UNITED STATES RESPONSE TO RECOMMENDATIONS IN
     THE INTERNATIONAL JOINT COMMISSION'S
            TWELFTH BIENNIAL REPORT
         ON GREAT LAKES WATER QUALITY
                 U.S. Department of State
                        and
             U.S. Environmental Protection Agency
             Great Lakes National Program Office
                    Chicago, Illinois

                     October 2005

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INTRODUCTION

The United States (or U.S.) compliments the International Joint Commission (the
Commission or "IJC") on the release of its Twelfth Biennial Report on Great Lakes
Water Quality. It contains thoughtful recommendations for actions by the U.S. and
Canada (the Parties).

The Parties have made significant efforts to address adverse environmental impacts
and to mitigate or reverse the subsequent effects.  The Parties take pride in their
cooperative efforts in working toward proactive solutions to avoid new impacts and to
protect the Great Lakes Ecosystem from degradation. The  U.S. wishes to assure the
Commission of our firm commitment to continue these efforts.

Since the issuance of the IJC's last Biennial Report, many significant activities have
taken place which have accelerated activities in the U.S. Great Lakes Program, the
most significant of which is President Bush's Executive Order creating  the Great Lakes
Regional Collaboration. The Great Lakes Regional Collaboration will lead to the setting
of strategic priorities for the Great Lakes Ecosystem and shows the Administration's
continuing commitment to these national and international treasures.  It harnesses the
energy of all levels of government and the private sector and insures that the strategies
are efficient and effective, and widely endorsed.  Many of these strategies will directly
address recommendations in the Twelfth Biennial Report. The Regional Collaboration
builds upon the U.S. Policy Committee's Great Lakes Strategy, another important
example of U.S. agencies collaborating to address, make, and track progress on the
shared Great Lakes  restoration priorities.  It is important to note that the Great Lakes
Regional Collaboration continues to benefit from the involvement of Canadian Federal
and Provincial observers and the IJC.

Another significant activity which has recently begun is the review of the Great Lakes
Water Quality Agreement (the  Agreement) which is required upon the release of every
third IJC Biennial Report.  The U.S. remains committed to the Great Lakes Water
Quality Agreement and the binational partnership with Canada that has developed since
its signing.  We believe that the Great Lakes Regional Collaboration will allow the U.S.
to better implement the programs needed to achieve the binational goals of the
Agreement.  With our Canadian colleagues, the U.S. is committed to an open,
transparent and inclusive review process that encourages the involvement of all
interested  Great Lakes stakeholders.

Other significant activities of note which have taken place during the last two years
include:

      authorizing the Great Lakes Legacy Act for addressing contaminated sediments
      in the Great Lakes Areas of Concern and the initiation of the first three projects
      funded by this program: Black Lagoon in the Detroit  River, Michigan AOC, Hog
      Island Inlet in the St. Louis River, Minnesota/Wisconsin AOC, and Ruddiman
      Creek in the Muskegon, Michigan AOC;

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      a renewal of the Remedial Action Plan Program under the management of the
      U.S. Environmental Protection Agency's (EPA) Great Lakes National Program
      Office (GLNPO);
      in 2004, the issuance of the Lake Huron Binational Partnership Action Plan and
      the Lakewide Management Plans (LaMPs) for Lakes Superior, Michigan, Erie
      and Superior;
      holding the State of the Lakes Ecosystem Conference (SOLEC) and issuing the
      associated State of the Lakes Report;
      the recognition of the Presque Isle Bay, Pennsylvania AOC as being in Recovery
      Stage; and
      progress by the U.S. Fish and Wildlife Service's (USFWS) Natural Resources
      Damage Assessment program towards restoring and protecting Great Lakes
      AOCs, including: Fox River/Green Bay, Wisconsin; Grand Calumet River,
      Indiana; Kalamazoo River, Michigan; Saginaw River and Bay, Michigan; and
      Ashtabula River and Harbor, Ohio.

While we can be proud of the many successes during the last biennium, we recognize
that there are a variety of continuing environmental issues in the Great Lakes
ecosystem. These include toxic contaminants, the protection and restoration of
important habitats; enhancing biodiversity; controlling the impacts of existing invasive
species, while limiting future introductions; and promoting sustainable patterns of
development. It is important to note that this response, while highlighting a small
selection of representative activities, reflects a wide universe of programs being
undertaken by the large number of U.S. Great Lakes partners to address these and
other issues. These partners include Federal, State, Tribal and local government
agencies as well as public,  private and non-profit businesses and organizations.

On behalf of the entire U.S. Great Lakes community, the U.S. Department of State and
EPA are pleased to present this Nation's response to the Commission's Twelfth Biennial
Report on Great Lakes Water Quality.

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CHAPTER 1: PHYSICAL INTEGRITY

This chapter concentrates on the impact of urban areas and climate change on Great
Lakes water quality and makes specific recommendations to the Governments:

RECOMMENDA TIONS

The Parties take binational actions to address the impact of urban land use on
Great Lakes water quality by:

•     evaluating under what circumstances best management practices are
      effective in managing urban runoff;
•     ensuring that information on urban best management practices reaches
      local authorities and implementers; and
•     assessing the cumulative effects of management actions to minimize the
      impacts of urbanization on the Great Lakes, using the Lake Erie basin as an
      example.

RESPONSE

Both the U.S. and Canada recognize the importance of addressing the impact of urban
land use on Great Lakes water quality.  Early on, this recognition led to the 1972
binational landmark Pollution from Land Use Activities Reference Group (PLUARG)
study that represented the first truly comprehensive effort to address the connection
between land use and water quality. PLUARG's reports were among the first to
acknowledge the  need to move beyond point sources of pollution,  and to consider
nonpoint sources. The subsequent implementation of a variety of  domestic programs
have led to significant reductions in urban nonpoint source pollution in the U.S. since
the study's conclusion.

More recently, the binational State of the Lakes Ecosystem Conference (SOLEC)
Indicators Development Process has proposed a number of indicators that will help
determine the impacts of urban land use of Great Lakes water quality. These include
indicators on Urban Density, Land Cover-Land Conversion, Brownfield Redevelopment,
and Ground Surface Hardening.  The tracking of these indicators will help guide
binational efforts to assess and improve upon any detrimental impacts on water quality.

Domestically, EPA identified urban runoff as one of the leading sources of water quality
impairment  in surface waters.  Of the eleven pollution source categories listed in the
report, urban runoff/storm sewers was ranked as the sixth leading  source of impairment
in rivers, fourth in lakes, and second in estuaries. State and local elected officials and
agencies, landowners, developers, environmental and conservation groups, and others
play a crucial role in protecting, maintaining, and restoring water resources. Their
efforts, in aggregate,  form the  basis for addressing the nationwide challenge  of urban
runoff.

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Currently, EPA is hoping to finalize in 2005 guidance entitled National Management
Measures to Control Nonpoint Source Pollution from Urban Areas. This document will
inform States, territories, authorized Tribes, and the public regarding management
measures that may be used to reduce nonpoint source pollution from urban activities.
Much of the information below is taken from this draft report.

Four major runoff management themes dominate the management practices presented
in this guidance document:

1.     Minimizing the amount of impervious land coverage and disconnect impervious
      areas.
2.     Promoting infiltration.
3.     Preventing polluted runoff by not allowing pollutants and runoff to mix.
4.     Removing pollutants from runoff before allowing it to flow into natural receiving
      waterbodies.

The proposed management practices can be grouped into two basic categories:

      Nonstructural practices which prevent  or reduce urban runoff problems in
      receiving waters by reducing potential  pollutants or managing runoff at the
      source.  These practices can take the  form of regulatory controls (e.g., codes,
      ordinances, regulations, standards, or rules) or voluntary pollution prevention
      practices. Nonstructural controls can be further subdivided into land use
      practices and source control practices.

      Structural practices which are engineered to manage or alter the flow, velocity,
      duration, and other characteristics of runoff by physical means.  In doing so they
      can control storm water volume, and peak discharge rates and, in some cases,
      improve water quality.  They can also have ancillary benefits such as reducing
      downstream erosion, providing flood control, and promoting ground  water
      recharge.

Watershed Approach

Since 1991, EPA has promoted the watershed approach as the key framework for
dealing with problems caused by urban  runoff and other sources that impair surface
waters.  Five principles guide the watershed approach:

      Place-based focus: Activities are directed within specific geographic areas
      known as management units. When surface runoff is  the primary issue, these
      management units are defined by watershed boundaries.  Other types of
      boundaries can also be used to define management units in special
      circumstances. If ground water is an issue, for example, ground water recharge
      areas might be a logical designation.

      Stakeholder involvement and partnerships: The people most affected by
      management decisions are involved throughout the process. Stakeholder
      participation helps to ensure that local quality of life, economic stability, and other

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      important community issues are incorporated into planning and implementation
      activities.  Partnerships among  public agencies and private groups at all levels
      are also crucial for long-term success.

      Environmental goals and objectives: The success of watershed initiatives is
      measured by improvements of the water resource rather than by programmatic
      objectives.  For example, reestablishing the pool and riffle structure in a stream
      channel to increase aquatic insect and fish populations might be an objective.
      Local goals and objectives need to be consistent with all applicable State, Tribal,
      and Federal statutes and regulations, including water quality standards.

      Problem identification and prioritization: Sound scientific data and methods
      are used to identify and prioritize threats to human and ecosystem health. This
      process usually begins with the assessment and characterization of current
      natural resource and community conditions within the management unit(s).
      Problems, including their causes and sources, are also documented.
      Stakeholders and partners then work jointly to set priorities among the various
      water resource concerns, taking into account priorities already established at
      scales above and below the management unit.

      Integration of actions: Stakeholders and partners take actions in  a
      comprehensive and integrated manner. Results are then evaluated and actions
      are adjusted as needed.

A key attribute of the watershed approach is that it can be applied with equal success to
large and small scale watersheds. Although specific objectives, priorities,  actions,
timing, and resources might vary from  large scale to small scale, the basic goals of the
watershed approach remain the same - protecting, maintaining, and restoring water
resources.

Management Practices

The U.S. Government has instituted a  number of tools for addressing urban nonpoint
source pollution and for addressing the four major runoff management themes listed
above.

