
                                             Action Plan for Lake Huron
Action
Draft Lake Huron Initiative
Initiative meetings
Initiative document
Lake Huron Symposium
Date
June 1999
June 1999
January /February 2000
April 2000
Early 2001
We recommend that the Regional Administrator, Region 5
work with Canada, other Federal agencies, and states to
identify, and implement, ways to make the LaMP process
more efficient (2.3).
                         Attempts to get complete information regarding problem
                         identification hindered EPA's and Canada's issuing of stage 1
                         LaMPs. In fact, throughout the lifetime of the LaMP new
                         information will likely become available regarding the problems of
                         each specific Great Lake. Also, while the Agreement calls for
                         issuing documents in four distinct stages, EPA found that in
                         practice the stages overlap. For example, all of the problem
                         identification was not completed before load reduction targets were
                         set or remedial actions began.

                         The Lake Ontario LaMP did not meet the strict definition of a stage
                         1 LaMP. The LaMP included all information that EPA and the
                         other parties to the agreement had at the time, notwithstanding
                         whether the information related to problem identification, load
                         reduction targets,  or remedial actions.  Where there was incomplete
                         information, the LaMP included a plan for obtaining the
                         information.  EPA has not received any negative feedback about
                         using this approach for a LaMP.
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                           Since the concept of issuing LaMPs in "stages" does not appear to
                           be working, EPA should work with Canada, other Federal agencies,
                           and states to identify ways for making the LaMP process more
                           efficient.  Some of the options that EPA staff suggested include:

                           •      issuing an initial document based on existing information
                                 and a plan for the next several years, and then updating the
                                 document every two years, such as what is being done with
                                 the Lake Ontario LaMP;

                           •      combining stages 1, 2 and 3 into one document;

                           •      revisiting the definition of LaMP as contained in the
                                 Agreement.
Agency Comments
and Actions
IMPROVING EPA
INVOLVEMENT
INRAPs
In responding to recommendation 2.3, the Regional Administrator
stated that LaMP development is now being made more efficient
through streamlining and acceleration. (See response to
recommendations 2.1 and 2.2.)  A workgroup has developed a
number of key recommendations that will be implemented.  EPA
will also use the process for development of the Great Lakes
Strategy to identify and implement ways to make the LaMP process
more efficient. To gain support of Canadian counterparts, the
Binational Executive Committee discussed how to improve the
LaMP process at their July  1999 meeting.
Region 5 RAP liaisons were not as effective as they could be in
working with the state and local officials. Region 5 assigned staff
to serve as liaisons for each of the RAPs within the Region.
However, the liaisons generally did not coordinate with each other
and many had not received training recently regarding their
responsibilities.  As a result, Region 5 was not as effective as it
could be in coordinating with RAPs.

According to the Act, states are primarily responsible for
completing RAPs, and were to incorporate them into state water
quality plans by January 1, 1993. EPA's role was to ensure that
states complete RAPs.  Regions 2, 3 and 5  approached their
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                          involvement in the RAPs differently.3 For example, in Region 5,
                          one person is assigned to be the RAP liaison for each RAP in the
                          Region. The liaison's goal was to facilitate and coordinate
                          communication regarding the RAPs.  In Regions 2 and 3, one
                          person serves as the contact point and provides technical support
                          for all of the RAPs in each region.
RAP Coordinator
Needed
We recommend that the Regional Administrator, Region 5
establish a RAP coordinator in Region 5 (2.4).
                          Region 5 needs to designate someone to be responsible for
                          coordinating RAP liaison activities.  The coordinator should be
                          responsible for:
                                 defining the roles and responsibilities,
                                 training new liaisons,
                                 facilitating communication among the RAP liaisons,
                                 collecting information for management on the status of
                                 RAPs, and
                                 ensuring there is adequate coordination with all RAP
                                 organizations.
                          In Region 5, the responsibility for organizing the RAP liaisons was
                          not clear. The Region 5 Lake Teams, GLNPO and the Water
                          Division could all have been potentially responsible for organizing
                          the RAP liaisons. GLNPO and the Water Division had staff who
                          were considered RAP coordinators, but neither of them performed
                          all of the activities that were needed to make the RAP liaisons more
                          effective. In GLNPO, the RAP coordinator only tracked the status
                          of the RAPs.  In the Water Division, the RAP coordinator kept a
                          list of all the RAP liaisons, but the list was not accurate. As for the
                          Region 5 Lake Team managers, while they put together an initial
                          training program for the liaisons, they had other responsibilities that
                          prevented them from devoting the time that was needed to continue
                          organizing the RAP liaisons.
       Seventy-eight percent of the U.S. and binational RAPs are in Region 5.

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                           EPA was to work with and ensure that states complete RAPs.
                           Liaisons were a way for EPA to provide information and technical
                           resources to RAPs and to monitor their progress. Better organized
                           liaisons will increase their effectiveness, and assist in further the
                           progress of all RAPs.

Agency Comments         In responding to recommendation 2.4, the Regional Administrator
and Actions                did not believe the establishment of a coordinator was needed for
                           RAPs, but did outline a number of other actions to accelerate
                           RAPs. Rather than assigning a liaison to all RAPs, decisions will be
                           made on a case-by-case basis, and the liaison's level of involvement
                           may differ for each RAP. In general, a liaison will not be assigned
                           for RAPs that have completed stage 2. All Region 5 divisions,
                           offices and teams will be asked to provide some expertise and
                           leadership where the RAP objectives align with program objectives.

                           The regional lake teams will serve as the forum for RAP
                           coordination.  Lake team managers will be given a renewed charge
                           to serve as the umbrella for the RAPs in their lake, and will be
                           responsible for providing orientation to the RAP liaisons. The
                           orientation will define the roles and responsibilities of the liaison.
                           As RAPs progress to different stages of completion, the team
                           managers will work with the liaison to redefine their role.

                           EPA's action plan for accelerating RAPs is:
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                                                     Table 5
                                              Action Plan for RAPs
OIG Evaluation
Action
Initiate RAP challenge with states
Discussion with states on roles,
schedules, and grant funds
Renewed charge to team mangers
RAP orientation by team managers
RAP challenge discussion at US
Policy Committee meeting
Progress report at Binational
Executive Committee meeting
Timing
July 1999
July/ August 1999
August 1999
As liaisons are appointed
and RAP stages change
November 1999
December 1999
CLARIFYING
ORGANIZATIONAL
ROLES AND
RESPONSIBILITIES
In responding to the draft report, the Regional Administrator
proposed actions that were more comprehensive than we originally
recommended. The proposed actions, when implemented, will
increase the effectiveness of the RAP liaisons and increase state
progress in completing RAPs. We support the actions the Region
has proposed to take.
In 1995, Region 5 reorganized, maintaining a media-based division
structure and adding regional teams, including teams for Lakes
Michigan, Superior, and Erie (lake teams) (see figure 2).  The lake
teams generally have one permanent staff member, the team
manager. Team members are from Region 5's media divisions and
other offices. While some team members may be full time, most
team members  spend between 10 and 30 percent of their time on
team activities. The team managers each report to a division or
office director(s).
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             Figure 2: Region 5 Organization Chart
                                           'J T_L'
                                              May 12, 1999
The lake teams were to:
       improve multimedia coordination;
       be focal points for resources and provide strategies for each
       of the lakes, including the LaMPs; and
       rely upon programs to find solutions to problems.
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                           The media divisions and offices were to use the teams to focus their
                           efforts in the Great Lakes.
 Clarify LaMP and RAP
 Responsibility
Agency Comments
and Actions
 We recommend that the Regional Administrator, Region 5
 clarify and communicate the priority and responsibility of
 LaMPs and RAPs in Region 5 (2.5).
While the Region 5 team structure was to facilitate multimedia
coordination of activities, there was some confusion as to the
priority and responsibility for LaMPs and RAPs. When LaMP and
RAP activities matched the priorities of media programs, the
activities generally were completed. However, where activities
such as writing a LaMP document and serving as a RAP liaison did
not fit with media program priorities, it was less likely that the
activities were supported or completed timely.  LaMP and RAP
activities are both areas where improvements are needed.

Without the support of the Region 5 divisions and offices, teams
are unlikely to accomplish specific tasks.  Tasks that are the
responsibility of the teams are indirectly the responsibility of all
divisions and offices in Region 5.  Region 5 divisions and offices
need to recognize this responsibility and communicate it to their
staff. Not doing  so will result in continued problems with
completing LaMPs and less than effective use of RAP liaison
resources.

