Water Pollution: Improved Coordination Needed to Clean Up the Great Lakes

Published by the Government Accountability Office on 1990-09-28.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

   Uesonrces,   Community,   and
   Economic Development Division


   September 28,1990

   The Honorable Henry J. Nowak
   Chairman, Subcommittee on
     Water Resources
   committee on Public Works
     and Transportation
   House of Representatives

   Dear Mr. Chairman:

   As you requested, we have reviewed the progress the Environmental Protection Agency’s
   (EPA) Great Lakes National Program Office has made in (1) defining its role within EPA and
   involving other EPA offices in implementing the Great Lakes Water Quality Agreement and
   (2) coordinating the efforts of other federal agencies. Our report also discusses other key
   issues affecting efforts to resolve the Great Lakes’ water quality problems.

   Unless you publicly release its contents earlier, we wiI1 make this report available to other
   interested parties 30 days after the date of this letter. At that time, we wilI send copies to the
   Administrator, Environmental Protection Agency; the Secretaries of the Army, the Interior,
   Agriculture, and Commerce; the Commandant, U.S. Coast Guard; the Director, Office of
   Management and Budget; and other interested parties.

   This work was done under the direction of Richard L. Hembra, Director of Environmental
   Protection Issues, who may be reached at (202) 275-6111. Other major contributors are listed
   in appendix III.

   Sincerely yours,

I/d J.Assistant
        Dexter Peach
                Comptroller General

                  More than 45 million people from the L’nited States and Canada rely on
                  the Great Lakes for a variety of uses,including drinking water. How-
                  ever, the water quality of the Great Lakes and their tributaries has dete-
                  riorated over the years becauseof industrial development, urbanization,
                  and agricultural activities. To deal with this problem, the U.S. and Cana-
                  dian governments entered into the Great Lakes Water Quality Agree-
                  ment in 1972. Later revisions strengthened the Agreement as awareness
                  grew about the dangers of toxic pollutants in the lake. The Environ-
                  mental Protection Agency (EPA), through its Great Lakes National Pro-
                  gram Office (Program Office). oversees and coordinates the fulfillment
                  of the IJnited States’ obligations under the Agreement.

                  Reflecting concern about the ability of the Program Office to fulfill its
                  mission, the Chairman. Subcommittee on Water Resources, House Com-
                  mittee on Public Works and Transportation. asked GAO to examine the
                  progress the Program Office has made in (1) defining its role within EPA
                  and invoh$ng other EPA offices in implementing the Agreement and (2)
                  coordinating the efforts of other federal agencies. GAO also discusses
                  other key issues affecting the Great Lakes’ water quality.

                  The Great Lakes Water Quality Agreement contains 17 annexes defining
Background        the specific programs and activities the two governments have agreed to
                  undertake. A key annex calls for the preparation of plans to ensure that
                  programs to rehabilitate the Great Lakes’ water quality are developed
                  and implemented. Remedial Action Plans define actions and timetables
                  for restoring water quality in 42 “areas of concern” in the Great Lakes
                  Basin of both the United States and Canada The development of these
                  plans involves all pertinent agencies.communities, and programs.
                  Whereas these plans focus on specific near-shore areas, Lakewide Man-
                  agement Plans serve the same function for open lake waters.

                  In 1978. ~~4’s Region V (Chicago) office established the Program Office
                  as the focal point to plan, coordinate. and oversee cleanup efforts by EPA
                  divisions, other federal agencies, and the Great Lakes states. As GAO
                  noted in a 1982 report on efforts to clean up the Great Lakes (~~~82-63,
                  May 21,1982), however, the Program Office was continually frustrated
                  in its attempts to accomplish these objectives. GAO noted that the Pro-
                  gram Office did not have a clearly defmed role within EPA and that its
                  contacts within EPA were largely limited to Region V, even though
                  Regions II (Sew York) and III (Philadelphia) also had responsibilities
                  regarding the Great Lakes. GAO also noted that the Program Office
                  needed to improve its coordination with other federal agencies and
                  states, and to solicit their support in implementing strategies for
                  improving the Great Lakes’ water quality.

                   Page 2                                        GAO/RCELbshl97   Water Pollotiom
                            Reflecting similar rmncems by the Congress, the Water Quality Act of
                            198i formally required the Program Office to ( 1) identify problems
                            regarding the Great Lakes. (2) coordinate the activities of organizations
                            that could help solve these problems, and (3) reprt to the Congress on
                            progrc% made in implementing the Agreement.