During the first 15 years of EPA's national program to abate and control water pollution
(1972-1987), EPA and State partners  focused most of the water pollution  control
activities on traditional point sources.  These point sources have been regulated by EPA
and the  States through the National Pollutant Discharge Elimination System (NPDES)
permit program established by Section 402 of the Clean Water Act (CWA). The NPDES
program functions as the primary  regulatory tool for assuring that water quality
standards are met. NPDES permits, issued by either EPA or an authorized State, are
developed to include both water quality-based and technology-based effluent limitations.

In 1987, in view of the progress achieved in controlling point sources and the growing
national awareness of the increasingly dominant influence of NPS pollution on water
quality, Congress amended the CWA to focus greater national efforts on nonpoint

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sources.  Under this amended version, referred to as the 1987 Water Quality Act,
Congress revised Section 101, Declaration of Goals and Policy," to add the following
fundamental principle:

      It is the national policy that programs for the control ofnonpoint sources of
      pollution be developed and implemented in an expeditious manner so as
      to enable the goals of this Act to be met through the control of both point
      and non point sources of pollution.

The Water Quality Act of 1987 also included language that required comprehensive
storm water permitting  using a two-phased approach.  Phase I of the storm water
program requires permits for medium and large municipal separate storm sewer
systems in incorporated areas serving over 100,000 population, runoff from industrial
activity, and construction activity that disturbs 5 or more acres of land. Phase II
requires, as of March 2003,  NPDES permits for small municipal separate storm sewer
systems and construction activity that disturbs 1-5 acres.

The CWA also establishes several reporting, funding, and other control programs that
address pollutants carried in runoff that is not subject to confinement or treatment.
These programs that relate to watershed management and urban nonpoint source
control include:

      CWA Section 303(d) for Impaired Waters,

      CWA Section 305(b)  and the  National Water Quality Inventory

      CWA Section 319 Grant Program for Nonpoint Source Management

      Clean Water State Revolving Fund

It is critical to the success of managing urban nonpoint source pollution control
programs that best management practices are identified and snared. Once programs
have been established and management practices implemented, managers can
evaluate the effectiveness of their programs using program and administrative
indicators.  This evaluation involves  reassessing conditions in the watershed to
determine whether the implemented practices effectively reduced nonpoint source
pollution. This reevaluation also identifies areas where additional restoration or
preservation activities are needed, which will guide future watershed initiatives and
thereby restart the management cycle. While this may be difficult to do on a lakewide
basis such as the IJC is recommending for Lake Erie, such sharing does take place
through a number of venues which are illustrated by the following examples.

In 2004, Ohio's Lake Erie Commission began a voluntary, incentive-based program for
balanced growth in the Ohio Lake Erie basin. This plan calls for the creation of a locally
driven planning framework that includes:

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      A new focus on land use and development planning in the major river tributary
      watersheds of Lake Erie. The goal is to begin to link land use planning to the
      health of watersheds and the lake.

      The creation of Watershed Planning Partnerships composed of local
      governments, planning agencies, nonprofit organizations, and other parties in
      each watershed. Participation in these partnerships would be voluntary but
      encouraged by State incentives.

      The locally determined designation of Priority Conservation Areas and Priority
      Development Areas in each watershed.

      The development of suggested model regulations to help promote best local land
      use practices that minimize impacts on water quality.

      The alignment of State policies, incentives, and other resources to support
      watershed planning and implementation for balanced growth.

Another Great Lakes example of ensuring that information on urban best management
practices reached local authorities and implementers is the Lake Michigan Watershed
Academy launched by the Lake Michigan LaMP in 2003. The academy began with a
two and a half day training session aimed at eight regional planning agencies but open
to other stakeholders. In 2004,  the participating planning agencies each held a one day
training session often with partners and co-sponsors. The conferences covered topics
of impacts on Lake Michigan, unique local situations and needed actions. Approximately
1,000 local officials and residents attended.  Follow up is still underway and  includes
hands on workshops for local officials, fact sheets for each Lake Michigan Watershed,
and the formation of a network of Great Lakes regional planning agencies.

Another program that provides a valuable planning tool for managing nonpoint sources
of pollution is the Total Maximum Daily Load (TMDL) Program for Impaired Waters.  A
TMDL is the sum of allocated loads of pollutants set at a level necessary to implement
applicable water quality standards for an  impaired water body, including wasteload
allocations for point sources, and load allocations for nonpoint sources and natural
background conditions.

A 1998 survey of waters requiring a TMDL found that 47 percent are impaired due to a
combination of point and nonpoint sources, 43 percent are impaired due to nonpoint
sources only, and just 10 percent are impaired by point sources only.  This points to the
utility of the TMDL program and its potential impact on reducing urban runoff to the
Great Lakes.

To date, few TMDLs have been established for waters of the Great Lakes.  A few
shoreline E.  call TMDLs (Indiana - Lake Michigan) have been established.  In addition,
some TMDLs have also been established for tributaries to the Great Lakes - (Lake
Macatawa, Michigan; all of the Cuyahoga River in Ohio; Salt Creek/Little Calumet River,
Indiana; the St. Joseph River, Indiana/Michigan; and the Galien River, Michigan).

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Beyond Traditional Water Quality Programs

Recently, there has been an increased focus on coordinating the multitude of Federal
programs with a role in watershed protection and land use.  The aforementioned Great
Lakes Regional Collaboration and the recent Memorandum of Agreement between EPA
and the National Oceanic and Atmospheric Administration (NOAA) to develop a coastal
communities partnership are excellent examples of this increased coordination.  In
addition, there is significant value in the increased coordination between water quality
and land conservation programs administered by the U.S. Department of Agriculture
such as the Conservation Reserve Enhancement Program,  the Wetlands Reserve
Program, and the Environmental Quality Incentive Program. These programs are
making a significant difference in the water quality of the Great Lakes by addressing
both nutrient and sediment loadings.

Another example of Federal-State cooperation to protect coastal waters is the Coastal
Nonpoint Pollution Control Program co-administered by NOAA and EPA pursuant to the
1990 reauthorized amendments to the Coastal Zone Management Act (CZARA).
CZARA requires participating States to design programs to  implement 56 different
management measures across (nearly) all the main categories of NPS  pollution. Urban
development, including impacts from new and existing development,
roads/highways/bridges, and septic systems are covered in these management
measures. All of the Great Lakes  States participate in CZARA except for Illinois which
is currently developing a delegation and pursuing Coastal Zone status.  Indiana and
Ohio are the two newest States to join, so they are just beginning to develop their
coastal nonpoint programs. Wisconsin and Pennsylvania have fully approved
programs, and New York is nearly approved.

The U.S. Army Corps of Engineers (Corps) is working in collaboration with other
Federal agencies,  State and local  land management agencies, and the Great Lakes
Commission to develop computer  models to predict soil erosion and sediment transport
for tributaries to the Great Lakes through the Great Lakes Tributary Model program
authorized by Section 516(e) of the Water  Resources Development Act (WRDA) of
1996, as amended. Modeling tools developed under this program are being used by
local governments to evaluate the impact of land use decisions and to more effectively
plan and implement measures for  soil conservation and nonpoint source pollution
prevention.  Models have been built or are under development for twenty tributaries,
including the Clinton River, where  the model is being used by the counties and the State
of Michigan to manage urban stormwater and bank erosion problems and reduce the
loadings of sediments to Lake St. Clair. A  model was also completed in 2004 for Mill
and Cascade Creeks which drain areas of  Erie County, Pennsylvania to Lake Erie.  This
model is being used by the State of Pennsylvania and the local RAP  group to design a
stream restoration project and support delisting of the Presque Isle Bay AOC.

The Corps is also supporting State, local, Tribal  and non-profit organizations in the
planning, design, and construction of projects to protect and restore aquatic habitat  at
more than fifty locations in the Great Lakes Basin through several authorities, including
the Great Lakes Fishery and Ecosystem Restoration Program, authorized by Section

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506 of WRDA 2000. Many of these projects will preserve and enhance the ability of
wetlands to trap sediments and nonpoint pollutants. An example project under study is
at Red Mill Pond, in LaPorte County, Indiana. The Pond was initially formed in 1833
when a dam was constructed on the Little Calumet River for hydropower to operate a
sawmill.  A significant native wetland community has developed and is dependent on
the earthen dam. The dam has been declared a hazard and has to be removed.  Dam
removal threatens to destroy the wetland, and diminish its capacity to filter nonpoint
pollution. The proposed project would include restoration of the stream morphology at
the dam site, and the restoration and preservation of open marsh, fen, seep and
woodland.

Through  its grant support to the biodiversity partnership called Chicago Wilderness, the
USFWS has helped develop a variety of projects intended to get sustainable
development tools into the hands of local decision-makers and developers.  These
include best practices for urban runoff management as well as habitat protection,
restoration, and management. Chicago Wilderness developed a set of
recommendations for real  estate developers, city planners, and community
decision-makers to promote sustainable development  in the region and also published
the Conservation Design Resource Manual, a guidebook containing model ordinances
to promote local nature, which communities can adopt or adapt for their own use.

In August 2004, EPA released a coordinated Smart Growth Strategy to insure that the
Agency's actions help State and localities revitalize more brownfields and reduce the
impact of development on air and water quality. It focuses on  five target areas:

      1.  Promote infill and redevelopment;

      2.  Catalyze smart growth transportation solutions;

      3.  Partner for innovative development and building regulations;

      4.  Support smart growth initiatives; and

      5.  Ensure EPA policies recognize the environmental benefits of smart growth.

A document entitled Protecting Water Resources with  Smart Growth was developed by
EPA to offer specific ideas on how techniques for smarter growth can be used to protect
water resources, with a focus on urban land use and urban runoff.  It can be accessed
at: www.epa.gov/smartgrowth

In addition,  GLNPO's Habitat Restoration and Protection Program has funded more
than ten projects in urban  areas.  This program tries to balance urban protection and
restoration projects with the protection and restoration needs of wilder, less inhabited
portions of the basin, understanding that urban results will be measured not so much in
terms of acres as in how many people have access, and not so much in terms of quality
of restoration as in preservation of what is left. New tools for dealing with urban
ecological problems were  developed. Ecological restoration and protection activities
were initiated  in Northwest Indiana, Northeast Ohio, and Buffalo, New York.