In responding to  recommendation 2.5, the Regional Administrator
agreed that Great Lakes activities, such as RAPs and LaMPs, that
are outside typical media priorities often receive less attention
within  Region 5 programs than headquarters driven requirements.
Attention to these activities can be increased in several ways.  One
way is  the participation of Region 5 programs in the development
and implementation of the Great Lakes strategy. A second way is
through the Region 5 planning process where LaMPs  and RAPs
will be highlighted to management and staff. The third way is to
align planning, budgeting, and accountability systems to support
completion of LaMPs and RAPs.
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GLNPO's Role Needs
Definition
                        Region 5's action plan and milestone dates to address the
                        recommendation are:

                                                  Table 6
                                            Action Plan for RAPS
Action
Lake Summit with Region 5 senior managers
Summary of agreements from Lake Summit
Region 5 lake team resource requests
conveyed
Resource decisions made by Region 5
Regional results plan
Midyear goal reporting
Lake Summit with Region 5 senior managers
Date
June 25, 1999
July 1999
July 1999
September 1999
October 1999
March 2000
April 2000
We recommend that the Regional Administrator, Region 5
define and communicate the role of GLNPO in LaMPs and
RAPs (2.6).
                        GLNPO's involvement in LaMPs and RAPs was limited. GLNPO
                        activities included:
                               tracking the status of LaMPs and RAPs,
                               serving on LaMP teams, and
                               providing grant funds for projects associated with LaMPs
                               and RAPs.
                        While GLNPO was part of the LaMP teams, several team members
                        told us that they continued to have problems getting information
                        from GLNPO. According to the lake team managers, GLNPO staff
                        generally did not offer information. Instead, they would find out
                        accidently that GLNPO had information they needed. On the other
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                           hand, GLNPO managers stated that the lake team managers did not
                           frequently ask for information.

                           Early in the history of the LaMP process, GLNPO and the Region 5
                           Water Division management decided that the Water Division would
                           be primarily responsible for LaMPs and RAPs.  This was a
                           controversial decision at the time, and continues to be a sensitive
                           issue. As a result, GLNPO and the Water Division had limited
                           communication regarding LaMPs and RAPs. In 1995,
                           responsibility for LaMPs and RAPs was transferred to the Region 5
                           lake teams. While coordination between GLNPO and the lake
                           teams increased, coordination and communication problems
                           continued.  As a first step, officials need to define the role GLNPO
                           has with LaMPs and RAPs. Once defined, GLNPO needs to
                           devote the resources necessary to fulfill that role.
Agency Comments
and Actions
CONCLUSION
The Regional Administrator agreed with recommendation 2.6 and
and stated that it is important that the role of all EPA programs in
LaMPs and RAPs be better defined and communicated. LaMP and
RAP roles and responsibilities will be addressed during the
development and implementation of the Great Lakes strategy,
which is discussed in Chapter 4.
                           While LaMPs and RAPs are complex, EPA can take actions to
                           further the progress of both. Most important, officials need to
                           clearly communicate the priority and responsibility of LaMPs and
                           RAPs to all Region 5 staff.  Without this, other actions directed
                           toward issuing LaMP documents and organizing RAP liaisons will
                           not be as effective as they could be. LaMPs and RAPs are the
                           primary processes called for in the Agreement to coordinate Federal
                           and state activities directed toward restoring beneficial uses to the
                           Great Lakes.  The less effective these processes are, the less likely it
                           is that the goal of restoring and maintaining the chemical, physical,
                           and biological integrity of the Great Lakes will be met.
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                                   CHAPTER 3
                       Responsibilities of EPA Offices
                     in the Great Lakes Need Definition
                          GLNPO does not have official agreements with other EPA offices
                          that work in the Great Lakes, as required by the Clean Water Act4.
                          These offices include Regions 2, 3, 5, and ORD.  As a result,
                          relationships of Region 5 offices working in the Great Lakes have
                          suffered, and  GLNPO and ORD did little coordination on research
                          planning.  GLNPO should enter into one, or multiple, agreements
                          with these entities to identify the roles and responsibilities of each in
                          the Great Lakes.
                           We recommend that the Regional Administrator, Region 5
                           prepare an agreement(s) that outlines the roles and
                           responsibilities of GLNPO, ORD, Regions 2, 3, and 5 in the
                           Great Lakes (3.1).
                          According to the Act, one of the functions of GLNPO is to
                          coordinate actions of the Agency, both headquarters and regions,
                          aimed at improving Great Lakes water quality.  The legislative
                          history of this section of the Act appears to indicate that Congress
                          intended these agreements to ensure that intergovernmental
                          coordination occurred, as well as coordination within EPA.

                          GLNPO's relationships with Region 5 and ORD were adversely
                          affected because the agreements were not in place, while
                          relationships with Region 2 and 3 were not. In Region 5,
                          GLNPO's working relationship with other divisions and teams
                          suffered from a lack of clear definition of roles and responsibilities,
       4 Section 118 (c) (8) of the Act requires that GLNPO enter into agreements with the various
organizational elements of the Agency working in the Great Lakes.

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                           as described earlier.  GLNPO and ORD also did little coordination
                           to plan research projects in the Great Lakes.
CONCLUSION
                           A clear description of roles and responsibilities of GLNPO, ORD,
                           Regions 2, 3, and 5, would help improve adversely affected
                           relationships and maintain good working relationships. Working
                           together to identify roles and responsibilities would also help
                           coordinate and clarify activities each was responsible for in the
                           Great Lakes. This would help improve working relationships and
                           efficiency of work in the Great Lakes to the benefit of the
                           environment.  Finally, taking a step to maintain good working
                           relationships now would help prevent deterioration of those
                           relationships in the future, and help prevent any negative impact on
                           the Great Lakes.
AGENCY COMMENTS
AND ACTIONS
The Regional Administrator agreed with the recommendation.
Roles and responsibilities of GLNPO, ORD, and Regions 2, 3 and 5
will be updated and articulated as part of the Great Lakes Strategy
planning process. The action plan and milestone dates for the Great
Lakes Strategy are described in Chapter 4.
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                   CHAPTER 4
Great Lakes Strategy Needs Improvement
          GLNPO officials can learn from problems they encountered
          creating and implementing the 1992 Joint Federal/State 5-year
          Strategy (strategy).  In creating the next strategy, GLNPO should
          strive to: (1) obtain buy-in and commitment from all parties, (2)
          focus on goals, (3) include performance measures, and (4) provide
          accountability for implementation which will result in a meaningful
          strategy that helps bring together Great Lakes efforts and activities.
          From this, GLNPO can design a new strategy that will fulfill a new
          purpose for the Great Lakes and help carry efforts forward to the
          millennium.

          GLNPO developed the 1992 strategy to help coordinate activities
          with other Federal agencies and states working in the Great Lakes.
          Parties to the Great Lakes strategy included six Federal agencies,
          the eight Great Lakes states and one tribal representative.

                                      Table 7
                         Parties to the Great Lakes Strategy
           Federal Agencies             States         Tribal Representative
           EPA                        Illinois         Chippewa/Ottawa Fishery
           Army Corps of Engineers        Indiana               Management
                                      Authority
           National Oceanographic and     Michigan
            Atmospheric Administration    Minnesota
           Coast Guard                  New York
           Department of Agriculture       Ohio
           Fish and Wildlife Service               Pennsylvania
                                      Wisconsin
          The purpose of the strategy was to shift away from doing business
          as independent agencies and to begin working as a team. The
          strategy was a voluntary effort to help focus Federal, state and
          tribal efforts on the Great Lakes.  It established three goals: (l)to
          reduce toxic pollution, (2) to protect and restore habitat, and (3) to
          protect human health and the health of the ecosystem's species.
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                          The strategy further identified specific activities and a framework
                          for implementing the strategy.

                          GLNPO management plans to issue a new Federal, state and tribal
                          strategy for the Great Lakes, by April 2000. Officials are taking
                          this opportunity to reconsider the strategy format, purpose, and
                          time frame.
BUY-IN AND
COMMITMENT
NEEDED
We recommend that the Regional Administrator, Region 5
ensure the Great Lakes strategy has input from all (former
and new) parties during its development (4.1).
                          Getting parties to buy-in to the strategy and participate in its
                          development will help ensure they will support the strategy and try
                          to implement it. According to several representatives of other
                          Federal agencies, states, and tribes, EPA primarily wrote the
                          strategy and presented it to the parties rather than working with the
                          parties to put together a strategy that everyone could support. As a
                          result, the original strategy was  developed without the complete
                          buy-in from all parties.  At the time, working in partnership was a
                          relatively new concept.

                          Several groups that were not involved in development of the
                          strategy deserve renewed or new attention:

                          •      Federal Research Community

                                The Federal research community should be included in the
                                development of the strategy to improve coordination on
                                research planning.  GLNPO, as program manager for the
                                Great Lakes, and the Federal Great Lakes research
                                community did not effectively coordinate regarding research
                                planning.  The lack of coordination may have resulted in
                                needed research not being undertaken or research
                                completed that was not needed or used.
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                          •      Regions 2, 3, and 5

                                Including Regions 2, 3, and 5 would also help give them a
                                sense of ownership of the strategy. Likewise, the Region 5
                                lake teams and media divisions could also benefit from
                                participation by developing a sense of ownership to the
                                strategy.

                          •      Great Lakes Tribes

                                GLNPO should make a special effort to ensure that all
                                Great Lakes tribes are aware of the opportunity to
                                participate in the development of the new strategy.  The
                                tribal representative on the 1992 strategy spoke for only a
                                small number of tribes. After the 1992 strategy was
                                developed, several other tribes expressed concern at not
                                being included.

