Advisors for a Sustainable Future
  U.S. Governmental Advisory Committee
  Independent Federal Advisors
  on the North American
  Agreement on Environmental Cooperation
                                                                  Jeffrey Wennberg
                                                                  Tel. 802-793-5345

                                                                  Designated Federal Officer
                                                                  Oscar Carrillo
                                                                  Tel. 202-564-2294
                                                May 16, 2011
Committee Members

  Jeffrey Wennberg

    John Bernal

    James Brooks

   Salud Carbajal

     Kirk Cook

   Karen Gallegos
    New Mexico

   Teri Goodmann

  Carlos Rubinstein

   Carola Serrato

  Octaviana Trujillo
 Pascua Yaqui Tribe

    Roger Vintze

   Gerald Wagner
   Blackfeet Tribe
The Honorable Lisa P. Jackson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460

Dear Administrator Jackson:

     The Government Advisory Committee (GAC) to the U.S. Representative to the North
American Commission for Environmental Cooperation (CEC) held its thirty-fifth meeting on
April 14-15 in Washington, DC.

     Special thanks are offered to Michelle DePass, Assistant Administrator for the Office of
Tribal and International Affairs (OITA). Assistant Administrator DePass brought a welcome
and thanks on your behalf and remained with the committees for an extended period during
which we had an excellent dialogue on a variety of issues, including your most recent
response letters. Assistant Administrator DePass also arranged a special breakfast meeting
for the NAC and GAC chairs and tribal representatives to discuss issues that were raised in
the last GAC advice letter and hear concerns specific to tribal nations. This outreach was
very much appreciated by all in attendance.
     We would also like to thank Sylvia Correa, Senior Advisor for North American
Programs in OITA for her presentation at the session.  Sylvia provided an  overview of the
draft Operational Plan, which is the heart of the advice that follows. Sylvia's wealth of
institutional knowledge is always very helpful, especially to our new committee members.
Thanks also to Acting Director Cynthia Jones-Jackson, Associate Director Mark Joyce and
NAC/GAC Designated Federal Officer Oscar Carrillo, and all of the Office of Federal
Advisory Committee Management and Outreach (OFACMO) staff for their excellent
preparatory work.
     Dolores Wesson, formerly of EPA and now Program Director for the CEC, made a
presentation on the draft Operational Plan,  with particular emphasis on the history of
Operational Plan development processes and how the  2011-2012 Plan is a departure from
past practice. As you will note in the advice letter, the GAC very much appreciated Ms.
Wesson's presentation and recommends that the draft Plan is modified to  include some of the
content she shared with the committees.
     Also in attendance and contributing were Rick Picardi of EPA's Office of Solid Waste
and Emergency Response and William Sonntag from EPA's Office of Environmental
Information. Both gentlemen provided background on several proposed CEC projects and
their importance from the perspective of EPA priorities.

    As always, we sincerely appreciate the participation from EPA's Office of International
Affairs and the Office of Federal Advisory Committee Management and Outreach. In
addition to Sylvia Correa of OITA, Cynthia Jones-Jackson, Mark Joyce, Oscar Carrillo,
Stephanie McCoy and Lois Williams from OFACMO staffed and supported our meeting.
    Unlike our fall meeting in New Orleans, which was partially held in common with the
JPAC, the April meeting in Washington B.C. was narrowly focused on the draft Operational
Plan with ample time for joint and separate committee discussion. The GAC hopes our
advice reflects the benefit of this focus and meeting structure.
    In conclusion, we appreciate EPA's continued support of our role in advising the United
States Government on the enhancement of environmental conditions throughout North
America, and look forward to supporting your efforts in the future.

                                      Jeffrey N. Wennberg, Chair
                                      Governmental Advisory Committee
cc:  Michelle DePass, Assistant Administrator, EPA, Office of International Affairs
    Jane Nishida, Director, Office of Regional and Bilateral Affairs
    Cynthia Jones-Jackson, Acting-Director, Office of Federal Advisory Committee
    Management & Outreach
    Oscar Carrillo, Designated Federal Officer
    Karen Chapman, Chair, U.S. National Advisory Committee
    Irasema Coronado, Chair, Joint Public Advisory Committee
    Evan Lloyd, Executive Director, CEC
    Members of the U.S. Governmental Advisory Committee
  Administrative support for the GAC is provided by the U.S. Environmental Protection Agency,
                Office of Cooperative Environmental Management
        Mail Code 1601-M, 1200 Pennsylvania Ave. NW Washington, D.C. 20460
                      (t) 202-564-2294 (f) 202-564-8129

                        Governmental Advisory Committee (GAC)
                             to the U.S. Representative to the
                     Commission for Environmental Cooperation (CEC)

                               April 14-15,2011 Meeting
                                   Washington, D.C.