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EPA Region 5 will continue its collaboration with the Midwest Spatial Decision Support
System Partnership (http://www.epa.gov/waterspace/) to develop, improve, disseminate
and demonstrate spatial decision support system tools. Its experience has shown that
local planners and decision makers need web-based access to scalable, data-based
watershed modeling tools in order to make land use decisions that are protective of
water quality. When provided with those tools and a support network such as the
Partnership, municipal officials are much more willing and able to factor water quality
impacts into their land use decisions.  EPA Region 5's overall goal is to enhance
environmental protection and watershed management by elevating the quality of local
land use discussions and decisions through the use of decision support tools.

Finally, in order to facilitate sharing information on current research findings and
successful best management practices across a broad range of stakeholders, including
in particular local authorities and implementers, EPA is specifically addressing the
impacts of urban land use on storm water runoff (and a range of other environmental
impacts) through a conference,  a charrette (an intensive design effort), and a
quantification effort. This effort  has the potential to be translated and transferred to
urban areas throughout the Great Lakes.  The conference, to be held in Milwaukee,
Wisconsin,  is titled "Green Makeover - Retrofitting Sites in Urban Areas to  Enrich City
Environments," and will emphasize environmental and quality of life considerations as a
part of urban site redevelopment.  By including green retrofit techniques such as rain
gardens and native landscaping, the environmental benefits of redevelopment can be
compounded to provide for long lasting improvement to air and water quality.  Green
retrofit techniques emphasizing the feasibility and benefits of management practices on
the site is especially important in the Great Lakes Basin, where combined storm sewer
overflows are having many negative environmental impacts.

At the conference, groups will plan retrofits of actual case study sites in Milwaukee.
These designs will potentially be implemented in conjunction with a quantification
project to measure the benefits  of green retrofit, with a strong stormwater (both quality
and quantity) component.  The environmental benefits of these green redevelopment
techniques  are often poorly quantified, and this project intends to fill some of these gaps
in knowledge.  Quantification of the environmental benefits and financial costs of green
retrofit techniques are needed in order to justify and promote their widespread use.
CHAPTER 2: BIOLOGICAL INTEGRITY

This chapter addresses the impacts of Alien Invasive Species and Pathogens in the
Great Lakes and makes three sets of recommendations, labeled A, B, and C below:

The governments take the following measures to eliminate the threat and impacts
of aquatic alien invasive species in the Great Lakes:
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RECOMMENDA TION A

Take immediate action to:

•     in the United States, pass the National Aquatic Invasive Species Act
      (NAISA) reauthorizing the National Invasive Species Act (NISA) of 1996;

•     in Canada, implement the National Action Plan to address the threat of
      aquatic alien invasive species; and

•     ratify and implement the International Maritime Organizations Convention
      for the Control and Management of Ships ballast Water and Sediments, and
      pursue stringent measures and rapid timelines.

•     Issue a reference to the International Joint  Commission to:

•     help identify the most effective ways to coordinate binational prevention
      efforts and harmonize national plans, particularly those dealing with
      residual ballast water and sediment in ballast tanks;

•     evaluate the effectiveness of current institutional arrangements;

•     assist with the establishment of a regional  standard stronger than the
      minimum required by the International Maritime Organization Convention;

•     ensure that economic analyses carried out for projects with potential
      environmental effects include the environmental and societal costs of
      invasive species control, damage, and mitigation, and the costs and
      benefits of prevention measures; and

•     assist with public education and communications.
RESPONSE

The IJC's determination that alien invasive species are a critical threat to the health and
viability of the Great Lakes has helped focus government and public attention on this
danger.  The IJC's call to action on the Asian Carp Barrier has helped spur the U.S.
Government and the Great Lakes States to action. The joint IJC/Great Lakes Fishery
Commission letter urging binational action to prevent invasive species raised the profile
of this important issue. It is difficult to overstate the importance of the pending and ever
increasing threats of aquatic nuisance species to the Great Lakes.  Taking an
ecosystem approach for the  prevention and management of this issue should be
considered.
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The U.S. agrees that effective legislative and international measures are important to
addressing invasive species issues.  There were a number of bills introduced in the last
Congress that would amend and reauthorize National Invasive Species Act (NISA),
including the National Aquatic Invasive Species Act (NAISA).  The U.S. agencies will
work to coordinate the U.S. Government's position on such bills if they are reintroduced
in Congress, keeping in mind the Aquatic Nuisance Species Task Force Strategic Plan,
progress thus far on ballast water regulations, the International Maritime Organization's
(IMO) ballast water convention, and the National Invasive Species Management Plan.
The U.S. has not come to a decision on signature or ratification of the IMO's Convention
for the Control and Management of Ships' Ballast Water and Sediments.  The U.S. is
working through the Ballast Water Working Group to develop and comment on the
various guidelines called for by that Convention. These guidelines will, in essence,
constitute the guidance the Parties will use in implementation  of the Convention.  As
those guidelines are developed, the U.S. Government will be in a better position to
formulate its views on signature or ratification of the Convention.

One response to the variety of threats posed by invasive species was the May 2003
Aquatic Invasive Species Summit convened by the USFWS and the City of Chicago's
Department of Environment. More than seventy global experts participated.  Solutions
to halting the influx of aquatic invasive species were explored, and recommendations
developed. The principal recommendations were two-fold, and included the long term
goal of hydrologically separating the Mississippi River drainage system and the Great
Lakes Basin within ten years. The second principal recommendation included the short
term goal of pursuing additional control and prevention technologies to augment the
existing and proposed electrical barriers. The Summit proceedings have been
published, and an excellent brief summary can be found at:

                   http://midwest.fws.gov/Chicago/summit.pdf
RECOMMENDATION B

Issue a reference on aquatic alien invasive species to the International Joint
Commission to:

•     Help identify the most effective ways to coordinate bi-national prevention
      efforts and harmonize national plans, particularly those dealing with
      residual ballast water and sediment in ballast tanks;

•     Evaluate the effectiveness of current institutional arrangements;

•     Assist with the establishment of a regional standard stronger than the
      minimum required by the International Maritime Organization Convention;
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      Ensure that economic analyses carried out for projects with potential
      environmental effects include the environmental and societal costs of
      aquatic alien invasive species control, damage, and mitigation, and the
      costs and benefits of prevention measures; and

      Assist with public education and communications.
RESPONSE

The U.S. supports further discussions with Canada and the IJC to seek agreement on
the scope of a reference.

The U.S. is consulting with Canada on a possible reference to the IJC. However, the
governments are anxious to avoid overlapping or duplicative efforts. It appears that
certain parts of the suggested IJC reference are in the process of being carried out by
U.S. agencies and their Canadian counterparts. For example, the U.S. and Canada
have intensified cooperation on harmonizing prevention efforts for alien invasive
species.  The two Parties met in November 2004 after Canada released its internal
National Management Plan and met again in spring 2005. The U.S. does not rule out
the possibility of working towards more stringent ballast standards than would be
adopted under the IMO. It would be best to fashion a reference that would focus the
IJC's efforts where they would add they most value.

The U.S. and Canada are also discussing the geographic scope such a reference would
cover.  Such a reference might do more to strengthen the two Parties' national
strategies for alien invasive species if it was not limited to the Great Lakes. Consistent
with this approach, the U.S. presently does not believe that there should be a separate
ballast water discharge treatment standard for the Great Lakes. The U.S. continues to
support the mandatory ballast water exchange requirements applicable under U.S.  law
to the Great Lakes. The U.S. Coast Guard is currently undertaking an environmental
impact analysis  of several alternative standards in preparation for proposing a rule for
use in approval  of ballast water treatment systems under the National Invasive Species
Act that will establish a biologically meaningful and scientifically sound ballast water
discharge standard on a national basis. Ballast water exchange would still be allowed,
but having a ballast water discharge standard would facilitate improvement of treatment
systems.

EPA, NOAA, and the USFWS are Cooperating Agencies in the preparation of the Draft
Programmatic Environmental Impact Statement.  This  standard would not only help
provide the Great Lakes with protection against the invasion of aquatic invasive species,
it would also avoid the problems a Great Lakes specific standard would bring, such as
economic impacts that might be caused if vessels were to shift their trade patterns to
ports outside the Great Lakes to avoid the cost of complying with a more restrictive
regional standard.
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These recommendations are also being considered by the Great Lakes Regional
Collaboration's Aquatic Invasive Species Strategy Team and the Indicators and
Information Strategy Team's Communications Work Group.
RECOMMENDATION C

All levels of governments should create and implement coordinated planning
actions to fully protect drinking water from increased pressures from industry,
urban expansion, aging infrastructure and agriculture, including ecosystem and
human health protection from large-scale animal operations.

RESPONSE

The U.S. agrees with this recommendation and has a variety of longstanding programs
in place and new ones being developed which strive to fully protect drinking water from
a variety of pressures.

For almost thirty years, protecting the Nation's public health through safe drinking water
has been the shared responsibility of EPA, the States, and over 53,000 public water
systems (PWSs) nationwide that supply drinking water to more than 270 million
Americans (approximately 90 percent of the U.S. population).  Within this time span,
drinking water standards have been established and are being implemented for ninety-
one microbial, chemical, and radiological contaminants. Forty-nine States have
adopted primary responsibility for enforcing their drinking water programs.  Additionally,
PWS operators are better informed and trained on the variety of ways to both treat
contaminants and prevent them from entering the source of their drinking water
supplies.

During 2005-2008, EPA, the States, and PWSs will build on these programmatic
successes while working toward the goal of assuring that 95 percent of the population
served by PWSs receives drinking water that meets all applicable health-based
standards through effective treatment and source water protection.  This goal reflects
the fundamental public health protection mission of the national drinking water program.
The standards  typically do not prescribe a specific treatment approach; rather, individual
systems decide how best to comply with any given  standard based upon their own
unique circumstances. Systems achieve compliance with standards by employing
various elements of what public health experts refer to as "multiple barriers of
protection" which may include source water protection, various stages of treatment,
proper operation and maintenance  of the distribution and finished water storage system,
and customer awareness.

EPA has identified key activities within five core program areas that  are critical to
ensuring safe drinking water.  The core program areas are:
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      the development or revisions to drinking water standards;

      the implementation of drinking water standards and other program requirements;

      the promotion of sustainable management of drinking water infrastructure;

      the protection of sources of drinking water from contamination; and

      the assurance that critical water infrastructure is secure from terrorist and other
      intentional acts.