                          GLNPO has begun implementing recommendation 4.1 to get input
                          from all parties. Preliminary discussions have been held with staff
                          from Regions 2, 3  and 5,  Office of Research and Development,
                          states, tribes, and other Federal agencies. Many additional Great
                          Lakes stakeholders, including the Federal research community and
                          tribes will be brought into the process once the Agency enters the
                          development phase.  The action plan and milestone dates for the
                          development of the strategy, which will address the
                          recommendations in this chapter, are included at the  end of the
                          chapter.
Agency Comments
Commitment Needed
                            We recommend that the Regional Administrator, Region 5
                            get agreement from all parties to implement the strategy
                            (4.2).
                          GLNPO officials need to identify a new way to ensure they have
                          obtained agreement to implement the strategy. For the 1992
                          strategy, managers at some Federal agencies indicated they were
                          committed to it, but did not follow through by dedicating resources
                          to achieving those commitments.  Similarly, some state officials
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Agency Comments
Agency Comments
could not sign the strategy because of their political climate, even
though they may have agreed with the strategy in principle.

In responding to recommendation 4.2, the Regional Administrator
stated that GLNPO plans on implementing the recommendation
through closer communication with key management officials
during the consensus building phase of the strategy, as well as
devising an improved formal mechanism to gain support for the
strategy.
 FOCUS ON GOALS
 We recommend that the Regional Administrator, Region 5
 focus the strategy on overall goals, as opposed to activities
 (4.3).
The new strategy should serve as an umbrella document, bringing
together all Great Lakes efforts and initiatives in one place. The
1992 strategy emphasized detailed activities rather than
achievement of goals and performance measures. Parties to the
strategy had difficulty planning several years ahead which activities
would be useful to meeting the goals and priorities of the strategy.
Other processes exist that outline specific Great Lakes  activities,
such as: LaMPs, RAPs, and the Binational Toxics Strategy.
Including detailed activities to the Great Lakes  strategy can be seen
as another layer of reporting on the same activities.

Region 5 agreed with recommendation 4.3. The focus of the
strategy will be on (1) protecting and restoring  the chemical,
physical, and biological integrity of the Great Lakes basin
ecosystem, (2) the removal of beneficial  use impairments, and (3)
the virtual elimination of persistent toxic substances. At the same
time, discussions with some stakeholders have  encouraged greater
specificity in the strategy so that a wide variety of Agency
managers, as well as the public, can understand what is intended to
be accomplished.  During the development of the strategy, GLNPO
will attempt to address both of these somewhat contradictory
objectives.
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 INCLUDE
 PERFORMANCE
 MEASURES
Agency Comments
 We recommend that the Regional Administrator, Region 5
 include performance measures and report progress against
 the measures (4.4).
The new strategy should include performance measures to report
on progress in restoring and maintaining the Great Lakes. The
1992 strategy did not include performance measures to evaluate
progress toward achieving the goals of the strategy. Performance
measures have become increasingly important to EPA as the
Agency moves toward adopting the Government Performance and
Results Act of 1994.

Region 5 agreed with the recommendation 4.4.  For Federal
agencies, the Government Performance and Results Act is one
potential source of measures. For state agencies, Environmental
Performance Partnership Agreements include performance
measures and reports.  During the development of the strategy,
GLNPO will also explore other possibilities for measurement and
progress reports, including subsequent development of an
implementation plan, annual meetings or conference calls, and
agreed delineation of Great Lakes activities in work plans.
 ENSURE
 IMPLEMENTATION
 We recommend that the Regional Administrator, Region 5
 designate GLNPO as responsible for working with the
 parties to the new strategy to ensure it is implemented (4.5).
                          GLNPO, in its role of coordinator of U.S. actions in the Great
                          Lakes, needs to ensure that the new strategy will be better
                          implemented than the 1992 strategy. GLNPO needs to ensure
                          parties to the strategy meet periodically to assess their collective
                          progress and that there is adequate coordination of activities.

                          The implementation of the 1992 strategy suffered from a lack of
                          accountability. No entity monitored the strategy to ensure that
                          commitments were met. As a result, some elements of the
                          framework of the strategy were not completely implemented.
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                           •      The U.S. Policy Committee was intended to facilitate
                                  discussion and coordination of activities among Federal and
                                  state agencies.  According to the strategy, the committee
                                  was to help set overall priorities and coordinate the
                                  development of individual agency action plans to achieve
                                  the goals of the strategy.  The U.S. Policy Committee met a
                                  couple of times, but has not met for several years.5

                           •      When GLNPO officials prepared reports, they focused on
                                  summarizing activities without assessing progress toward
                                  achieving the goals. Without assessing progress, there was
                                  no determination of how well parties to the Great Lakes
                                  strategy were doing in achieving the strategy's goals.

Agency Comment          The Regional Administrator agreed with recommendation 4.5.
                           GLNPO will be working over the next year to ensure the
                           completion and implementation of the strategy.
CONCLUSION
AGENCY ACTIONS
                           Without full implementation of and buy-in to the Great Lakes
                           strategy Federal agencies and states were not able to achieve the
                           intended benefits of the strategy. Each Federal agency, state, and
                           the tribal organization that was party to the strategy was doing
                           work in the Great Lakes, and without coordination these activities
                           may not completely solve the problems in the Great Lakes.
                           Working together, parties can learn from the experience of others
                           and make the best use of limited resources.
                           In responding to the draft report, the Regional Administrator
                           proposed the following action plan for implementing the strategy:
                                                         Table 8
                                         Action Plan for the Great Lakes Strategy
        With the acceleration of LaMPs and RAPs, the Agency is reconvening the U.S. Policy Committee, with
the initial meeting scheduled for November 1999.

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Action
Hold initial consultations on scope and
nature of strategy
Develop a draft plan for strategy process
Request participation from lead Agencies
Hold initial conference call
Hold first kick-off meeting
Brief US Policy Committee
Draft strategy
Public consultation
Final document issued
Date
Completed
Completed
August 1999
September 1999
October 1999
November 1999
December 19997
January 2000
February 2000
April 2000
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                                                                               Exhibit 1
                                                                             Page 1 of 3
                                    Background	
Great Lakes Water
Quality Agreement         The overall purpose of the Great Lakes Water Quality Agreement
                           (Agreement) was to restore and maintain the chemical, physical,
                           and biological integrity of the Great Lakes.  The general objective
                           of the Agreement was that the waters be free from:

                           •      substances that may form into sludge or will adversely affect
                                  aquatic life or waterfowl;

                           •      floating materials such as debris, oil, and scum in amounts
                                  that are unsightly;

                           •      materials that produce color, odor, taste, or other
                                  conditions in such a degree as to interfere with beneficial
                                  uses;

                           •      materials that are toxic or harmful to humans, animal or
                                  aquatic life; and

                           •      nutrients that create growths in aquatic life as to interfere
                                  with beneficial uses.

                           To restore and protect the Great Lakes, the Agreement identified
                           14 beneficial uses impairments that needed to be addressed, as
                           shown in table 9.
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                                                                                  Exhibit 1
                                                                                Page 2 of 3
                                                        Table 9
                                              Beneficial Use Impairments
                                    Restrictions on fish and wildlife consumption
                                    Tainting of fish and wildlife flavor
                                    Degradation offish wildlife populations
                                    Fish tumors or other deformities
                                    Bird or animal deformities or reproduction problems
                                    Degradation of benthos (organisms living at the bottom
                                    of the lake)
                                    Restrictions on dredging activities
                                    Eutrophication or undesirable algae
                                    Restrictions on drinking water consumption, or taste
                                    and odor problems
                                    Beach closings
                                    Degradation of aesthetics
                                    Added costs to agriculture or industry
                                    Degradation of phytoplankton and zooplankton
                                    populations
                                    Loss offish and wildlife habitat
Importance of
Coordination
The U.S. has numerous Federal agencies and states with an interest
in the Great Lakes.  For example, several Federal agencies are
responsible for habitat: EPA, Army Corps of Engineers, Fish and
Wildlife Service, and Department of Agriculture. EPA and the
Army Corps of Engineers both work with sediments. The EPA and
the Coast Guard are both concerned with exotic species.  Besides
Federal agencies, there are eight states with various  state agencies
that have an interest in the Great Lakes. The overlapping
responsibilities make coordination among Federal and state
agencies very important.
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                                                                              Exhibit 1
                                                                             Page 3 of 3

Role of GLNPO            The Act formally established the Great Lakes National Program
                           Office (GLNPO) and identified its functions as:

                           •       development and implementation of specific action plans to
                                  carry out responsibilities of the Agreement,

                           •       establishment of a Great Lakes system-wide surveillance
                                  network to monitor water quality,

                           •       serving as liaison with Canada,

                           •       coordinating actions of the Agency directed at improving
                                  the Great Lakes, and

                           •       coordinating actions with other Federal agencies and states.
                                          31

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                                                    Improving EPA's Great Lakes Program
                                                                              Exhibit 2
                                                                            Page 1 of 4
                                 Status of LaMPs
LAKE ERIE
                           In Spring 1993, the U.S. and Canada began the initial phase of
                           developing a Lake Erie LaMP. Ohio is serving as the lead state,
                           with participation from Michigan, Pennsylvania, and New York. In
                           1995, a concept paper was issued identifying the LaMP's goal, to
                           restore and protect the beneficial uses of Lake Erie, with a focus on
                           the 14 beneficial use impairments.  Ecosystem objectives will be
                           used to guide LaMP efforts toward defined endpoints and serve as
                           a basis for establishing commitments for reducing, eliminating, or
                           preventing sources of beneficial use impairments.