                      General Comments on Advice 2011-1, 2 and 3

The GAC met in joint session with the NAC on April 14 and briefly on April 15, with the
balance of the meeting on the 15th devoted to GAC deliberations on this response to the charge
questions. The Charge Questions from EPA to the GAC for this meeting were as follows:

The new CEC Operational Plan 2011: This is the first operational plan incorporating the three
priorities outlined in the new CEC strategic plan.

1)  Comment on the substance and format of the operational plan.
    a)  Are the projects aligned with the three Council priorities?
    b)  Is the format user-friendly?
    c)  Any other observations you have on the new plan?

2)  Follow-up on Meeting Discussion: During the April meeting you will have a dialogue with
    EPA officials on the advice you provided in your December advice letter.
    a)  Is there any advice you would like to provide based on your discussions; any new insights
       gained that would further your advice?

The GAC offers this advice organized in three groups: Operational Plan format and presentation,
general observations and comments, and project-by-project advice. While these sets of
recommendations are offered separately they collectively respond to Charge Question number 1
and should be considered together.

No advice is offered on charge question number two. The GAC appreciates Assistant
Administrator DePass' response and has no further recommendations  or insight beyond that
contained in the December letter.

                        Governmental Advisory Committee (GAC)
                             to the U.S. Representative to the
                     Commission for Environmental Cooperation (CEC)

                                     Advice 2011-1:
                  2011 Draft Operational Plan Format and Presentation

The GAC appreciates the organizational plan background and history briefing provided in the
April 2011 meeting which helped members understand why the plan is structured and formatted
in the current fashion. The GAC supports the detail which is contained in each of the project
sections and the requirement that each project be explained in the context of the three Priorities.
The result of the Parties' and Secretariat's joint effort to provide more detail has resulted in
greater transparency. However, an additional result is the plan is now larger and more difficult to
navigate and understand. The GAC recommends the following enhancements to the plan
document, all of which are intended to better communicate the 'sum of the parts' purposes and

   1.  Provide a brief (2-3 page) Executive Summary. The Executive Summary should not
       include project-specific detail. Rather, it should (a) summarize the process by which the
       plan was developed,  (b) state the broad purposes or goals it seeks to serve,(c) reinforce
       the project selection criteria and (d) briefly describe any significant departures from prior
       plans. Long-standing projects that are being terminated should be identified with
       explanation of whether and how the work may continue outside the CEC. New initiatives
       should be identified with a brief rationale for their elevation to funded status. Also, a
       discussion of significant budgetary information would be useful.

   2.  Provide a matrix showing critical information about all the projects on a single
       page. The matrix would have the projects listed in the rows and attributes in the columns.
       For example, the three priorities of Healthy Communities & Ecosystems, Climate Change
       - Low Carbon Economy, and Greening the Economy in North America could each have a
       column. This snapshot would summarize projects and identify the multiple priorities
       being supported, and not simply categorizing them by a single priority as was done in the
       draft plan. The GAC noted that project #10 Ecosystem Carbon Sources and Storage:
       Information to Quantify and Manage for Greenhouse Gas Emissions Reductions served
       both Climate Change - Low Carbon Economy and Healthy Communities & Ecosystems,
       even though it was categorized under climate change. Subsets of strategic objectives
       within a priority could also be identified. Additional attributes could include whether the
       project is a continuation of past work or a new initiative, the expected life of the project,
       partners or key resources the project will engage or require, linkages with other proposed
       or past CEC projects or activities, project budget, etc. A sample matrix is shown below.


North American Capacity Building
Framework Document
Alaskan Populations and Indoor Air
Big Bend- Rio Bravo
Tracking Chemicals
Risk Reduction
Environmental Monitoring
Environmental Law Enforcement
Improving Comparability
Carbon Sources
Platform on Climate Change
Green Building
Greening Auto Supply Chain
Tracking Pollutants
Healthy Communities and

s .