The Drinking Water State Revolving Fund is a major EPA/State effort that has provided
States with significant financial resources to address program needs resulting from
aging infrastructure and regulatory requirements. Protection of sources of drinking
water should be enhanced by the States' recent completion of assessments for all
public water systems that identify potential sources of contamination and the source
water's susceptibility to contamination.  Efforts at the State and local level are now
shifting towards using the information in  the assessments to identify appropriate
measures to protect drinking water.

Collectively, these core areas and other interrelated elements of the national safe
drinking water program form a balanced, integrated framework that comprises the
multiple barrier approach to  protecting public health from unsafe drinking water. At the
national level, implementation of this approach  is expected to result in significant
progress toward the public health goals described above.

With respect to the last part  of the recommendation regarding the protection of
ecosystem and human health from large scale animal operations, on  February 12,
2003, EPA issued revised regulations for the Effluent Limitations  Guidelines and the
National Pollutant Discharge Elimination System Permit Regulations for Concentrated
Animal Feeding Operations (CAFOs - 68 FR 7176).  The changes were intended to
remove ambiguity about which operations are covered by EPA rules and parallel rules
adopted by authorized States and to ensure effective manure management by large
operations, including land application. The revised regulations expanded the number of
operations covered from  12,500 to an estimated 18,500 and included requirements to
address the land application of manure from CAFOs.  EPA estimates that every year
this rule is implemented nationwide, it will remove 166 million pounds of nutrients  and
2.2 billion pounds of sediment loads from existing discharges.

EPA is currently working to resolve issues arising from the February 28, 2005 U.S.
Court of Appeals, Second Circuit opinion in Waterkeeper Alliance Inc., et al. v. EPA, in
which the court overturned or remanded certain provisions of the regulation.
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CHAPTER 3: CHEMICAL INTEGRITY

This chapter addresses the health impacts of mercury and PCBs, especially in AOCs,
the Parties ability to communicate these health risks, and methods for controlling the
global emission and deposition of mercury. The IJC makes three recommendations
labeled A, B, and C below:

RECOMMEND A TION A

The Commission recommends that the two federal governments, in conjunction
with the states and provinces and institutions:

      Undertake retrospective and prospective epidemiological studies, in
      Areas of Concern and other pertinent locations of the Great Lakes
      basin, to better understand potential neuro-developmental effects
      associated with methyl mercury and PCBs.
RESPONSE

The U.S. agrees that a better understanding of the potential neuro-developmental
effects associated with methylmercury and PCBs would benefit not only the people
living in or adjacent to the AOCs but also all of the residents of the Great Lakes Basin.
We would also like to note that there are substances besides PCBs and mercury that
have deleterious effects at sufficient levels of exposure. Many of these are being
addressed by the Great Lakes Binational Toxics Strategy.

The Centers for Disease Control and Prevention (CDC), the Agency for Toxic
Substances and Disease Registry (ATSDR) and the States are generally the agencies
responsible for conducting epidemiological investigations (both retrospective and
prospective).

ATSDR is currently working with the IJC to produce a report evaluating the health
implications of hazardous substances in the U.S. 26 AOCs.  This report is currently in
draft form. Upon conclusion of this report, ATSDR has no future plans to undertake
retrospective and prospective epidemiological studies in AOCs in the Great Lakes
Basin.

Epidemiological studies of the exposure and effect of methylmercury are best
conducted for populations that have relatively high  exposures. In general, there are not
grounds for thinking methyl  mercury exposures are especially high in Great Lakes
AOCs. For example, mercury has been a factor in designating only one U.S. AOC
(Deer Lake, Michigan). However, as additional blood methylmercury level data are
collected and analyzed for various populations in the region, additional epidemiological
studies may be warranted.
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In recent years, the U.S. has contributed to epidemiological studies of methylmercury
exposures among fish-eating populations. These studies have been used in the
development of the EPA reference dose for methylmercury exposure, in the National
Academies of Science's review of the reference dose in Toxicological Effects of
Methylmercury (2000), and in ATSDR's toxicological profiles.

Additional studies are being conducted among populations that have high
methylmercury exposure because of elevated concentrations  of methylmercury in fish
      dietary patterns (studies by Dr.  Donna Mergler and Dr. Ellen Silbergeld).
Lessons from such major studies will have broad geographic applicability. Therefore,
ATSDR will be focusing its Great Lakes related efforts on its Great Lakes Human Health
Effects Research Program (GLHHERP).

Great Lakes Human Health Effects Research Program

Since 1992, ATSDR has run the GLHHERP which is designed to characterize exposure
to contaminants via consumption of Great Lakes fish, and  investigate the potential for
short and long term adverse health effects. GLHHERP's goals are to identify sensitive
human sub-populations residing in the Great  Lakes Basin, and to reduce exposure to
toxic chemicals.  It is designed to investigate and characterize the association between
the consumption of contaminated Great Lakes fish and short and long term harmful
health effects.  Its six objectives are:

      Build upon and extend the results from past and ongoing research;

      Develop information databases  and/or research  methodology that will provide
      long term benefits to the human health effects research efforts in the Great Lakes
      Basin;

      Provide direction for future health effects  research;

      Provide health information to State/local health officials, the concerned public,
      and their medical health  care professionals;

      In concert with State/local health officials, increase public awareness regarding
      the potential health implications of toxic pollution in the Great Lakes Basin; and

      Coordinate as necessary with relevant U.S. Department of Health and Human
      Services research programs and activities, including those of CDC, the Food  and
      Drug Administration (FDA), the  National  Institutes of Health (NIH), and the Indian
      Health Service (IHS), as well as with EPA and State and local health
      departments to ameliorate adverse public health impacts of persistent toxic
      substances in the Great  Lakes Basin.

Several studies evaluating the health effects of eating fish from various locations within
Great Lakes Basin have been completed or are  ongoing. Here is a brief summary of
these studies with more information provided in Appendix 1. The first five studies are
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ongoing; the second five are completed and are in the process of submitting
publications:

      An epidemiologic study in an established cohort of American Indians, the
      Mohawk Indian Tribe, which investigates the association between the
      consumption of locally caught fish and wildlife and body burdens of PCBs , 68
      PCB congeners, dichlorodiphenyldichloroethylene (DDE), mirex, and
      hexachlorobenzene (HCB) in men and women who live along the St. Lawrence
      River and its tributaries.

      A longitudinal assessment of neuropsychological and thyroid function in aging
      Great Lakes fisheaters and a prospective study of health outcomes in Asian
      Americans.

      A longitudinal-sequential study involving behavioral testing of three cohorts of
      children born to women from Oswego County,  New York, who consumed large
      amounts of Lake  Ontario sportfish over their lifetime.

      A cross-sectional and longitudinal observational assessment of the effects of
      PCB exposure, both current and in utero, on reproductive health. The main goal
      of this project is to assess fecundity and reproductive success in two cohort
      studies of individuals selected from two source populations at elevated risk of
      exposure to PCBs via consumption of Great Lakes sport-caught fish.

      A research grant  to conduct statistical analyses of congener-specific serum PCB
      data for about 750 adult Mohawk Indians using multivariate techniques and to
      compare the results with those for other published relevant databases to identify
      unique populations and environmental variables in the Mohawk cohort.

      The New York State Angler Cohort Study (NYSACS) is a population-based study
      established to assess the association between past and current consumption of
      sport fish, from the Great Lakes, and short and long term human health effects
      such as reproductive and developmental effects.

      A research grant  to continue and expand mercury exposure research which will
      provide additional information needed regarding methylmercury exposure and
      possible health risks to pregnant women and women of childbearing age living in
      the Great Lakes Basin.

      A continuing examination of the association between sport caught fish
      consumption in the diet of Great Lakes area residents and serum levels of PCBs,
      DDE, dioxins, and furans which have been detected in Great Lakes fish.

      A longitudinal assessment of exposure and the potential for adverse health
      effects such as reproductive and developmental effects to chlorinated
      hydrocarbons by  consumption of contaminated Great Lakes Fish in pregnant
      woman of African-American descent and their newborns.
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      A study of the Ojibwa Tribe to determine exposure to methylmercury and
      organochlorines (PCBs and pesticides) via fish consumption and their correlation
      with adverse health outcomes.

In the future, the GLHHERP plans to continue to provide research findings to public
health officials to improve their ability to assess and evaluate chemical  exposure in
vulnerable populations.  ATSDR also plans to focus on research priorities of children's
health, endocrine disrupters, mixtures, surveillance, and identification of biomarkers,
i.e., exposure, effect, and susceptibility.  In addition, the program will use established
cohorts to monitor changes in body burdens of persistent toxic substances and
specified health outcomes, and develop and evaluate new health promotion strategies
and risk communication tools.

It is also important to note that there are national efforts which will have a profound
impact on assessing human health both nationwide and within the Great Lakes Basin.
These include work being done by the CDC and EPA.

Centers for Disease Control and Prevention  Efforts

CDC's National  Health and Nutrition Examination Survey (NHANES) is  a continuous
survey of the health and nutritional status of the civilian, non-institutionalized U.S.
population. It is designed to be representative of the general U.S. population. Data are
released and  reported in two year cycles. NHANES began measuring blood mercury
levels in a representative sample of these populations in 1999 to determine levels of
total blood mercury in childbearing-aged women and in children aged 1-5 years. The
findings confirmed that blood mercury  levels in young children and women of
childbearing age usually are below levels of concern. However,  6 percent of
childbearing-aged women had mercury exposure levels at or above a blood mercury
concentration equivalent to the EPA Reference Dose (RfD).  EPA defines the RfD as an
estimate of a daily exposure to the human population (including sensitive subgroups)
that is likely to be without an appreciable risk of deleterious effects during a lifetime. An
estimated level assumed to be without appreciable harm. For more information, please
goto:

             www.cdc.gov/mmwr/preview/mmwrhtml/mm5343a5.htm

It is also important to note that the RfD does not define a bright line above which
individuals are at risk of adverse effect. The work being  undertaken by the GLHHERP
as described above is helping to determine whether U.S. populations in the Great Lakes
Basin are experiencing mercury exposure higher than national norms.  The same
applies to other contaminants of concern, both in NHANES and in the Great Lakes
Basin.