                           The LaMP is being produced as a series of technical reports
                           describing the current and desired states of environmental
                           conditions in Lake Erie. The reports on critical pollutants and
                           beneficial use impairments, when completed, will represent the
                           stage 1 LaMP for Lake Erie. The LaMP will also include
                           ecosystem objectives, and is expected to be issued by June 2000.
                           Table 10 identifies the report topics, current status,  and the dates
                           the reports are expected to be completed.
                                          32

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                                                    Improving EPA's Great Lakes Program
                                                                              Exhibit 2
                                                                            Page 2 of 4
                                       Table 10
                                   Lake Erie LaMP
Report Topic
Ecosystem objectives and
indicators
Critical pollutants and other
pollutants of concern
Beneficial use impairments
Status as of April 1999
Draft report was sent to the
LaMP's technical workgroup on
December 8, 1998.
Draft report is being prepared.
Use impairment assessments had
been issued for 6 of 14 beneficial
uses.
Expected Final Report
June 1999
August 1999
Two additional assessments will be
completed by April 1999. The
subcommittee is working on a
strategy for completing the six
remaining use impairment
assessments.
LAKE HURON
                           In 1999, EPA, the state of Michigan, Canada and other Federal
                           agencies began working on a Lake Huron Initiative, which has
                           similar goals to a LaMP.  Prior to this, the State of Michigan held a
                           conference on June 10, 1998, in Saginaw, Michigan which
                           addressed the current status of the Lake Huron watershed. The
                           conference was attended by stakeholders from U.S.  and Canadian
                           government and non-government agencies.  Representatives of the
                           Michigan Departments of Natural Resources, Environmental
                           Quality, and Agriculture voiced their opinions that a LaMP was not
                           the preferred management option for the basin because of the
                           difficulties that other organizations were having with LaMPs for the
                           other Great Lakes.  In January 1999, officials met again to establish
                           the Lake Huron Initiative and set out a schedule for beginning work
                           on Lake Huron.
                                          33
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                                                    Improving EPA's Great Lakes Program
                                                                             Exhibit 2
                                                                            Page 3 of 4
LAKE MICHIGAN
LAKE ONTARIO
                           The Great Lakes Critical Programs Act required EPA to publish in
                           the Federal Register a draft LaMP for Lake Michigan by January 1,
                           1992, and a final LaMP by January 1, 1994. EPA published the
                           draft in August 1992. Based on public comments, EPA revised the
                           draft and issued it for public comment again in May 1995. This
                           draft focused primarily on toxic pollutants. However,
                           governmental agencies and stakeholders recognized the draft was
                           too limited, and that other stressors contribute to impairments in
                           Lake Michigan.  Comments confirmed that the LaMP should
                           include an ecosystem approach to protecting Lake Michigan. EPA
                           is working with other governmental agencies and stakeholders to
                           revise the LaMP to address habitat, biodiverisity, and exotic species
                           issues. The final draft stage 1 LaMP will be circulated for public
                           comment in the fall of 1999, and submitted to the IJC in early 2000.
                          In 1996, Region 2, the New York State Department of
                          Environmental Conservation, Environment Canada, and Ontario
                          Ministry of the Environment officially started working on the Lake
                          Ontario LaMP.  The LaMP built on work the organizations had
                          been doing since 1987 under the Lake Ontario Toxics Management
                          Plan.  The stage 1 LaMP was issued in 1998. While the focus of
                          the stage 1 LaMP was on problem definition, it also included
                          elements of stages 2 through 4, which address load reductions and
                          remedial measures that need to be taken to achieve the load
                          reductions.

                          The LaMP included a work  plan for completing a draft stage 2
                          LaMP by the fall of 2000. Activities include:
                                          34
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                                                    Improving EPA's Great Lakes Program
                                                                              Exhibit 2
                                                                             Page 4 of 4
                                 evaluating the effectiveness of existing programs,
                                 enhancing mass balance models,
                                 facilitating cooperative lakewide monitoring,
                                 executing habitat protection and restoration activities,
                                 developing ecosystem objectives and indicators, and
                                 establishing basin teams and partnerships.
LAKE SUPERIOR
                           The Lake Superior LaMP is being done in segments: critical
                           pollutants, non-chemical stressors, and ecosystem principles and
                           objectives. Much of the focus, and written documents to date, had
                           been on critical pollutants and ecosystem principles. The stage 1
                           LaMP for critical pollutants was issued in September 1995, and the
                           stage 2 document is expected to be  completed in April 1999.  The
                           Ecosystem Principles and Objectives, Indicators, and Targets for
                           Lake Superior document was completed in September 1995 and
                           has been updated periodically.  EPA also expects to complete a
                           document combining the stage  1 and 2 LaMPs for non-chemical
                           stressors.

                           The Lake Superior LaMP covers more than the Agreement
                           anticipated because the IJC also recommended that Lake Superior
                           be a demonstration zone for zero discharge. The zero discharge
                           program (Broader Program) and emphasis on a partnership
                           approach to achieving goals, make up what is known as the Lake
                           Superior Binational Program. The LaMP also incorporates the
                           "Broader Program," that focuses on management and coordination
                           needed to ensure beneficial uses are protected and restored.  The
                           LaMP serves as an update for the Binational Program.
                                          35

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                                                   Improving EPA's Great Lakes Program
                                                                            Exhibit 3
                                                                          Pagel of 2
                                 Status of RAPs
                                      Table 11
                         Status of 31 U.S. and Binational RAPs
Areas -of-Concern
Ashtabula River
Black River
Buffalo River
Clinton River
Cuyahoga River
Deer Lake 6
Eighteenmile Creek
Fox River
Grand Calumet River
Kalamazoo River
Lower Menominee River
Manistique River
Maumee River
Milwaukee Estuary
Muskegon Lake
Oswego
Presque Isle Bay
River Raisin6
Rochester Embayment
Rouge River
Saginaw River/Bay
Sheboygan River
St. Louis Bay / River
Torch Lake 6
Waukegan Harbor
White Lake
State
OH
OH
NY
MI
OH
MI
NY
WI
IN
MI
MI/WI
MI
IN/OH
WI
MI
NY
PA
MI
NY
MI
WI
WI
MN/WI
MI
IL
MI
Report to IJC
Stage 1
1991
1994
1989
1988
1992
1987
1997
1988
1991

1991
1987
1992
1994
1987
1990
1993
1987
1993
1989
1988
1989
1992
1987
1993
1987
Stage 2


1989
1995


1997


1998
1996
1997


1994
1991


1997
1994




1995
1995
Latest
Update

1997
1999
1998
1996





1996
1997
1997

1994
1999
1995


1998

1995
1995


1995
No. of Use
Impairments
6
10
5
8
10

3
10
14
7
6
5
10
10
10
4
2

12
13
12
8
9

5
10
Impact from
SF Site
Y
Y
N
Y
N
N
N
N
Y
Y
Y
Y
N
N
Y
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Toxic
Sediments
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
       1 The RAPs will be updated during 1999, and will include an identification of the number of use
impairments.
                                         36
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         Improving EPA's Great Lakes Program
                                  Exhibit 3
                                 Page 2 of 2
Areas -of-Concern
State
Report to IJC
Stage 1
Stage 2
Latest
Update
No. of Use
Impairments
Impact from
SF Site
Toxic
Sediments
Binational Areas of Concern
St. Marys River
St. Clair River
Detroit River
Niagra River, NY
St. Lawrence River, Massena
Total
MI
MI
MI
NY
NY

1992
1991
1991
1994
1990


1995
1996
1994
1991


1997
1996

1996

10
9
9
5
3

Y
N
Y
Y
Y
22
Y
Y
Y
Y
Y
31
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                                                   Improving EPA's Great Lakes Program
                                                                            Exhibit 4
                                                                          Pagel of 2


             Scope, Methodology, and Prior Audit Coverage
SCOPE AND
METHODOLOGY        The evaluation was conducted from July 10, 1998, to May 17,
                          1999.  The fieldwork was performed primarily in Region 5, with
                          limited work performed in Regions 2 and 3.  Except as noted
                          below, we performed our work in accordance with Government
                          Audit Standards, 1994 Revision, issued by the Comptroller General
                          of the U. S. We deviated from standards only in the reporting of
                          results. The standards require that findings be presented
                          persuasively, and include sufficient, competent, and relevant
                          information in order to provide convincing evidence of the need for
                          corrective action.  Since the evaluation was performed at Region 5
                          management's request, with an acknowledgment that improvements
                          were needed, we limited the amount of detail in the report relating
                          to the conditions.  The focus of the report was on the cause of the
                          problems and the recommended corrective actions.