Law Enforcement

Change - Low
Comparability of
Emissions Data

Experts' Engage-
ment & Infor-
mation Sharing

Greening the Economy

Final Work


Initiative or

Year of

with Other

Parthers or

3.  Provide a life cycle chart for current and proposed projects. In her PowerPoint
   presentation CEC Director of Programs Dolores Wesson provided the graphic shown
   below. GAC members found this to be very helpful and consistent with past
   recommendations offered by the committee. The GAC believes such a graphic should be
   included in this and all future operational plans. The GAC recommends that additional
   columns beyond 2012 be added indicating the life expectancy of the project. Some
   graphic indication should be made to clearly indicate which years are covered by the
   operational plan and budget and which extend into the future and are therefore
   speculative and subject to future Council approval. If necessary, a disclaimer noting
   budgetary constraints can be included.

CEC Projects
North American Atlas
State of the Environment Report
Environmental Assessment of NAFTA
Healthy Communities and Ecosystems
Capacity Building in Vulnerable Communities
Improving Indoor-air Quality in Alaskan Native Populations
Big Bend - Rio Grande Transboundary Landscape Conservation
Invasive Species
North American Pollutant Release and Transfer Registers
Environmental Monitoring and Assessment of Pollutants across NA
Sound Management of Chemicals
Air Quality Information and Management
Strengthening Wildlife Enforcement
Trade and the Enforcement of Environmental Laws
Species and Spaces of Commons Concern (marine, terrestrial)
Monarch Butterfly
Recovering Vaquita
Climate Change - Low-Carbon Economy
Improving Comparability of Emissions Data
Ecosystem Carbon Sources and Storage
NA Online, Interactive Informational Platform on Climate Change
Greening the Economy in North America
Green Purchasing
Conserving Biodiversity Through Trade
Renewable Energy
Environmental Sustainability and Competitiveness in NA
Clean Electronics/ E-waste
Greening Supply Chains (SMEs, Auto Sector)
Green Building









                         Governmental Advisory Committee (GAC)
                              to the U.S. Representative to the
                     Commission for Environmental Cooperation (CEC)

                                     Advice 2011-2:
                       2011 Draft Operational Plan General Advice

The GAC offers the following general comments on the Operational Plan development process
and document. Project-specific advice is offered in Advice 2011-3, below.

For a number of years the GAC has urged the United States to advocate that the Parties assume
greater control over the development of the Operational Plan. In the past the Operational Plans
were generated by the working groups and Secretariat staff and worked their approvals up
through the organization, ending with Council. The GAC appreciated the value of having front-
line knowledge and expertise guide the previous drafts but was troubled by the perception that
the end product promoted the continuation of the status-quo rather than embrace the evolving
strategic priorities of the Council.  For the first time the 2011-2012 Operational Plan fully
embraces this advice and the GAC deeply appreciates the substantial effort the Parties undertook
to accomplish this.

The draft 2011-2012 Plan is therefore a departure from its predecessors, with projects reflecting
the engagement of the Parties and furthering the three strategic priorities. The Plan document,
however, provides only budget information and project descriptions and justifications. The larger
context and rationale for the selection of these projects  is not presented. This leaves the reader to
speculate on how and why certain projects are funded and others are not. Prior Operational
Plans clearly presented the rationale for project funding but failed to connect all the projects with
Council priorities; the 2011-2012 Operational Plan clearly connects projects with Council
priorities but does not present the selection criteria, process or rationale.

The GAC recommends that in addition to the document enhancements proposed in GAC Advice
2011-1, the Operational Plan document  include a section following the Executive Summary and
the budget tables to provide this needed context. This section should contain a description of the
process used by the Parties to propose, consider and select projects. It should identify the
General Standing Committee as the entity that received, evaluated and proposed the projects. It
should list and explain the evaluation criteria used by the GSC:

1) Consistency with the Strategic Plan
2) North American scope
3) Results - clear and tangible
4) Agency - CEC most effective
5) Timeline - clear & sunset
6) Identify:
   a) Links with other projects
   a)  Target audience and application
   b) Beneficiaries
   c)  Stakeholder involvement