CDC's Environmental Public Health Tracking Program is tracking the ongoing collection,
integration, analysis, and interpretation of data about environmental contaminants,
exposure to environmental contaminants, and human health effects potentially related
to exposure to environmental contaminants.  The Program also disseminates
information related to these data.  The mission of environmental  public  health tracking is

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to improve the health of communities. Federal, State, and local agencies, using
information from an environmental public health tracking network, will be better
prepared to develop and evaluate effective public health actions that will prevent or
control chronic and acute diseases, which can be linked to hazards in the environment.
This information can help healthcare  professionals provide better care and targeted
preventive services. In addition, the public will have a better understanding of what is
occurring in their communities and what actions they may take to protect or improve
their health. Currently, four of the Great Lakes States participate in this program
(Wisconsin, Illinois, New York, and Pennsylvania).

A competitive grants program also was offered to schools of public health to establish
Centers of Excellence in Environmental Public Health Tracking. These Centers provide
expertise and support to CDC and State and local health departments in developing and
using data from environmental public health tracking systems at the local, State, and
national levels and investigate potential links between health effects and the
environment.  For more information, please go to:

                  http://www.cdc.gov/nceh/tracking/default.htm
EPA Efforts

As part of its mission to protect human life and the environment, EPA conducts research
to characterize, predict and diagnose human and ecosystem exposure to harmful
pollutants and other conditions in the air, water, soil, dust and food. The National
Exposure Research Laboratory and other agency bodies provide exposure information
for chemicals, biologicals, radiation, and changes in climate, land and water use.  EPA's
Integrated Risk Information System (IRIS), summarizes available toxicity data and
contains  EPA's assessment of the ways in which the general public may be exposed to
individual chemicals. Additionally,  EPA develops and field tests new technologies for
assessing and modeling exposure  patterns, concentrations and scenarios,  including
short and long-term effects and the potential for exposure across great distances. Much
of this work has led to EPA input into the NHANES  selection of contaminants to be
selected  and work by EPA scientists based  on the NHANES data collected.

EPA has also been working for several years on the development of measures to track
factors important for children's environmental health.  In proportion to their size, children
breathe more air, drink more water and eat  more food than adults. This puts them at
greater risk of exposure to pollutants.  Children's bodies are also less able to
metabolize, detoxify and expunge these pollutants.  In recognition of the greater
vulnerability of children to harmful substances, EPA has established the Office of
Children's Health Protection (OCHP).  OCHP ensures that all standards set by EPA are
protective of any heightened risks faced by  children and that newly developed policies
address children's health concerns. Through education and outreach, EPA also seeks
to raise awareness of children's health concerns among schools, communities, health
professionals and families. Part of this work has resulted in two EPA publications,
America's Children and the Environment, Measures of Contaminants, Body Burdens,

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and Illnesses] and America's Children and the Environment: A First View of Available
Measure.  Both are available at:

                      www.epa.gov/envirohealth/children

EPA is embarking on a new phase of this work in which it will be discussing new areas
of work in children's environmental health indicators. EPA conducted a workshop in
March 2005 which focused on suggested new data sources and methods to improve the
measures for different topic areas currently in the reports and on additional new topic
areas or measures that should be considered.  Some of the specific issues EPA will be
considering are neuro-developmental disorders in children, better ways to assess
dietary exposure to food contaminants, and additional measurements of chemical body
burdens in children. Information from this work can be factored into fish consumption
advisories for sensitive populations issued by the Great Lake States.
RECOMMENDATION B

The Commission recommends that the two federal governments, in conjunction
with the states and provinces and institutions:

      Make fish advisories clear, simple, and consistent, and ensure that
      they are reaching the intended audiences.

RESPONSE

The U.S. agrees that fish advisories should be clear and simple to reach the intended
audiences.  Since contaminant levels may vary somewhat location-to-location, complete
consistency may not be possible. The  U.S. agrees that appropriate consistent advice
across the Great Lakes s is desirable.

State and Tribal Efforts

The States and American Indian Tribes have primary responsibility for advising
residents about the health risks of consuming chemically contaminated
noncommercially caught fish and wildlife. They do this by  issuing consumption
advisories for the general population, including recreational and subsistence fishers, as
well as for sensitive sub-populations (such as pregnant women, nursing mothers, and
children). These advisories are based  on chemical contaminants (e.g., mercury, PCBs,
and dioxins) that have been found in local fish and wildlife.  The advisories include
recommendations to limit or avoid consumption of certain fish and wildlife species from
specified water bodies or, in some cases, from specific water body types, such as all
inland lakes.

States typically issue four major types of advisories and bans to protect both the general
population and specific sub-populations:
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      When levels of chemical contamination pose a health risk to the general public,
      States may issue a "no consumption" advisory for the general population.

      When contaminant levels pose a health risk to sensitive sub-populations, States
      may issue a "no consumption" advisory for the sensitive sub-population.

      In water bodies where chemical contamination is less severe, States may issue
      an advisory recommending that either the general population or a sensitive sub-
      population restrict their consumption of the specific species for which the
      advisory is issued.  This may include size-based restrictions, an important tool for
      protecting public health, since older and larger fish often contain higher levels of
      toxic substances

      When events warrant, States may issue a commercial fishing ban, which
      prohibits the commercial harvest and sale offish, shellfish, and/or wildlife species
      from a designated water body and, by inference, the consumption of all species
      identified in the fishing ban from that water body.

All of the Great Lakes States have fish consumption advisories.  When States and
Tribes issue advisories, they may take into account the culture and languages of their
respective residents.  In order to make the advisory well understood, fish consumption
advisories are often published in multiple languages. The advisories may also not only
contain information on the possible pollutant problems, they also may inform fish-eaters
of the best ways in which to select, clean and cook the fish. This added information
helps the consumer reap the benefits of eating fish and shellfish while being  confident
that they are reducing their potential exposure to bioaccumulative pollutants.  It is
important to remember that recommendations on safe levels offish consumption for
organic pollutants are often based on the assumption that proper cleaning and cooking
advice has been followed.  Cleaning and cooking procedures do not reduce the mercury
content offish. Fish consumption advisories are updated periodically and can be found
at the following web site:

                   http://epa.gov/waterscience/fish/states.htm

Federal Efforts

In March 2004 FDA and EPA jointly issued national fish consumption advice in a
brochure entitled, What you Need to Know about Mercury in Fish and Shellfish for
women who might become pregnant, women who are pregnant, nursing mothers and
young children.  The advice applies to both commercial and noncommercial fish.
Beginning in summer of 2004, EPA and FDA began distributing the brochure in English
and Spanish with additional languages planned for late 2005.  Approximately 6 million
copies of the English version (lesser amounts in Spanish) have been distributed by mail
and at national medical conferences. Over 170,000 members of the U.S. medical
community, as well as State, Tribal, local health departments, WICs, Pregnancy
Planning Centers, and other public health organizations received brochures.   Brochures
can also be ordered by contacting the EPA document distribution center at 1-800-490-
9198. For further information regarding the advisory, visit the EPA Fish Advisory

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Program website at www.epa.gov/ost/fish. EPA and FDA will continue to promote the
advisory at major medical and environmental health conference around the country
throughout 2006.

Outreach materials developed by EPA and ATSDR were also sent to physicians and
can be found at:

               www.epa.gov/waterscience/fishadvice/advice.html

In 2003, the University of Illinois at Chicago School of Public Health completed the PCB
Risk Communication and Outreach Project, which was funded by EPA's Persistent,
Bioaccumulative Toxics (PBT) Program.  This project identified the need for consistent,
culturally-sensitive fish consumption information for urban ethnic fishers in the Lake
Michigan basin who remain uninformed (and possibly overexposed) about contaminants
in the fish they use to supplement their diets.  Recognizing this,  the PBT Program has
started a project to scale up efforts to enhance outreach to ethnic and minority fishers in
three States, including the Great Lakes States of Michigan and Wisconsin.

In 2004, the Great Lakes Indian Fish and Wildlife Commission (GLIFWC) completed a
report on dioxin contamination in Lake Superior fish,  funded by the PBT Program. The
report identified low levels of several dioxins and furans in fish used for both
subsistence and commercial purposes by Great Lakes Tribes. In addition to the
possibility of excess exposure, the report also pointed out the need for clarity and
consistency in fish consumption advisories from multiple jurisdictions.

Approximately every 18 months, EPA hosts the National Forum  on Contaminants in
Fish which is attended by Federal, State and Tribal agency staff as well as members
from the regulated community.  Each forum has a session on Risk Management Issues
which include discussions of the special outreach needs of particular sub-populations.
At the January 2004 forum, this session included presentations  on risk communications
to diverse populations in an urban setting and risk communications for medical
practitioners. The proceedings from this forum can be found at:

                  www.epa.gov/waterscience/fish/forum/2004/

The most recent forum was held on September 18-21,  2005 in Baltimore, Maryland.
More information can be found at:

                  www.epa.gov/waterscience/fish/forum/2005/

Other Resources

In addition to Government issued fish consumption advisories, additional outreach
materials have been distributed to Great Lakes fish consumers.  For example The
Illinois-Indiana  Sea Grant issued a fish consumption  information brochure in 2003
entitled "The ABCs of PCBs: Know Your Catch".  The brochure was published in
English, Polish, Spanish and Korean and was distributed to Great Lakes fishermen.
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In 2002, the Lake Erie Forum published a fish consumption brochure entitled "A
Family's Guide to Eating Fish from the Lake Erie Basin," targeting women and children
in this area. These types of outreach efforts exemplify how the Federal government,
States, and local communities are working together to better inform the public of
possible health risks and benefits.

Currently, the Illinois-Indiana Sea Grant is undertaking a project which focuses on fish
consumption risks and benefits through education of children and their families via
teacher education and dissemination through community-based health expos targeting
this vital health issue.  In order to make information on fish contaminants more readily
available to subsistence anglers and to pregnant and nursing mothers, an education
program will be developed to provide critical human health guidance.  The information-
based expos created by students with their teachers' guidance will:

      increase awareness of the risk among populations who fish for subsistence; and

      provide knowledge and improve understanding about how to properly clean
      potentially contaminated Lake Michigan fish, especially for those populations
      which are at most risk, such as pregnant and nursing mothers and their young
      children.

The U.S. will continue to identify targeted sub-populations which require targeted
outreach regarding the benefits and risks associated with consuming Great Lakes fish
and wildlife. Appropriate outreach materials will be developed which  can more
accurately and appropriate these benefits and risks in a culturally sensitive manner.
RECOMMENDATION C

Select and promptly implement programs in both the United States and Canada
that would substantially reduce the deposition of mercury in its reactive gaseous
form in the Great Lakes region; and also pursue multi-lateral strategies for further
control of this persistent toxic substance on a global basis.