                          As part of the work, we evaluated the internal control assessment
                          of the Great Lakes National Program Office for FY 1996  and  1997.
                          We also assessed the Agency's compliance with laws and
                          regulations that were specific to the Great Lakes.

                          To gain an understanding of the LaMPs and RAPs, we discussed
                          the processes with management and staff at EPA, other Federal
                          agencies, states, and non-governmental organizations who were
                          involved with the processes. Due to the large number of
                          organizations involved with RAPs, we also sent surveys to EPA,
                          state and local officials requesting input on what can be done to
                          improve the RAP process.  We also evaluated completed LaMP and
                          RAP documents and reports that have been written about the
                          processes.
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                                                     Improving EPA's Great Lakes Program
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                           In order to make recommendations for improving the next Great
                           Lakes strategy, we evaluated the previous strategy and EPA's
                           implementation of the strategy.  We discussed with staff at EPA,
                           other Federal agencies, and states what can be done to improve the
                           next strategy. We also evaluated other planning processes to
                           determine the extent to which they can be used in coordinating
                           Federal and state activities in the Great Lakes.

                           As part of the second objective on effective national agreements,
                           we also evaluated the Agency's implementation of the Binational
                           Toxics Strategy. However, our limited review did not identify any
                           potential areas  of concern that warranted expanding the evaluation
                           or recommending improvements.

                           The Regional Administrator, Region 5, responded to the draft
                           report on July 27,  1999. Region 5 staff provided clarification of
                           some sections of the response through telephone discussions and
                           electronic mail. The response was incorporated  into the text of the
                           report and attached as appendix 1.
PRIOR AUDIT
COVERAGE               There was no prior audit coverage that related to our objectives.
                                           39

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                                                                             Appendix 1
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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                 GREAT LAKES NATIONAL PROGRAM OFFICE/REGION 5
                           77 WEST JACKSON BOULEVARD
                              CHICAGO, IL  60604-3590

                                  JUL271999

MEMORANDUM

SUBJECT:      Response to IG Draft Report No.  98-000360
               Improving EPA's Great Lakes Program

FROM:         Francis X.  Lyons
               Regional Administrator, Region 5
               Great Lakes National Program Manager

TO:            Anthony C. Carrollo
               Divisional Inspector General for Audits
               Northern Division

       Thank you for the opportunity to respond to the Draft Report on Improving EPA's Great
Lakes Program. Pursuant to your request, the attached response includes comments on the
findings and recommendations and action plans for implementing the recommendations.  An
electronic version of the response will be sent to Janet Kasper. Input to this response was
provided from GLNPO; the Region 5 Water Division; Regional Team Managers for Lakes
Michigan and Erie; the Regional Team Managers for Northwest Indiana, Southeast Michigan,
and Northeast Ohio, and Sediments; and the Office of Research and Development. Others,
including Regions 2 and 3, were also provided an opportunity to comment.

       If you have any questions about this response, please contact Gary Gulezian at 312-886-
4040. The staff contact for this report is Michael Russ, who can be reached at 312-886-4013.
                                             Francis X. Lyons
cc:     JoLynnTraub
       Gary Gulezian
       Steve Bradbury
       Howard Levin
                                     •ya way slvnud by FrancisX. Lyons.
                     i UK original response was signed u^
                                        40

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                                                    Improving EPA's Great Lakes Program
                                                                               Appendix 1
                                                                              Page 2 of 15
                   RESPONSE TO RECOMMENDATIONS
                     IG DRAFT REPORT NO. 98-000360
               IMPROVING THE GREAT LAKES PROGRAM
Recommendation 2.1.  Issue LaMP Documents. We recommend that by September 2000
the Regional Administrator, Region 5, work with other appropriate Federal, state, and
Canadian governmental organizations to issue LaMP documents for Lakes Michigan and
Erie describing what is known about the extent of the problem and load reductions and
remedial measures that are needed.

We concur with the recommendation and have begun to implement it.

The US and Canada have been successful  in developing and issuing the critical pollutant
component of the Lake  Superior Stage 2 Lakewide Management Plan (LaMP). The critical
pollutant component of the Stage 3 LaMP  for Lake Superior will be completed by April 2000.  In
formulating our strategy for accelerating the Lake Michigan and Lake Erie LaMPs, we evaluated
what has contributed to  the success of the Lake Superior effort. Two factors are noteworthy.
First, the Lake Superior Binational Program has had active stakeholder involvement; the States
and other partners have written major portions of the LaMP and have played a leadership role
throughout the process.  The Public Forum developed the load reduction schedules for the Lake.
Second, the EPA Lake Superior Team had dedicated technical and administrative support
resources, including a full time LaMP author position, funded by the Water Division.

An important part of our strategy for accelerating the Lake Michigan and Lake Erie LaMPs will
therefore be to obtain State commitment to write documents and to expedite the review and
approval process.  We will utilize the development of the next Great Lakes Strategy, the
Continuous Planning Process under  the Clean Water Act, and negotiation of State grants for
Great Lakes CEM (Coastal Environmental Management) funds to achieve this goal.  We will
also better utilize  State Water Director meetings as a means of integrating LaMP and Remedial
Action Plan (RAP) work with base program requirements under the Clean Water Action Plan.

We will also allocate Regional resources to meet the accelerated schedules. Both GLNPO and
Water traditionally provide substantial support to the LaMPs.
    The GLNPO  has focused on basin-wide issues, particularly in science support for the
    open lakes and in working with  Canada. GLNPO also has provided specific support to
    the LaMPs and RAPs, including: the Lake Michigan Mass Balance Study, assisting with
    the critical pollutant portion of the Lake Michigan LaMP; funding a habitat coordinator in
    Minnesota (4 years), Michigan (2 years) and Wisconsin (2 years) to assist with the habitat
    portions of the Lake Superior LaMP; writing the original background paper on habitat for
    the Lake Erie LaMP; identification (with Superfund staff) of important biodiversity
    investment areas to be incorporated into the Lake Michigan LaMP; providing

                                         1
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    atmospheric deposition information (already incorporated into the Lake Ontario LaMP);
    assisting RAP implementation via sediment assessment (sites in 24 AOCs) and
    remediation (sites in 3 AOCs); and development of an ecosystem indicator framework
    which can be used by the LaMPs. Most of this work will continue. To further LaMP
    acceleration, GLNPO proposes additional assistance with indicator development, with
    connections on Binational Toxics Strategy (BNS) long-range transfer work, and with the
    ecosystem component of the LaMPs.

    Prior to the 1995 Region 5 reorganization, the Water Division had the lead for developing
    LaMPs and RAPs per an agreement between the GLNPO and Water Division Directors.
    In Fiscal Year (FY) 1999, the Region 5 Water Division received 7.3 FTE and about $3.49
    million from the Office of Water to support its efforts for Lakes Superior, Michigan, and
    Erie and the 24 Areas of Concern (AOCs) in Region 5.  However, the resource needs far
    exceed the FTE allocated.  In addition to FTE for the Regional Team Manager positions
    and above mentioned dedicated Lake Superior Team members, the Division has posted
    LaMP author positions for Lake Michigan and Lake Erie; has funded a full time Detroit
    RAP manager located in Michigan and a full time outreach position for Lake Superior,
    located in Duluth; has provided two positions for grants management;  three positions for
    community outreach; three FTE  for RAPs; and two FTE for GIS work and monitoring
    support.  The Water Division also has generally awarded approximately half of its Great
    Lakes Coastal Environmental Management funding for State FTE in support of RAPs and
    LaMPs.  For FY98-99 the Division redirected funds from base program activities,
    especially NPDES, to support LaMPs and RAPs.  However,  resource accounting under
    GPRA, and concerns by the Assistant Administrator for Office of Water on base program
    priorities, will not allow the Water Division to continue this level of reprogramming.

It is important to note that the Great Lakes and Regional Teams  are multi-media, cross-cutting
Regional priorities. Dedicated resources, particularly Team members who spend a significant
amount of time and effort on the LaMPs, have helped progress for the Lakes where the LaMPs
are most advanced. To accelerate LaMP progress, all applicable Divisions and Offices, not just
the Great Lakes National Program Office (GLNPO) and the Water Division, must stand ready to
support the Regional Teams. This support does not mean moving resources to the Lake Teams
or asking for additional taps, but will require a short-term focusing of existing program staff with
needed expertise or experience  which aligns with both the program and the LaMP need. For
example,  staff with expertise in sources and loadings or habitat will be needed to assist the
Regional Teams with the accelerated schedules. A commitment by the Resources Management
Division to the timely processing of the LaMP author positions will be needed.