The overview section should describe the internal CEC process used for the selection, review
and approval of projects. This information was contained in the presentation by Dolores Wesson
and the slide graphically depicting the process is repeated here:
        Operational  Planning Process for 2011-2012
Steering Committees (SCs)
 January guidance,
 nomination of 7 SCs
 136 government
      Development of 23 projects, January - February
 14 projects selected and revised
 with lead drafters, March
 GSC clearance of 14 projects for
 JPAC review, 24 March
                                       Revisions to 14 projects, March
                                                    14 project
                                                    descriptions sent to
                                                    JPAC, 25 March
                                                  JPAC/public review, 28
                                                  March-27 April
 Council considers
 JPAC advice
 Council approves OP
 week of 16 May
               Implementation of OP11-12
                                                                 JPAC advice transmitted to Council
                                                                          6 May
The GAC also believes that with greater transparency regarding how the selections are made
comes the opportunity to offer advice and comment on the process itself. Advisory committee
and stakeholder input on the criteria and process should be invited and considered prior to the
development of future Operational Plans.

Efforts should also be made to quantify the expected benefits derived from CEC projects where
such quantification is possible. Local and state governments are regularly tasked to estimate the
health, economic or fiscal benefits of proposed investments so that the results can be measured
against those projections. Several of the proposed projects appear to lend themselves to this
approach but have not been proposed or presented in this fashion. The GAC recommends that
project proposals include this type of analysis wherever possible, and identifies several specific
opportunities in Advice 2011-3.

In reviewing the specific projects the GAC  repeatedly observed that work similar to that
described in the Plan has been or is being undertaken by others. In some project descriptions

there is an early task calling for research to identify such work and incorporate its availability
into the detailed design of the project, but this is not found in all. The GAC believes that there is
a great deal to be learned from  similar work undertaken by federal agencies, states and
provinces, NGOs, universities and private entities and recommends that every effort be made to
identify and assemble the results of this work before launching a new project. The collection of
this information will allow the  CEC to identify analytical or programmatic gaps or opportunities
to harmonize disconnected projects and as a result maximize the benefit of the CEC's

The GAC noted that the projects under the second priority, Climate Change - Low Carbon
Economy, are mitigation-focused; scant attention is given to the challenge of climate adaptation
here or elsewhere in the Plan. Many local and state jurisdictions throughout North America are
rapidly concluding that unavoidable climate change expected to occur over the next several
decades will present new challenges to infrastructure, ecosystems, agriculture, human health and
economic growth. The GAC recommends that the Parties elevate addressing climate adaptation
within the second priority objectives. Toward that end the GAC recommends that all the projects
within the Operational Plan be  reviewed for opportunities to incorporate these concerns. Specific
GAC suggestions can be found in Advice 2011-3.

The GAC notes that a number of the projects call for assembling officials or experts to discuss or
develop plans and strategies, and to facilitate better coordination among the three Partners'
agencies  and departments. The GAC is aware that the CEC has made good use of electronic
meetings (webinars and teleconferences) in the past and encourages a review of travel and
related budgets in this operational plan to ensure that the CEC makes maximum practical use of
this technology.

Finally, given the broad scope and very limited budget available to the CEC, the GAC restates
advice offered in prior letters and recommends that the United States support limiting the number
of projects undertaken at any one time to avoid diluting efforts and to enhance opportunities for
advancing projects.

                         Governmental Advisory Committee (GAC)
                              to the U.S. Representative to the
                     Commission for Environmental Cooperation (CEC)

                                     Advice 2011-3:
             2011 Draft Operational Plan Project-Specific Recommendations

Project 1: Capacity Building to Improve the Environmental Health of Vulnerable Communities
in North America

This project is a good example of the principle mentioned in Advice 2011-2 above pertaining to
similar work completed or undertaken by others. While the project summary acknowledges and
identifies existing tools, data sources and best practices, the five tasks do not include a step
designed to research these and other opportunities. The GAC believes that a great deal of related
work has been done by NGOs and others and recommends that the framework development
process not begin until a complete understanding of the work performed by others is achieved.

The Environmental Outcome statement is a restatement of the project's purpose. This project
might lend itself to some quantification of expected benefits,  at least as an illustration of the
project's potential  if not a prediction of global benefits. For example, under existing tools several
Canadian programs are mentioned. Have any of these been evaluated to show reduced incidence
of disease or mortality? If so, this information could be used in the "outcome" section to
illustrate the potential health outcomes or economic savings benefits of the project proposal.