RESPONSE

The U.S. considers all air emissions of mercury, in any chemical form, to potentially
contribute to atmospheric deposition of mercury to the earth and its surface waters.
Elemental mercury can be converted to reactive gaseous mercury  in the atmosphere,
and elemental mercury can be dry deposited, particularly in leaf litter in deciduous
forests.  Dry deposition of mercury vapor from the atmosphere is not a well understood
as wet deposition and could potentially rival wet deposition (of reactive gaseous
mercury).

Through time, the U.S. has undertaken many steps to reduce national releases of
mercury. These have resulted in reductions of both elemental and reactive gaseous
mercury:

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      Use of mercury within the U.S. economy has decreased by greater than 95
      percent since the 1960s.  Mercury use has been discontinued in pesticides,
      paints, certain batteries, and medicines.

      U.S. human-caused emissions of mercury to air have decreased 45 percent
      since  1990.

      On December 19, 2003, EPA issued final regulations to reduce mercury
      emissions from chlorine production plants that rely on mercury cells (68 FR
      70903, codified at 40 C.F.R. part 63, subpart Mill).  The regulations establish
      numerical emission limits for total mercury from existing vents, and also include a
      set of rigorous work practice standards, representing the best practices from the
      industry, to mitigate fugitive mercury releases. These standards are more
      stringent than were required by a pre-existing regulation that covered this source
      category.  Today, there are nine such plants in the U.S., as compared to about
      20 in the early 1990s.

      Mercury emissions  from municipal waste combustors and medical  wastes
      incinerators have been reduced by more than 90 percent as a result of
      regulations issued under the Clean Air Act. These facilities were an important
      source of reactive gaseous mercury to the atmosphere in the U.S.

Reduced releases of mercury may help explain significant reductions in mercury levels
since the 1970s within Great Lakes fish (trout and smelt) and birds (herring gulls).

In March 2005, the U.S. became the first country in the world to regulate mercury
emissions from coal-fired power plants.   EPA issued the Clean Air Mercury Rule, which
is the first ever Federal rule to permanently cap and reduce mercury emissions from
coal-fired power plants.  Under the Clean Air Mercury rule, the first phase cap is 38
tons, and it takes effect in  2010.  Mercury reductions under this cap will be achieved
largely as the result of "co-benefits" of reducing emissions of sulfur dioxide and nitrogen
oxides under the Clean Air Interstate Rule. 70 Fed. Reg. 25,162 (May 12, 2005) (Clean
Air Interstate Rule); 70 Fed. Reg. 28,605 (May 18, 2005) (Clean Air Mercury Rule).
Coal-fired power plants are expected to reduce beyond the first phase cap of 38 tons
and emit about 31 tons in 2010.  They are expected to reduce beyond what is required
in order to bank allowances for future years. Moreover, we anticipate substantial
reductions in the emissions of reactive gaseous mercury as the result of the first phase
cap.  The final cap in the Clean Air Mercury Rule on mercury emissions from coal-fired
power plants comes into effect in 2018.  When fully implemented, emissions from these
sources will be reduced from 48 tons per year to 15 tons,  which is a reduction of nearly
70 percent.  This multi-pollutant approach creates strong incentives for the power sector
to install a significant number of scrubbers and Selective Catalytic Reduction (SCR)
technologies. These controls particularly reduce reactive gaseous mercury, the form
that matters  most for reducing U.S. deposition. EPA included information as to the
amounts of mercury deposition, and the impacts of CAIR and CAMR in reducing that
deposition, in a rulemaking under the Clean Air Act concerning domestic power plants.
(See 70 Fed. Reg. 15994 (March 29, 2005); Technical Support Document: Methodology
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Used to Generate Deposition, Fish Tissue Methylmercury Concentrations, and
Exposure for Determining Effectiveness of Utility Emissions Controls):

     www.epa.gov/ttn/atw/utility/depo_fishmehg_exp_oar-2002-0056-6186.pdf

Another source of emissions being addressed is the melting of auto scrap that contains
mercury switches at steel production facilities.  EPA is involved with efforts to
encourage the removal of these switches before the scrap goes to the steel production
facilities, and also is developing a regulation to control emissions from  these facilities.

In recent years, the U.S.  has contributed significantly to international activities to
promote greater prevention of mercury releases.  Since 2002, for instance, the U.S. has
contributed significant resources to support  the United Nations Environmental Program
(UNEP) and its participating nations with activities to address mercury  pollution,
including completing the  Global Mercury Assessment report, conducting awareness
raising workshops, development of guidance materials, and undertaking other
information-sharing activities. During 2005,  in addition to continuing general support for
the UNEP Mercury Program, the U.S.  is considering and  developing new initiatives
among countries and other stakeholders to  support collaborative activities, including
information sharing among interested nations to assist them with addressing a variety  of
mercury issues,  such as risk assessment, emissions inventories, combustion of coal,
small-scale and industrial-scale mining, chlor-alkali  production, and the use of mercury
in products.

There have also been a variety of regional projects  aimed at mercury reduction.  Below
are four examples of these type of projects:

1.    Working under a 2002 Pollution Prevention Demonstration grant from EPA
      Region 5,  the Minnesota Technical Assistance Program (MnTAP) used Hospitals
      for a Healthy Environment (H2E) tools to demonstrate the effectiveness of
      pollution prevention at health care facilities. As a result  of MnTAP's work through
      this project, at least 34 Minnesota health care facilities (22 percent of Minnesota
      hospitals)  are engaged in documented pollution prevention efforts at some level.
      Thirteen facilities have signed on as  H2E "Partners" and 29 have either
      eliminated 75 percent of their mercury or are working toward that goal. These
      facilities have eliminated 394 pounds of mercury, 851 gallons of hazardous
      chemicals, and 250,000  pounds of solid waste. A  number of outreach efforts and
      communication techniques were used to reach the healthcare audiences.
      Working through the University of Minnesota's Academic Health Center and the
      healthcare trade associations proved most effective. H2E provides useful tools
      and good publicity to encourage pollution prevention in the healthcare sector.
      MnTAP worked with H2E to develop  some of its products, including the Chemical
      and Solid Waste Minimization Plans.  The full report on this project  is  available
      on the MnTAP Web site:

                           http://www.mntap.umn.edu
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2.     EPA Region 5 continues to participate in statewide dialogues in Michigan and
      Indiana to develop statewide recycling infrastructures for recycling electronic
      waste, which is a key source of lead, mercury and other metal emissions (and
      possibly a source of some brominated flame retardant emissions, as well).  State
      and local governments,  recyclers, reuse organizations, manufacturers, non-
      profits, and trade associations participate in these dialogues.  The stakeholders
      consider and discuss existing information and proposed changes in four areas:
      educational resources (to include in a tool kit with case studies and models),
      funding, logistics and regulatory approaches, including possible landfill bans.
      The groups also target public sector purchasing of greener electronics, and are
      working  to identify a common data standard to report the successes of local
      electronics recycling collection  events throughout the region.

3.     In November 2004,  EPA Region 5 published a Mercury Pollutant Minimization
      Program (PMP) guidance to address situations where a PMP is required in a
      State-issued NPDES permit for a Publicly Owned Treatment Works (POTW).
      The guidance is needed to assist the States in implementation of stringent limits
      being imposed as a result of the Great Lakes Water Quality Guidance (GLWQG).
      Many POTWs will not be able to demonstrate compliance with these limits and
      will need to obtain variances. As a variance condition, these POTWs will need to
      implement a PMP to address sources of mercury within their systems. The
      guidance was developed in coordination with the Region 5 States, in order to
      promote a consistent approach for these programs.  It includes recommendations
      on sectors that should be addressed (e.g.  medical and dental facilities, schools,
      laboratories, etc.), and potential approaches for controlling these sectors.
      Decisions as to specific  PMP requirements in a community will continue to be
      made by the State and local POTW.

      The guidance has been  used by the Indiana Department of Environmental
      Management in development of its Streamlined Mercury Variance rule, which is
      expected to be finalized  in June 2005, as well as by the Wisconsin Department of
      Natural Resources as it  develops its State-specific Mercury PMP Guidance.
      Currently, 33 out of 230  major POTWs in the Great Lakes Basin have GLWQG-
      based mercury limits and PMP requirements.  The goal is for over 200 to have
      them by 2007.   The region will continue to track POTW effluent levels in relation
      to the underlying water quality criteria, but the effects of PMP implementation are
      expected to be seen in sludge before  POTW effluent. The Region has begun to
      establish a baseline of mercury in sludge from  POTWs in the basin, and has set
      a goal that by 2008, levels of mercury in land-applied sludge will have decreased
      by 25 percent.

4.     In 2003 and 2004, using a coordinated approach with State health departments,
      local hazardous waste collection events, and a previously developed audit tool,
      EPA Region 5 Waste, Pesticides and Toxics Division collected approximately
      1,000 pounds of mercury from Wisconsin and Michigan schools.
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CHAPTER 4: ECOSYSTEM INTEGRITY

This chapter addresses the ecosystemic changes occurring in Lake Erie and urges the
governments to continue researching this phenomenon and makes the following
recommendation:

RECOMMENDATION

The Commission recommends that Governments continue to fund binational
research efforts begun in 2002 and 2003 to better understand changes in the Lake
Erie ecosystem. The institutional model provided by the Lake Erie Millennium
Network should be considered for adaptation and adoption on the other Great
Lakes to foster enhanced binational cooperation and communication.

RESPONSE

The U.S. Government shares the IJC's concern with the changes taking place within the
Lake Erie ecosystem.  The restoration of Lake Erie through the combined efforts of
Federal, State and Provincial actions is one of the great environmental success stories
of our time.  Troubling changes which are now occurring are posing a threat to this
success and are being addressed directly by the Parties.

The changes in the  Lake Erie ecosystem which has raised concerns is the occurrence
of the "dead zone," an area in the central basin of Lake Erie where the oxygen at the
bottom of the lake goes below 1 milligram/liter, a level at which no fish and few other
organisms can survive. Monitoring by GLNPO aboard its research vessel the R/V Lake
Guardian helped  identify this problem which is associated with observed rising levels of
phosphorus in Lake Erie.  The appearance of the "dead zone" is not a new problem; it is
something that U.S. agencies are quite familiar with and have successfully addressed in
the past, when phosphorus abatement programs were successful in greatly  improving
Lake Erie's water quality.