A number of discussions and activities have taken place that will result in issuance of LaMP
documents describing what is known about the extent of the problem and load reductions and
remedial measures that are needed:
    A Region 5 LaMP Workgroup was established to look at this and other issues in response
    to the direction of Region 5 and  State Water Directors at their February 1999 meeting.
                                         42

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-   In the April 1999 Region 5/State Environmental Directors meeting, a challenge was
    issued for the LaMP technical work groups and management committees to complete
    Stages 1-3 of the LaMPs by April 21, 2000 (Earth Day).
    Workgroups responsible for producing the LaMPs have responded to the challenge. The
    LaMPs will be accelerated by 1 year (Lake  Superior) to 2 years (Lakes Erie and
    Michigan).  Approval of this acceleration is still required by the LaMP Management
    Committees and, for the Binational LaMPs, Canada.
    LaMP acceleration was discussed during the June 1999 Region 5 Lake  Summit. Region
    5's Senior Leadership generally agreed to acceleration of the planning stage of the LaMPs
    and the development of schedules for those parts of the LaMPs that could not be
    completed by April 2000.
    There was general agreement to the proposed schedules during a July 7 call between the
    National Program Manager and representatives of the States.
    Binational discussions regarding LaMPs will occur at the July Binational Executive
    Committee meeting.  We will work closely with our Canadian counterparts to secure their
    agreement to accelerated LaMP schedules.

The proposed schedules for Lakes Michigan and Erie are:

    Lake Michigan
    April 2000 Deliverables
    !      Lake Michigan LaMP Stages 1-3 merger that includes:
    !      Vision, goals and sub-goals of the LaMP
    !      Status of the ecosystem described in detail, including impairments and human health
          implications
          Environmental indicators based on the State of the Lakes Conference template
          Chemical, physical and biological causes and sources of impairments and stressors as
          we know them to date (loadings)
    !      An initial set of remedial action to achieve initial percentage reduction targets in
          order to meet LaMP goals

    After April 2000
          Finalize TMDL/LaMP Framework (June 2000)
          State-by-State and Sector meetings to incorporate LMMB model results into LaMP
          (Summer 2000)
          Finalize Lake Michigan Coordinated Monitoring and Reporting Plan (Fall 2000,
          following SOLEC session)
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Lake Erie
April 2000 Deliverables
 !   Recommendations for new actions on PCBs and mercury
 !   Recommendations for habitat projects
 !   Use impairment conclusions:
    "     Four additional assessments completed
    "     Five presented in draft form
    Draft ecosystem objectives
    Status report on pollutant source identification work for 30 pollutants of concern

After April 2000
Stage 1
 !   Draft Stage 1 Report Completed (July 2000)
 !   Final Stage 1 Report Completed (September 2000)
Stage 2
 !   Draft combined Stage 2/3  Report completed (April 2001)
 !   Final combined Stage 2/3 Report completed (September 2001)
Stage 3
 !   Draft supplemental Stage 3 Report completed (September 2001)
 !   Final supplemental Stage 3 Report completed (December 2001)

Action Plan/Milestones.  Milestones for each Lake will differ; however, the milestones could be
grouped as follows:
    Establishment of Detailed, Accelerated LaMP Schedules through
    LaMP Management Committees                                        Summer 1999
    U.S. Policy Committee Meeting to Ensure Progress on Meeting
    Schedule Deadlines                                                November 1999
    U.S. Policy Committee Meeting to Ensure Progress on Meeting
    Schedule Deadlines                                                    Spring 2000
    LaMP documents (critical pollutant portions, but see schedules above)         April 2000
    Finalized/Completed LaMP documents                          December 2000 - 2001

Recommendation 2.2. We recommend that by September 2000 the Regional
Administrator, Region 5, work with other appropriate Federal, state and Canadian
government organizations to decide what action to take on the Lake Huron LaMP, and
when activities will begin.	

We concur with the recommendation and have started a Lake Huron Initiative under a
cooperative agreement with the Great Lakes Office of the Michigan Department of
Environmental Quality (MDEQ). Like the existing LaMPs, the purpose of the Lake Huron effort
(derived from the Great Lakes Water Quality Agreement) is to restore and maintain the chemical,
physical, and biological integrity  of the the Lake Huron Ecosystem. The effort will focus on
                                         44

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identification of data needs, identification of actions (on-going and future), funding resources,
and stakeholder and public involvement.

Much progress has already been made toward development of a management plan for the Lake
Huron watershed. Following up on recommendations from the 1996 State of the Lakes
Ecosystem Conference, GLNPO supported, via an assistance agreement, MDEQ's Great Lakes
Office in putting together a June 1998 Lake  Huron Conference and a January 1999 Lake Huron
workshop. The Lake Huron Conference brought together bi-national governmental
representatives and the public to initiate efforts to identify priority issues and future efforts
needed to ensure a sustainable Lake Huron Watershed.  Participants attended the Lake Huron
Workshop from both Michigan and Ontario, including representatives of Federal, State, and
Provincial governments and the public.  Workshop participants developed an action agenda for
addressing Lake Huron and to help identify priority issues and necessary future efforts. In May
1999, MDEQ developed a draft "Lake Huron Initiative" report.

Pending Binational approval, by April 2000, the Lake Huron Initiative report will assess
beneficial use impairments and  critical pollutants, address habitat/biodiversity issues, identify
potential cooperative monitoring proposals,  and include any products (such as fish-related
environmental objectives) developed in conjunction with the Lake Huron Technical Committee
of the Great Lakes Fishery Commission. An action plan will also be prepared to identify key
actions and priorities for Lake Huron regarding beneficial use impairments/critical pollutants and
habitat/biodiversity.  Plans for after April 2000 include implementing key actions identified in
the April 2000 action plan, strengthening binational cooperation and participation,  additional
work strengthening elements of critical pollutants and ecosystem management activities, and a
Lake Huron Symposium in 2001.

The Lake Huron Initiative is not currently a Lakewide Management Plan, although it has many
of the elements and attributes of a LaMP.  Management has been discussing the LaMP process
with the States, and the State of Michigan would like to use the Lake Huron Initiative  to serve as
a reinvention approach to lakewide management planning. Lake Huron will be an ideal place to
initiate this because only Michigan, Environment Canada, and the Province of Ontario would be
involved in such an effort, so the complexities of a multi- State perspective and participation
should be able to be  substantially streamlined. Therefore, we believe the approach to Lake
Huron can be streamlined and completed in  a substantially faster time frame than some of the
other lakewide efforts.  The Lake Huron initiative will serve as an excellent base for future
efforts and will be carefully managed so in the future, it can serve as the LaMP. It is worthwhile
to note that the Lake Ontario LaMP began as a Toxic Management Plan and was successfully
reformulated into a LaMP.

Discussions with our Canadian  counterparts on Lake Huron have not produced an agreement to
begin a LaMP. Environment Canada has  informed us that they will not be able to take up the
issue of a LaMP for Lake Huron until the year 2000, as they do not have additional resources to
apply to this effort.  To meet the intent of the Great Lakes Water Quality Agreement (GL WQA)

                                           5
                                          45

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and to be lakewide in nature, a LaMP must be binational in its approach.

These are issues that will continue to be addressed as the Lake Huron effort progresses.  In the
year 2000 time frame, the Agency will initiate discussions with both Environment Canada, as
well as MDEQ regarding the progress and future of the initiative. Currently, a management
representative from the GLNPO sits on the Lake Huron Executive Steering Committee and is
actively participating in this process. A GLNPO staff member is currently the project officer for
the Cooperative Agreement and is also participating and providing technical support and
coordination to the initiative.

Action Plan/Milestones.
    Draft Lake Huron Initiative                                                June 1999
    Initiative Meeting in Rogers City, MI                                        June 1999
    Initiative Meeting/Public Meeting                                January/February 2000
    Initiative Document/Action Plan Final                                     April 2000
    Lake Huron Symposium                                                   early 2001

Recommendation 2.3. We recommend that the Regional Administrator, Region 5 work
with Canada, other Federal agencies, and states to identify, and implement, ways to make
the LaMP process more efficient.

We agree with this recommendation and have begun to implement it.

The Lakewide Management Committees for Lakes Michigan, Erie and Superior have met and
discussed the proposed acceleration and are excited about this opportunity. Deadlines and
specific schedules often energize groups, and the enthusiasm of each group of partners is
apparent. The LaMP Technical Workgroups are taking ownership of schedules and are prepared
to work together to meet the challenge. As discussed in the response to Recommendations 2.1
and 2.2, LaMP development is now being made more efficient through streamlining and
acceleration. A workgroup has developed a number of key recommendations that will be
implemented.  Through the steps being taken to accelerate the LaMPs, by April 2000,
documentation should be available for each of the Great Lakes which describes, at least for
critical pollutants, what is known about the extent of the problem and load reductions and
remedial measures that are needed.  These  documents, even if they are not technically
"completed" LaMPs  will sufficiently lay out the information available to all parties at the time
they are issued.  Where there is incomplete information, a plan will be included for obtaining the
information. This process will be used for the existing LaMPs. The process will be focused on
implementation and gaining the on-the-ground improvements needed to protect and restore the
Lake ecosystem.