The GAC believes this project is particularly well suited to also address climate adaptation,
especially to the degree that a changing climate will present new or amplify existing
environmental hazards or susceptibility to them. Most climate models show for many regions an
increase in the number and duration of heat waves, increased frequency and intensity of storms,
and significantly altered rainfall patterns. These changes in weather patterns are likely to directly
(as is the case with heat waves) or indirectly (as is the case with  expanded ranges for disease)
alter human health environmental stressors. The study of variables that influence the
vulnerability of individuals, communities or populations should include these factors as well as
the identification of appropriate risk mitigation measures.

Project 2: Improving Indoor Air Quality to reduce exposure to airborne contaminants including
fine particulates and chemical compounds in Alaskan Native Populations and other Indigenous
Communities in North America

This project is a good example of a well-defined project with measurable outcomes. The GAC
had some question about whether the CEC is the best entity to fund the project. After a
discussion of the unique circumstances facing these Alaskan Native communities the GAC
concluded that the  CEC was an appropriate funder for this project, and that the project clearly
addressed the first  strategic priority.  The GAC would like to see a stronger emphasis on how the
lessons learned could be applied elsewhere in Canada, the US and Mexico, and where permanent
funding might be found for similar projects going forward.

Project 3: North American Grasslands: Management Initiatives and Partnerships to Enhance
Ecosystem and Community Resilience

The GAC supports this extension of the CEC's excellent grasslands program, but believes that
some of the work proposed in this project has been undertaken by others, notably the NRCS, the
Nature Conservancy, DOT, BLM and USGS. Therefore Task 1, which seeks to coordinate,
synthesize and disseminate information regarding best practices from ranching and related
industries, appears too narrowly defined. The GAC recommends a comprehensive review of all
related efforts before undertaking potentially duplicative tasks. Furthermore, the GAC believes
the following assertion in the Project Summary is wrong, or at best overstated: "To date, best
management practices and actions have been lightly developed, poorly coordinated and are not
explicitly linked to research that demonstrates the biodiversity value and sustainability of these

The GAC supports continued work in this area and very much appreciates the value of past CEC
grasslands work; however we believe the state of knowledge in this field is better than
represented in the project summary and want to make sure scarce CEC funds are used to expand
our understanding and improve conservation efforts, and not to duplicate work done by others.

The GAC notes that the development of accepted methods for quantifying carbon sequestration
values for managed grasslands would be of value. Accounting for carbon sinks is a critical need
if we are to make reliable projections of future atmospheric CC>2 concentrations and whether and
when GHG mitigation measures will achieve targets tied to atmospheric concentrations. As such
the GAC believes this project should be classified on the proposed matrix as serving both
Priority 1  and Priority 2.

Project 4: Big Bend-Rio Grande Collaboration for Transboundary Landscape Conservation

The GAC applauds the inclusion of this project in the Operational Plan. The GAC has been
calling for the CEC to become more involved in water-related issues and projects for a number
of years and sees the Big Bend-Rio Grande Collaboration project as a superb example. The
project is presented with specific tasks  and objectives well thought out and described. The GAC
suggests that the description of environmental outcomes  could contain more measurable goals,
for example, "recruiting additional landowners for implementing grassland restoration;" could
specify a target number or percentage increase, and "improving the status of the Rio Grande
silvery minnow;" could specify some metric by which an improvement could be tested.

The project as described represents a monumental undertaking, but the GAC is aware of
opportunities for partnerships that should help. In addition to those mentioned in the Operational
Plan, the GAC specifically suggests the International Boundary & Water Commission (IBWC),
and in particular the Texas Clean Rivers Program, which has collected water quality data
throughout the Texas portion of the Rio Grande Basin. The bilateral solutions developed by the
IBWC for the U.S./Mexico border region have potential for application to the U.S./Canada
border and to tri-lateral water-related issues.

Project 5: Approaches for identifying and tracking chemicals in commerce in North America

Project 6: Risk reduction strategies to reduce the exposure to chemicals of mutual concern

Project 7: Environmental Monitoring and Assessment of Chemicals of Mutual Concern

These projects are a continuation of the Sound Management of Chemicals program within the
CEC, which has been one of the most successful efforts the CEC has undertaken. The
environmental outcome statements for projects 5 and 7 are specific and measurable. The
environmental outcome statement for project 6 could be improved to include a measurable
outcome, or at least an illustration from related efforts of the potential benefit.  The information
developed under project 5 and related chemicals tracking projects needs to be readily available to
states, localities and tribal nations. This is already the case in the U.S. and Canada, but is not yet
the case in Mexico.1 Task 1 seeks to complete work on the Mexican National Chemicals
Inventory. Once completed, similar information should be publicly available for all three nations.
The GAC supports these projects and the overall extension of SMOC program activities.