                            In rtbcent years, the Program Office has taken steps to improve its visi-
Results in Brief            bility and its coordinating role within EPA by expanding its contacts with
                            both headquarters and regional offices In addition, the Program Office
                            establish4 the Great Lakes Advisory Committee in 1989 to further
                            improve ccH)rdination within EN. The committee includes representation
                            from all rhe key EM offices having responsibilities that affect the water
                            qualit > of t ht* Great Lakes.

                            The Program Office has also improved its coordination with agencies
                            outside EI:\ that can affect the Great lakes’ water quality. In particular,
                            the Office reached agreement with other agencies on how to implement
                            many of the annexes and established the U.S. Policy Committee-a
                            group consisting of senior officials from many federal and state agencies
                            and other groups-to advise the United States on how to best address
                            the Agreemenr. While these efforts have helped to achieve progress on
                            most of the annexes, the development of Remedial Actian Plans and
                            Laktwide Management Plans-key steps toward cleaning up the Great
                            Lakes-is far behind schedule.

                            1Vhile improvements in the Program Office’s operations should help, a
                            much larger effort is needed to address the serious pollution problems
                            affecting the Great Lakes. Even the difficult challenge of developing
                            Remedial Action Plans and Lakewide Management Plans, which will
                            involve substantial commitments of tilme and resources by many organi-
                            zations. are just initial steps in planning the cleanup. Carrying the plans
                            out will take decades and will require more effective pollution control
                            programs by EPA and both the public and private sectors.

Principal Findings

Steps to Improve Internal   The Program Office has taken several steps in recent years to improve
                            coclrdination within EPA at both the regional and the headquarters level.
EPA Coordination            At the regional level. the Program Office has (1) expanded its contacts

                            Page :I
                           E%tcutive summuy

                           with Regions II and III and (2) increased its funding of Region II
                           projects, thus attempting to change the perception within EPA that the
                           Program Office is merely an extension of Region V. At the headquars
                           level, the Program Office has worked with the Office of Marine and
                           Estuarine Protection and individual estuary programs to help develop
                           policies and activities directly affecting the Great Lakes. It has also
                           entered into agreements with EPA’S Office of Research and Development
                           to fund a variety of research projects on the Great Lakes.

                           ,Vevertheless, greater coordination with other headquarters offices was
                           needed, since the Program Office’s mandate was to develop a compre-
                           hensive “ecosystem” approach that considers all sources of pollution
                           affecting the Great Lakes. Accordingly, the Office established the Great
                           Lakes Advisory Committee in 1989. While the number of headquarters
                           offices with key programs affecting the Great Lakes was initially lim-
                           ited, the Administrator added other key EPAoffices in April 1990.The
                           Office of Air and Radiation was added, for example, because the atmos-
                           phere contributes toxic chemicals tc the Great Lakes.

Enhanced Coordination in   Improved coordination and cooperation beLween the Program Office and
                           other federal agencies hb. e resulted in progress in meeting many of the
Plan Development Is        Agreement’s annexes, including annexes intended to help resolve con-
Needed                     taminated sediment, airborne toxic substances, and other problems.
                           However, the completion of the most important and difficult annex,
                           which calls for the development of Remedial Action Plans and Lakewide
                           .Management Plans, has been delayed for years.

                           Representatives from state and local agencies and public interest groups
                           engaged in developing these key plans maintain that the Program Office
                           needs to be more involved to speed their development. However, Pro-
                           gram Office staff told us that while they are augmenting their role some-
                           what, (1) resource limitations prevent the Office from doing
                           substantially more to advance these plans beyond providing basic gui-
                           dance and some technical assistance, (2) the task is primarily a responsi-
                           bility of state and local governments through implementation of their
                           water pollution contro1 programs, and (3) EPA’S three Great Lakes
                           regions should also play a larger role than they have in the past.

                           CAObelieves that because of the importance of developing plans to clean
                           up the Great Lakes- and the lack of progress in achieving this objec-
                           tive-these issues need to be resolved. The U.S. Policy Committee, cre-
                           ated in 1989 to recommend ways to improve coordination and

                           Rgt   4                                        Gio/ltcED#1B7   w&au Pou?lh
                      cooperation among federal and state agencies and environmental groups
                      as they implement the Agreement, appears to be uniquely situated to
                      help resolve this disagreement. Indeed, officials from the Program Office
                      and other agencies who are members of the Committee told GAO that
                      such a role would be appropriate for this newly formed Committee,
                      since it already brings together the federal, state, local, and other inter-
                      ests that will ultimately be involved in cleaning up the Great Lakes.
                      They also agreed that whiIe the Committee was initially established by
                      the Program Office, it operates with considerable independence, which
                      would enhance the credibility of its recommendations.