EPA will use the process for development of the Great Lakes Strategy to identify, and implement
ways to make the LaMP process more efficient. Improving LaMP efficiency will also be a part
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of Great Lakes Strategy implementation.

The Binational Executive Committee will also discuss how to improve the LaMP process at their
July meeting. This will help develop support from our Canadian counterparts.

Action Plan/Milestones. See Recommendations 2.1 and 2.2.
Recommendation 2.4. We recommend that the Regional Administrator, Region 5 establish
a RAP coordinator in Region 5.	

Establishing a RAP coordinator in Region 5 is not the answer to the issues raised in the Inspector
General's Report.  We do appreciate the need to focus more attention on the RAP process and
bring it to closure. We do not see "coordination" as being the real issue.  Historically, the States
have had the lead for RAPs with Region 5 playing a minor role. For several years the Water
Division had a full time RAP coordinator, but the position was eliminated because it was not
needed.  Issues will need to be addressed State-by-State for each RAP.  If there is a role for an
EPA RAP liaison to play, we would seek to have a RAP liaison appointed. There may not be a
need for an EPA RAP liaison for each RAP.
We believe that the best strategy for
accelerating the RAPs is to issue a
"challenge" to the States such as they issued
to us for the LaMPs. Roughly half of the
RAPs are in the implementation phase (see
Figure 2.5); for the remaining RAPs, we need
to agree on roles, establish aggressive
schedules and milestones,  and allocate funds
accordingly.  EPA's role will differ from
RAP to RAP. For example, during FY98
Region 5 led efforts to develop a Four Party
Letter of Commitment for the three
binational RAPs: the Detroit, St. Mary and
St. Clair Rivers. A full time position was
established by the Water Division for the
Detroit RAP and is housed in the Detroit
area. In other instances, the RAP has an
active Public Advisory Committee, full State involvement, and EPA's participation is not needed.

Where an active EPA role is required, the Water Division and GLNPO cannot provide all of the
resource support. All Divisions, Offices, and Regional Teams will be asked to provide some
expertise and leadership where the RAP objectives align with program objectives. This is
already occurring in many instances, such as the Superfund program's involvement in AOCs.
F
T
igure 2.5.
he 22 Region 5 RAP liaisons come from:
Office
ARD
GLNPO
OSEA
RMD
Superfund
Water
Stage 1


1
3
4
4
Stage 2
1
2


3
3
Total
1
2
1
3
7
7


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The extramural dollars received by the Region 5 Water Division for LaMP and RAP support
have already been significantly reduced, with a cut of close to $1 million in FY99 an additional
cut of close to $1 million expected for FY2000.  Further, the Region 5 RAP/LaMP funding of
$3.6 million contained in the President's budget for FY 2000 may be cut even more during
budget negotiations. The first priority for use of these funds will be completion of the LaMPs.
The remaining limited funds should be strategically allocated for those RAPs that need the most
work and/or EPA support. In general, we will not continue funding State RAP positions where a
Stage 2 RAP has been developed.  The CEM grant process will be the vehicle to make these
decisions. However, additional support, particularly for implementation, is needed from other
places, including Water, GLNPO (even though the President's budget identifies a cut of $1.2
million to its budget), Superfund, and other programs.

We believe that the best forum for RAP coordination is the Regional Team for each Lake.  RAPs
are viewed in the GLWQA as "point sources" to the Lakes and we need to ensure that actions to
address contaminated sediments in particular are consistent with  Stage 3 LaMPs. The Region  5
Lake Team Managers will be given a renewed charge to serve as  the umbrella for the RAPs in
their Lake, and to coordinate the planning and funding process. Toward this end, the Lake Team
Managers and the Regional Team Managers for the respective geographic teams  (NW Indiana,
SE Michigan and NE Ohio) will coordinate more closely together.

Also, and in keeping with Section 118 of the Clean Water Act, the Region 5 Water Division, in
consultation with GLNPO and other program offices involved in RAP actions, will, as
workplans/Environmental Performance Partnership Agreements are revised or renewed,
negotiate specific commitments with States for water quality management plan updates, and will
review the updates to ensure they define appropriate RAP actions.  This is in keeping with
Section 118 which assigns primary responsibility for completing the U.S. RAPs to the States and
anticipates that RAPs will be included in the States' water quality management plans.

Finally, we note the resource constraints, issues of roles and responsibilities, and  other problems
that are inherent in addressing RAP issues may require additional work before they are resolved.
Some of these issues will be addressed during the process of developing a new Great Lakes
Strategy.

Action Plan/Milestones.
    Initiate RAP "Challenge" with States/stakeholders                            July 1999
    Discussions with States on lead roles/accelerated schedules and
    CEM grant dollars                                                  July/August 1999
    Renewed charge to RTMs                                               August 1999
    RAP "challenge" discussion at US Policy Committee Meeting
    and agreement on how to implement                                   November 1999
    Progress report at BEC Meeting                                        December 1999
(See also the Recommendation 4.1 response with respect to the Great Lakes Strategy schedule.)
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Recommendation 2.5. We recommend that the Regional Administrator, Region 5 clarify
and communicate the priority and responsibility of LaMPs and RAPs in Region 5.

We agree with this recommendation and will explore means to implement it.  Special Great
Lakes activities outside of typical media priorities often receive less attention within Region 5
programs than do headquarters-driven requirements.  Accelerated progress in Region 5 on
LaMPs and RAPS will require special attention by the Regional Administrator in his role as
Great Lakes National Program Manager. The Region 5 Deputy Regional Administrator also has
a crucial role in establishing the roles for Regional programs in accomplishing the priorities for
LaMPs and RAPS.

One vehicle for heightening participation of Region 5 programs will be their participation in the
development and implementation of the next Great Lakes Strategy. While not signatories to the
Strategy itself, EPA programs will be vital participants in its development. Objectives for the
programs can be articulated in supplemental annual plans, or  agreements, which will implement
the Strategy.

There are also a number of important points (see Action Plan/Milestones below) in the Region 5
Planning Process where LaMPs and RAPS can be highlighted to management and staff. The
GLNPO Director and Water Division Director, as Goal Leads, will ensure that LaMPs and RAPS
are emphasized at these times to all of the Region 5 Senior Leadership Team.

Actions speak louder than words, and one of the best ways to  send a message that the LaMPs and
RAPs are a high Regional priority is to align systems to support them. Planning, budgeting,
accountability and awards systems should all support completion of LaMPs and RAPs.

Action Plan/Milestones.
-   Lake Summit                                                        June 25  1999
    Summary of Agreements from Lake Summit                                 July  1999
    Region 5 Lake Team  Resource Requests conveyed                            July  1999
    Resource Decisions by USEPA Region 5                               September  1999
-   Regional Results Plan                                                 October  1999
    Mid-year Goal Reporting                                               March 2000
    Lake Summit                                                          April 2000
(See also the Recommendation 4.1 response with respect to the Great Lakes Strategy schedule.)
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Recommendation 2.6. We recommend that the Regional Administrator, Region 5 define
and communicate the role of GLNPO in LaMPs and RAPS.

We agree with this recommendation and will explore means to implement it. It is important that
the role of all EPA programs in LaMPs and RAPS be better defined and communicated.

The LaMPs and RAPs are multi-media efforts and will require full Regional support to succeed.
This is especially true for the implementation phase, which will require that base programs be
focused on Stage III activities. As described earlier in the response, the lead for LaMPs and
RAPs historically rested with the Water Division as a result of an agreement between the
GLNPO and WD Directors. The GLNPO focused on basin-wide issues, particularly in science
support for the open lakes and in working with Canada.  The Water Division Co-Chaired the
LaMP Management Committees with no GLNPO participation.

The FY95 Regional reorganization recognized the multi-media nature of the Lakes and shifted
the lead for LaMPs/RAPs to Regional Teams. Early in this process each of the Lakes had an
individual SLT sponsor. Later, the Directors of GLNPO and Water Division recognized the
benefits of "joint" sponsorship for all three Lakes. Communication and collaboration between
Water Division and GLNPO has significantly improved, as well as base program support for
LaMPs and RAPs. The Directors meet frequently with the Lake RTMs, and are fully committed
to the accelerated schedules for the LaMPs. The two Directors now Co-Chair the Lake Michigan
Management Committee.  A GLNPO Manager attends the Lake Superior and Lake Erie
Management Committees.  Funding processes are being coordinated to ensure the best use of
both CEM ands GLNPO dollars.

RAP and LaMP roles and responsibilities will also be addressed during the development and
implementation of the Great Lakes Strategy. Regional programs and RAP and LaMP teams will
be key participants in its formulation and implementation.

Action Plan/Milestones
See milestones for development of Great Lakes Strategy (Recommendation 4.1).
Recommendation 3.1. We recommend that the Regional Administrator, Region 5 prepare
an agreement(s) that outlines the roles and responsibilities of GLNPO, ORD, Regions 2, 3,
and 5 in the Great Lakes.