In response to the discovery of rising phosphorus levels, GLNPO launched the Lake
Erie Supplemental Study of Trophic Status, which began on June 17, 2002.  This study
includes Lake Erie experts from more than twenty U.S.  and Canadian universities and
institutions.  The study is an initial investigation to identify the most probable causes of
the problem, and will most likely lead to more targeted research. Preliminary data have
been provided to EPA and a final report is  due in 2005. To date, the available
information does  not indicate any substantial or significant  increases in loadings of
phosphorus or other nutrients to Lake  Erie from external sources, but this is  still an area
of investigation.  Researchers are investigating several hypotheses including the theory
that zebra and quagga mussels (non-native invasive species) may be a cause of the
problem. Preliminary results, although inconclusive, have lent some support to this
hypothesis,  but the cause or causes may be more complex.

To further our understanding of the Lake Erie ecosystem, NOAA's Great Lakes
Environmental Research Laboratory, in collaboration  with researchers in the U.S.  and
Canada, is conducting one of the largest, most comprehensive Lake Erie research field

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programs. The two-year project, the International Field Years on Lake Erie, started in
April 2005 and includes a series of ship cruises, as well as field and laboratory work.
Researchers will try to better understand the impact of the "dead zone" on the food web
in this region, including fish. The whole-lake research effort will focus primarily on
issues related to the effects of oxygen depletion (hypoxia/anoxia) on food-web
interactions and fish production in the central basin, as well as the causes of harmful
algal blooms in the west basin. Two major partners in the effort are GLNPO and the
National Sea Grant College Program.

In addition, the USFWS led Great Lakes Basin Ecosystem Team binational partnership
is pursuing and demonstrating success for Lake  Erie assessment and restoration of
shared priority fish, wildlife, and habitat needs, including for Western Lake Erie island
conservation, lake sturgeon restoration, climate change impacts, coastal habitat
restoration, migratory bird stopover sites, and the emerging issue of wind power
generation (http://greatlakes.fws.gov/).

Lake Superior

Pursuant to the decision of the Binational Executive Committee to  ensure that each lake
basin has a monitoring strategy, the Lake Superior LaMP Workgroup has formed a
coordinated monitoring committee. This Committee has been meeting on a regular
basis to formulate a monitoring strategy for Lake Superior, assess where and what the
highest priority monitoring needs are, and how to best achieve these monitoring goals.
This monitoring committee is comprised of a binational group of scientific experts who
work with the other ecosystem committees of the Lake Superior Workgroup, including
aquatics, habitat, terrestrial wildlife and chemical committees.

Lake Ontario

The Lake Ontario LaMP has a history of binational monitoring cooperation and
continues to implement this, with the three efforts that have been ongoing since 2003 to
improve understanding of the Lake Ontario ecosystem. They are the Lake Ontario
Atmospheric Deposition Study for developing a more detailed understanding of
atmospheric deposition processes within the Lake Ontario, the Lake Ontario Lower
Aquatic Foodweb Assessment for developing a better understanding of the changes
that are occurring in Lake Ontario's lower aquatic foodweb and its  ability to support fish
populations, and the Interagency Laboratory Comparison Study helping to understand
differences in analytical and sampling methods.

Lake Michigan

The Lake Michigan Monitoring Coordinating Council was established to enhance
coordination, communication, and data management among  agencies and other
organizations that conduct or benefit from monitoring efforts in the Lake Michigan basin
in the interest of supporting the Lake Michigan LaMP. The Council has 31 members
representing Federal, State, Tribal, and local governments, nonprofit watershed groups,
and other environmental organizations, educational entities, and the regulated
community. The Council meets twice each year in locations throughout the watershed.

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Council meetings, biennial conferences, and feedback from constituents shape the
Council's work plan and activities. The Council will develop goals, each with an active
working group, whose broad membership will expand the core Council membership.

In 1999, four short-term working groups were created to develop information to move
the Council forward: Data Inventory and Analysis, Monitoring Objectives, Watershed
Pilots, and Outreach and Collaboration. The progress of those short-term working
groups set the stage for the development of a new Council operating framework in
2001.

The new  Council framework has been developed to increase coordination between
appropriate monitoring entities,  allow the development of a strategic plan for monitoring,
and add value to the individual efforts of the Council's member organizations. The new
Council framework takes advantage of the logical interactions between the various
resource-based monitoring entities and other affected stakeholder groups. The working
groups formed under this new framework will build on the efforts to coordinate
monitoring within individual resources by groups such as the LaMP Committees, the
Wisconsin Groundwater Coordinating Council, and the Great Lakes Fishery
Commission.  Each of these resource based working groups will coordinate existing
monitoring networks around  several common considerations: monitoring objectives;
spatial, temporal and parameter network design; methods comparability; quality
assurance and control planning; database sharing; and data analysis approaches.
Currently, an aquatic nuisance species basin survey is being completed.

Lake Huron

The Lake Huron Binational Partnership is performing many of the activities necessary to
develop a formal LaMP for Lake Huron. Monitoring  is currently coordinated using a
combination of focused domestic studies and binational basinwide approaches.
Canada's Federal-Provincial working group  is pursuing several monitoring activities,
including the Southeast Shore Project, which is investigating causes of beach closings
along the southern Canadian coastline in  Lake Huron.  The U.S. has initiated the Lake
Huron U.S. Agencies Coordination Meeting which has begun the development of a
coordinated monitoring and management plan for the domestic U.S. .  An expected
infusion of resources in FY 2005 will help the U.S. enhance this effort.  Building upon
these domestic efforts, binational data sharing occurs as part of the biennial  progress
reporting under the Lake Huron Binational Partnership. The upcoming Lake Huron
Symposium scheduled for October 2006 in Ontario,  Canada will bring together Lake
Huron researchers for a technical  discussion on the status of the Lake Huron
ecosystem  and will culminate in a peer-reviewed technical report that will inform and
guide future management efforts.  In addition, the Partnership is currently developing
plans for  more extensive coordinated monitoring to take  place in 2007. All of these
efforts are closely linked with the binational efforts of the Great Lakes Fishery
Commission's Lake Huron Teams. Through these efforts, Lake Huron will be
supporting data sharing and monitoring coordination activities which are similar to the
Lake Erie Millennium Network.
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Appendix 1 - Great Lakes Human Health Effects Research Program Studies

Several studies evaluating the health effects of eating fish from various locations within
Great Lakes Basin have been completed or are on-going.  Here are examples of
ATSDR's funded institutions and research topics:

The New York Angler Cohort Study-Exposure Characterization and Reproductive
Developmental Health conducted by John Vena, Ph.D. of State University of New
York at Buffalo

The New York State Angler Cohort Study (NYSACS) is a population-based study
established to assess the association between past and current consumption of
contaminated  sport fish, from the Great Lakes, and short-and long-term human health
effects. The research program's current objectives include:

     Establish a cohort of African-American and Hispanic anglers from the Buffalo
     River and Niagra River.

     Conduct a pilot study of 5th-8th graders and begin development of Great Lake
     Environmental Education and Community Action Initiative.

     Continue the study of the prospective pregnancy cohort study (to include other at-
     risk women) analyzing the relationship between consumption of contaminated fish
     from Lake Ontario and two sensitive reproductive outcomes: time to pregnancy
     and early pregnancy loss.

     Assess biomarkers of exposure and/or susceptibility to dioxin-like compounds and
     biomarkers of immune status.

     Continue the tracing of the entire cohort and conduct passive follow-up through
     vital records.

     Continue to implement dissemination and communications efforts in concert with
     the New York State Health Department.

PCB, DDE, Mirex, and HCB Exposure Among Native American Men and Women
from Contaminated Great Lakes and St. Lawrence River Basin Fish and Wildlife
and Neurological Effects of Environmental Exposure to PCBs conducted by
Edward Fitzgerald, Ph.D. of the New York State Department of Health

An epidemiologic study in an established cohort of American Indians, the Mohawk
Indian Tribe, which investigates the association between the consumption of locally
caught fish and wildlife and body burdens of PCBs , 68 PCB congeners, DDE, mirex,
and HCB in men and women who live along the St. Lawrence River and its tributaries.

In order to investigate the hypothesis that exposure to PCBs via fish consumption, close
proximity to a  hazardous waste site, and other sources has resulted in elevated body
burdens of PCBs and has caused PCB congener-specific and age-specific neurological

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effects, the investigators propose to recruit 75 men and 75 women, 55-74 years of age
from an area with historically high PCB contamination.  They will recruit a comparison
group of equal number, matched to the study population regarding age and gender.
Their objectives are to estimate cumulative and peak dietary and residential exposure of
PCBs among the study population using current and estimated air concentrations. A
questionnaire regarding fish consumption will be used to estimate PCB exposure via
fish. Blood samples from these individuals will be analyzed for 109 PCB congeners
levels and correlated the environmental levels using  "fingerprinting" methods. A
neuropsychological test battery will be performed on the subjects and the investigators
will attempt to correlate with the exposure  estimates  and serum  PCB levels. Serum PCB
levels and neuropsychological function will be compared to a matched control group.

Great Lakes Fish as a Source of Maternal and Fetal Exposure to Chlorinated
Hydrocarbons conducted by Donald P.  Waller, Ph.D. of the University  of Illinois at
Chicago

The purpose of this study is to determine the effects  of consumption from possibly
contaminated fish (PCB's, DDT/DDE and dieldrin) on pregnant woman of African-
American descent and their newborns. The subject population will consist of a control
and a fish consuming group who will be identified at the U. Chicago Lying-in Hospital, U.
Ill Hospital, Miles Square Clinic and Altgeld Gardens Clinic (and possible other area
clinics). The subjects are interviewed and then followed throughout pregnancy to term.
Biological specimen collections consists of maternal  and fetal cord blood, placenta,
breast milk, adipose tissue and meconium. The investigators will evaluate meconium as
a biologic specimen to predict infant  in utero  exposure  to toxic chemicals.