Project 8: Enhancing Environmental Law Enforcement in North America

The GAC supports this project and notes support for related efforts in earlier advice, however the
project description is unclear, the objectives are not measurable and the scope of the effort is
fragmented and confusing. GAC members who have been on the committee for a number of
years and attended earlier briefings were able to explain the project to new members, but without
that supplemental information the new members would not have been able to grasp the purpose
or benefit of the project from the Operational Plan.

The GAC recommends that the description of Project 8 be rewritten to resolve this problem.
Furthermore, the Environmental Outcome  section lacks any measureable metric  by which
progress can be judged. Of all the projects in the Operational Plan, the interdiction of illegal
shipments of environmentally-regulated materials is not only measureable, it is measured.
Simply stating that the project will "increase the number of non-compliant targets identified"
fails to take  advantage of this statistic. By how much will the number increase? When should the
benefits of the project become apparent?

Project 9: Improving Comparability of Emissions Data, Methodologies and Inventories in North

This is a continuation of the project authorized prior to the development of the Operational Plan
that was originally proposed by the  GAC in earlier advice. The GAC recognizes  the continuing
value of this effort however the project description does not incorporate or explicitly consider
work done by others. The Climate Registry, which has members in Canada,  the US and Mexico,
has studied these issues and offered guidance. On several key standards the Regional Greenhouse
Gas Initiative in the US Northeast, the Western Climate Initiative, which covers  most of Canada
and the Western US, and the Midwest Governors' Accord have prepared joint guidance for their
programs. The New England Governors/Eastern Canadian Premiers organization has also studied
harmonizing data, methodologies and inventories between the US states and Canadian provinces.
1 U.S.:


At a minimum a review of this work should be incorporated into the CEC work plan for Project
9, and perhaps the project plan should include bringing these organizations into the discussions.

Project 10: Ecosystem Carbon Sources and Storage: Information to Quantify and Manage for
Greenhouse Gas Emissions Reductions

As is the case with Project 9, this effort should incorporate the work already done by the New
England  states, the West and Midwest  and by universities and government agencies. This project
is a good illustration of the recommendation made under Advice 2011-2 concerning work done
by others. The project should begin with a thorough review of the work already done and an
analysis of the issues, focusing on disparities and gaps. Priorities for CEC research and
coordination can then be set with some confidence that the CEC investment is adding real value
to the larger effort to resolve these questions.

Project 11: North American On-line, Interactive Informational Platform on Climate Change

GAC committee members present agreed that this project (when completed) could be of
immense value to the Parties2. In fact,  one committee member was aware of at least one
privately funded endeavor attempting to develop a similar project in scope and end result. Much
like the previous comments on other projects, the GAC believes exploration of partnerships with
other entities should be explored for leveraging the resources necessary to complete the project
in a timely fashion; and ultimately satisfying the demand for this completed work project, a
demand that the committee perceived to be present today. The committee took note of several
well-known on-line Climate Change platforms of varying types that exist already, and while
none match the exact description for this project, the members thought communication with
those responsible for them should be a  priority very  early in the project scheme.

Project 12: Improving Conditions for Green Building Construction in North America

This project description is not clearly written; but, the goal of the project is valuable. This is
essentially a project that will assemble  key tri-lateral officials to prepare a follow-up project
work plan with measurable goals and objectives for  future consideration by the Council. The
GAC will reserve specific comment until the results of this effort are available, except to note
that experience in states and communities has demonstrated that the biggest employment,
economic and environmental benefits tend to be found in "green" retrofits of existing buildings
rather than new construction.

Project 13: Improving the economic and environmental performance of the North American
Automotive Industry Supply Chain

This project is an extension of the CEC's past successful efforts in this area. The project
description identifies multiple metrics by which progress can be measured but does not state a
measureable goal or environmental outcome, nor does it use a quantified measure of past success
as an illustration of the project's potential.
 : GAC Chair Jeff Wennberg recused himself from this discussion due to a potential conflict.


Project 14: Tracking Pollutant Releases and Transfers in North America (North American PRTR

This is a continuation of the North American PRTR project and is supported by the GAC. The
project summary and environmental outcomes do not contain measureable goals or objectives.
Given the past success of these CEC efforts it would seem possible to identify measures by
which the level of future success could be gauged.