We agree with this recommendation and will implement it as part of the new Great Lakes
Strategy being developed under the leadership of the Great Lakes National Program Manager.
Roles and responsibilities of GLNPO, ORD, and Regions 2, 3, and 5 will be updated and
articulated as a part of the Strategic planning process. In that process, care will be taken to
obtain agreement by those organizations to the descriptions of those roles and responsibilities.

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Even in the absence of a formal agreement among GLNPO, Region 5, and ORD, there has been
significant research coordination among these organizations. Examples include:
    The integration of Great Lakes and Great Waters research activities responsive to Section
    112 (m) of the Clean Air Act Amendments of 1990 pertaining to multimedia loadings.  In
    response, the Administrator's Office, Region 5, GLNPO, and the Offices of Air, Water
    and Research and Development developed and implemented research to enable research-
    grade measurements of persistent, bioaccumulative toxic (PBT) deposition from the
    atmosphere to the Great Lakes; long-term research investigating the potential for local
    and distant sources to contribute atmospheric loadings of PBTs to Lake Michigan and
    Chesapeake Bay; long-term mercury research on measurement methods and species
    availability; and a procedure for integrating scientific knowledge into the Great Waters
    Report to Congress.
    ORD participates on the steering committee for the State of the Lakes Ecosystem
    Conferences.
    GLNPO, Regional, and ORD coordination for the Lake Michigan Mass Balance Study,
    the first-ever intensive monitoring of Lake Michigan air, water, sediments, and biota.
    GLNPO has consistently participated in ORD's Regional Science Council, providing
    annual recommendations to ORD about high priority research needs.
    As a result of a transfer from the Region 5 Administrator's Office, GLNPO has,
    beginning in 1999, begun to participate in the Research Coordination Teams which
    provide annual recommendations to ORD about high priority research needs. This
    participation is bearing fruit this year with the inclusion of Great Lakes indicators in the
    current draft STAR Request for Applications for coastal indicators. In recognition of
    previous work done with ORD, the GLNPO participant in this effort is being given a
    bronze award by ORD in the Agency's August 1999 award ceremony.
    Since 1996, ORD, GLNPO, and  Region 2 have been cooperating and coordinating in
    assessing changes in the biological community of Lake Ontario.
    From 1992-1994, ORD and GLNPO cooperated and coordinated in implementing Great
    Lakes EMAP monitoring.

GLNPO and ORD propose to encourage development of a broader GLNPO/ORD program, using
as a prototype the Lake Michigan Mass Balance collaboration for planning and research  among
the National Health and Environmental Effects Research Laboratory, the National Exposure
Research Laboratory and GLNPO. It is important to note, however, that increased research
coordination will require increased staff resources. Participation in activities, such as strategic
planning, Congressional reporting, or the formulation of risk management options requires an
organizational structure providing for senior scientists to accomplish these objectives. Neither
GLNPO, nor ORD, nor the Regions are currently  slated for staffing increases which would allow
for increased coordination.

Action Plan/Milestones.
See Action Plan/Milestone for Recommendation 4.1.

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Recommendation 4.1. We recommend that the Regional Administrator, Region 5 ensure
the Great Lakes strategy has input from all (former and new) parties during its
development.

We agree with the recommendation and have begun to implement it.

During early 1999, GLNPO, under the leadership of the Great Lakes National Program Manager,
led a number of discussions with a variety of key parties regarding Great Lakes Strategy renewal:
    During the October Great Lakes Planning Meeting, GLNPO's management discussed the
    Strategy with representatives of State and Tribal natural resource agencies and
    environmental agencies, other EPA offices, including Regions 2 and 3 and ORD, and
    with other Federal agencies.
    At the November Midwest National Resource Managers Environmental Roundtable, a
    Great Lakes group comprised of representatives from USEPA and other Federal agencies
    met and discussed the renewal of the Strategy.  The group generally supported renewal of
    the Strategy.
    In the Spring of 1999, we discussed our plans to renew the strategy with the Regional
    Tribal Operations Committee. Participants, including the Tribal Co-Chair, strongly
    supported a new Strategy.
    A series of meetings were held in December, February, March, and April to discuss a
    number of Great Lakes strategic issues with the State environmental directors and State
    water directors. The State environmental directors and water directors clearly supported
    renewal of the Great Lakes Strategy.
    Regional Team Mangers and other key Region 5 managers have participated in a number
    of the above-mentioned meetings and will fully be a part of the effort. In addition,
    Region 2 and Region 3 were invited to the Great Lakes portion of the State directors's
    meetings (December and April) and participated in the December meeting via conference
    call.  This coordination and communication will continue throughout the process.

Discussions thus far have been preliminary. Many additional important Great Lakes
stakeholders, including the Federal Research Community and interested Great Lakes Tribes, will
be brought into the process once we enter the development phase.

Action Plan/Milestones for Development of Great Lakes Strategy.
    Hold initial consultations on scope and nature of strategy                      Completed
    Develop draft plan for strategy process                                     Completed
    Request participation from lead Agencies                                   August'99
    Hold initial conference call                                             September '99
-   Hold first kick-off meeting                                               October'99
-   Brief US Policy Committee                                             November'99
    Draft Strategy                                                 December/January '99
-   Public Consultation                                                   February 2000
    Final Issues Resolved/Final Document Issued                                April 2000

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Recommendation 4.2. We recommend that the Regional Administrator, Region 5 get
agreement from all parties to implement the strategy.

We agree with this recommendation and will develop methods to obtain the support and
agreement of key partners to the strategy.

We plan on doing this by closer communication with key management officials during the crucial
consensus building phase of the process, as well as devising an improved formal mechanism to
gain support for the strategy. We plan on discussing this more fully as we enter the strategy
development period.

Action Plan/Milestones.
See Action Plan/Milestone for Recommendation 4.1.
Recommendation 4.3. We recommend that the Regional Administrator, Region 5 focus the
strategy on overall goals, as opposed to activities.

We agree with this recommendation and will explore ways of implementing it.

We plan on continuing to focus our Great Lakes goals on protecting and restoring the chemical,
physical, and biological integrity of the Great Lakes basin ecosystem, the removal of beneficial
use impairments, and the virtual elimination of persistent toxic substances.

We have also received comments, though, that encourage greater specificity in the Strategy. The
Strategy must clearly articulate what will actually be carried out. It needs to be specific enough
for a wide variety of Agencies and managers, as well as the public, to understand what is
intended to be accomplished.

During the development of the Strategy, we will attempt to address both of these somewhat
contradictory objectives.

Action Plan/Milestones.
See Action Plan/Milestone for Recommendation 4.1.
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Recommendation 4.4.  We recommend that the Regional Administrator, Region 5 include
performance measures and report progress against the measures.

We agree with this recommendation and will explore ways of implementing it.

There are a number of ways this could be done.  The Government Performance and Results Act
calls for just such accountability and is applicable to the proposed parties to the Great Lakes
Strategy.  Many of the State and Federal environmental programs develop and implement
Environmental Performance Partnership Agreements which already include performance
measures and progress reports. Some even have sections devoted to the Great Lakes. During the
development of the Strategy, we will explore these, and other, possibilities for measurement and
progress reports with respect to the Strategy, including subsequent development of an
implementation plan, annual meetings and/or conference calls, agreed delineation of Great Lakes
activities in work plans, etc.

Action Plan/Milestones.
See Action Plan/Milestone for Recommendation 4.1
Recommendation 4.5.  We recommend that the Regional Administrator, Region 5 designate
GLNPO as responsible for working with the parties to the new strategy to ensure it is
implemented.

We agree with the recommendation and are already implementing it. GLNPO has been
designated as the lead, and has taken the lead, in developing a plan and approach for the new
Strategy.  GLNPO will be working over the next year to ensure its completion and
implementation.

Action Plan/Milestones.
See Action Plan/Milestone for Recommendation 4.1.
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                                   DISTRIBUTION

Headquarters

       Assistant Administrator for Research and Development (8101R)
       Assistant Administrator for Water (6101)
       Assistant Administrator for International Activities (RRB 31207)
       Associate Administrator for Congressional and Intergovernmental Relations (1101)
       Associate Administrator for Communications, Education, and Public Affairs (1701)
       Agency Follow-up Official (3101)
        Attn: Assistant Administrator for Administration and Resource Management
       Agency Follow-up Coordinator (3304), Attn: Director, Resource Management Division
       Audit Follow-up Coordinator, Office of Research and Development (8102R)
       Headquarters Library (3404)
Region 5
       Regional Administrator (R-19J)
       Senior Leadership Team
       Audit Follow-up Coordinator (MFA-10J)
       Public Affairs (P-19J)
       Intergovernmental Relations Officer (R-19J)
Region 2
       Regional Administrator
       Audit Follow-up Coordinator

Region 3

       Regional Administrator (3RAOO)
       Audit Follow-up Coordinator (3PM70)

Office of Inspector General

       Inspector General (2410)
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