Longitudinal Assessment of Neuropsychological and Thyroid Function in Aging
Great Lakes Fisheaters and a Prospective Study  of Health Outcomes in Asian
Americans Project Description conducted by Susan L. Schantz, Ph.D.  of the
University of Illinois at Urbana-Champaign

The objectives of the proposal are to:

     Complete follow-up neuropsychological assessments of aging Lake Michigan
     fisheaters, statistically analyze the data and prepare manuscripts for publication.

     Establish a cohort of Asian American (Hmong people from Laos and Cambodia)
     men and women of childbearing age who have a high probability of consuming
     contaminated fish from the Fox River and/or other local polluted water.

     Describe the reproductive experiences of this population. Determine fish
     consumption practices of this population.

     Determine the distribution of serum PCB levels in a subset of the cohort.

     Examine changes in serum PCB and serum thyroid hormone levels during
     pregnancy.
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     Evaluate health outcomes in infants born to the women in this cohort.

In the first study the researchers will evaluate cognitive and motor function in aging (50
to 70 plus years old) fisheaters and in their age- and sex-matched non-fisheating
controls. The two groups will be tested using a  neuropsychological assessment battery
designed to detect subtle deficits in cognitive and motor functioning.

In the second study of this research project some of the activities will include
determining the levels of PCBs in mothers' blood during pregnancy and at delivery;
samples will also be collected from the umbilical cord. Mother's blood will also be
examined to assess thyroid status in relation to PCB exposure. The cochlear function
will be assessed in the newborns within 24-48 hours of postnatal age. Physical
measurements (height, weight, head circumference) will be obtained at birth, at 6,  9,
and 12 months. Behavioral assessment will be  done in the newborns (Brazelton
Neonatal Behavioral Assessment Scale) and at 6 and 12 months of age (Bayley Scales
of Infant Development). Cognitive testing will be done at 6 months of age (Pagan Test of
Visual Recognition Memory). Further cognitive testing will be done at 9 and 12 months
of age

Behavioral Effects of Consumption of Lake Ontario Fish: Two Methodological
Approaches - Continuation of A Longitudinal Study Testing 4 and 6 Year Olds
conducted by Thomas Darvill, Ph.D. of State University of New York at Oswego

This is a longitudinal-sequential study involving behavioral testing of three cohorts  of
children born to women from Oswego County, New York, who consumed large amounts
of Lake Ontario sportfish over their lifetime.  Initial data from the Oswego study of
newborns (supported by ATSDR) show that newborns from mothers who consumed
about 40 equivalent pounds of Lake Ontario fish scored more poorly on reflex,
automatic, and habituation clusters of the Neonatal Behavioral Assessment Scale than
those from mothers who consumed 40 PCB equivalent pounds of Lake Ontario fish or
no fish. These data represent the first replication and extension of the neonatal results
of the Lake Michigan Maternal Infant Cohort study by Jacobson et al. (1984). More
recent data from the Oswego project indicate that prenatal exposure to PCBs impairs
cognitive functioning in children as early as  1 and 3 years of age. To date, the
investigators have obtained behavioral data at 3, 6, 12, 24, 36,  51, and 54 months of
age. Funds are requested to continue the assessment of behavioral and cognitive
development of the children in the study as they enter elementary education years
(grade K-2).

Health Risks from Consumption of Great Lakes Fish conducted by Lawrence J.
Fischer,  Ph.D. of Michigan State University

This research grant seeks to continue and expand mercury exposure research
supported by the ATSDR Great Lakes Human Health Effects Research Program. This
research effort will provide additional information needed regarding mercury exposure
and possible health risks to women of childbearing age living in the Great Lakes Basin.
This is important because the developing human fetus is known to be particularly

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susceptible to the neurotoxic effects of methylmercury, the primary form of mercury
present in fish. The proposed research has been divided into 3 subprojects, each with a
specific focus. The subprojects are as follows:

Subproject  1. Determination Using Segmental Hair Analysis of the Time Course of
Exposure to Methylmercury in Pregnant and Non-Pregnant Women: The goal of this
proposed research  is to determine the time course of mercury exposure in pregnant
women throughout the entire period of gestation. Further, non-pregnant women have
been recruited for studies using the same sampling and analytical methodology so that
a comparison between the two groups can be made. This comparison will provide
information on mercury exposure and toxicokinetic differences that may be related to
pregnancy itself.

Subproject 2. Mercury  Hair Levels at Mid-Pregnancy and Risk for Preterm Delivery in a
Cohort of Michigan  Women: The goal of this proposed research is to examine the
relationship between methylmercury and early pregnancy loss in particularly susceptible
populations. This study will also provide mercury body burden data for a population that
has traditionally been understudied, African-Americans.

Subproject 3. Develop  and Implement a Pilot Project for Monitoring the Michigan
Population for Mercury Exposure: A pilot project will be undertaken to investigate the
feasibility of statewide random sampling of Michigan women to determine baseline
mercury levels. Additionally, historical data regarding mercury levels in various species
of freshwater fish obtained through the State of Michigan yearly fish  monitoring effort
will be analyzed to evaluate possible regional differences in fish contamination and to
evaluate  in  a systemic  way, the chronology and  regionality of mercury-related fish
contamination in the State. Results from these studies will permit a much better
understanding offish contamination and consumption as they relate to methylmercury
exposure in women.

Consortium for the Health Assessment of Great Lakes Sport Fish Consumption
conducted by Henry A. Anderson, M.D. of Wisconsin Department of Health and
Family Services.

This project continues to examine the association between sport caught fish
consumption in the  diet of Great Lakes area residents and serum levels of 1) PCBs, 2)
DDE, 3) dioxins, and 4) furans which have been detected in Great Lakes contaminated
fish. The  area residents consist of a cohort of frequent consumers of Great Lakes fish
(charter boat captains and their spouses with n = 1868 households, and Wisconsin
anglers with n = 129 households) and infrequent consumers (n = 1,300 households
from the same community as the captains). In addition, serum  PCB and DDE levels are
being evaluated in the  group to determine if an association exists between the serum
levels and 1) birth outcomes, 2) serum thyroid and steroid hormone levels, and 3)
reproductive outcomes (e.g., semen quality).  Risk communication has also been a
component of the study.

The cohort had blood serum samples drawn for  contaminants and received a phone
interview dealing  with 1) fish consumption, 2) reproductive history, 3) health advisory

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awareness, 4) risk factors (e.g., smoking), and 5) demographic information. Of the
frequent consumers, 1868 households completed the phone interview with more than
500 individuals participating in the blood drawing. Of the infrequent consumers, 1,300
households completed the phone survey and 99 of these individuals had blood drawn.

Results have shown the PCB and DDE levels were higher in frequent consumers of
Great Lakes fish when compared to the infrequent consumers. A pilot study also
revealed that frequent consumers had higher serum dioxin, furan, and coplanar PCB
levels than a comparison group.

Assessing Effects of Human Reproductive Health of PCB Exposure via
Consumption of Great Lakes Fish conducted by Wilfried Karmaus, M.D., MPH of
Michigan  State University

The study  design is a cross-sectional and longitudinal observational assessment of the
effects of PCB exposure, both current and in  utero, on reproductive health. The main
goal of this project is to assess fecundability and reproductive success in two cohort
studies of  individuals selected from two source populations at elevated risk of exposure
to PCBs via consumption of Great Lakes sport-caught fish. A secondary goal is to pilot
a case control study of low sperm count in relation to the same exposures. In the two
cohort studies, investigators aim to examine specific hypotheses about the relationship
of PCB exposure to reproductive health occurring directly through consumption of sport-
caught Great Lakes fish, and  occurring indirectly through in utero exposure. PCB
exposure,  in both the cohort and case-control studies will be assessed by a detailed
questionnaire on fishing practices and through serum analysis for PCBs. To assess
reproductive health in the cohort studies, investigators will examine time to pregnancy,
sex ratio and selected correlates of fertility, including serum levels of testosterone, LH
and FSH in men, and cyclic levels of urinary progesterone, estradiol, LH, and FSH in
women. The first population (Cohort A), which is already assembled and will be
expanded  in the next fiscal year, is a sample  of couples, one or both of whom is a
licensed angler,  and individuals resident in one often Michigan counties abutting one of
three of the Great Lakes. Cohort A consists of couples and individuals who completed a
questionnaire on sports fish eating practices and who indicated plans to have a child
within the  next five years. The second population (Cohort B), to be assembled, consists
of adult offspring of an existing cohort of Michigan anglers interviewed and assessed by
the Michigan Department of Health, starting in the 1970's. In Cohort A, the exposures of
interest will be assessed in the couples themselves; in Cohort B, the exposures of
interest are in the female member of the couple, with emphasis on exposures that are
likely to have occurred while the woman was  in  utero or exposed to breast milk.
Couples from both cohorts who are planning  pregnancies will be followed prospectively.
Specific reproductive outcomes will be assessed in relation to both serum PCB levels
and to self-reported Great Lakes fish  consumption.
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Ojibwa Health Study II - Epidemiology, Laboratory Toxicology, and Outreach
conducted by John Bellinger, Ph.D., University of Wisconsin-Milwaukee

This proposal continues the study of the original Ojibwa Health Study on dietary fish
containing methylmercury and organochlorines (polychlorinated biphenyls and
pesticides) and their correlation with adverse health outcomes. The first three years
(Phase I) of the project focused on setting up the participating Tribes and conducting
laboratory toxicological studies. The second three years (Phase II) continued those
studies with the emphasis on completing sample collections. As part of the proposed
continuation of the study, the investigators will conduct neurobehavioral assessment of
individuals who provide biologic samples because of the known relationship between
high levels offish contaminants and neurologic dysfunction. The next three years
(Phase III) the investigators will complete all chemical analyses on biologic samples and
report the results back to the Tribes. Health promotion and risk communication
strategies will be implemented with the input from The research program will also
support the ongoing Tribal research aimed at monitoring contaminant levels in the local
fisheries run by the different Tribes. The specific aims of the research falls in two
categories: human epidemiology studies and outreach activities.

PCB Congener and Metabolite Patterns in Adult Mohawks: Biomarkers of
Exposure and Individual Toxicokinetics conducted by Anthony DeCaprio, Ph.D.,
State University of New York at Albany

To conduct statistical  analyses of congeners-specific serum PCB data for ~750 adult
Mohawk Indians using multivariate techniques and to compare the results with those for
other published relevant databases to identify unique populations and environmental
variables in the Mohawk cohort.
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