Xeanup of the Great   Even though progress has been made in completing the annexes,
                      cleaning up the Great Lakes will be costly and will take well into the
akes Will Be Costly   next century. The Program Office can play an important role in this
                      effort by helping to coordinate the efforts of organizations at all levels
                      of government and by providing direct technical support in certain
                      instances. However, the Program Office’s potential contribution should
                      be evaluated in the context of the enormous task at hand. Ilhstrating
                      the enormity of this task, a recent GAO report (GAOIRCED~~I~~, Aug. 10,
                       1988) estimated that it would cost over $1.8 billion to bring Michigan’s
                      Rouge River, one of the 42 areas of concern, up to public health stan-
                      dards by the year 2005. Realistically, therefore, success in cleaning up
                      the Great Lakes will depend much more heavily OFthe level of commit-
                      ment and resources the nation and the Great Lakes region are willing to
                      devote to the effort.

&commendations        problems of the Great Lakes, and in particular to speed progress on the
                      development of Remedial Action Plans and Lakewide Management
                      Plans, GAO recommends that the EPA Administrator request. that the U.S.
                      Policy Committee assess,identify, and recommend appropriate roles and
                      responsibilities for the Program Office and other organizations in devel-
                      oping these plans.

lgency Comments        erally agreed with its accuracy. Their comments have been included
                       where appropriate. However, as requested, GAO did not obtain official
                       comments on a draft of this report.

Executive Summary
Chapter 1                                                                                             8
Introduction                Pollution Problems in the Great Lakes
                            Great Lakes Water Quality Agreement and Subsequent
                            Creation of EPA’s Great Lakes National Program Office                    11
                            Objectives, Scope, and Methodology                                       14

Chapter 2                                                                                            16
StepsTaken to               GINPO’s Role Within EPA Expanded by 1987 Water
                                 Quality Act
Improve GLNPO’s             Efforts Made to Improve Coordination With EPA                            17
Coordination Within              Headquarters
                            EPA Regional Involvement Has Expanded and Improved                      18
EPA                         Conclusions                                                             20

Chapter 3
Greater EPA                 GLNPO’s Coordination With Other Agencies Initially
                                Centered on IX
Invokezxnt Needed           U.S. Policy Committee Established to Improve                             22
in Coordinating                 Interagency Coordination
                            GLNPO Has Coordinated With States and Other Agencies                     23
RemedialAction plans            in Implementing Annexes, but Key Plans Are Behind
                            Improvement in Gathering Information From Federal                        29
                                Agencies for Annual Report
                            Conclusions                                                              30
                            Recommendation                                                           31

Chapter 4                                                                                            32
XNPO in Perspective: Restoring the Great Lakes’ Water Quality Is a
                         Monumental Task
Zeaning Up the Great Government Programs Need to Limit Toxic Discharges                              33
LakesWill Be Costly      More Effectively
md Will Take Decades Conclwiom

                             P8ge 6                                     GA0/llcxwm197   water Pollution
ppendixes   Appendix I: GLNPO Or@niiMoti      Chart
            Appendix II: Federal Agencies With Key Roles in the
                Cleanup of the Great Lakes
            Appendix III: Major Contibutors to This Report

igures      Figure 1.1: The Great Lakes Basin
            Figure 1.2: Areas of Concern in the Great Lakes Basin


            DDT       dichlorodiphenyltrichloroethane
            EPA       Environmental Protection Agency
            GAO       General Accounting Office
            GLIWO     Great Lakes National Program Office
            LJC       International Joint Commission
            LMP       Lakewide Management Plan
            No&L4     National Atmospheric and Oceanic Administration
            NPDES     Kational Pollutant Discharge Elimination System
            Fa        polychlorinated biphenyl
            RAP       Remedial Action Plan
hapter 1

‘ntroduction                                                                                     .

                                  The five Great Lakes-Superior, Michigan, Huron, Erie, and Ontario-
                                  together form the largest freshwater system on earth. The Great Lakes
                                  represent 20 percent of the world’s and 95 percent of the United States’
                                  supply of fresh water. Approximately 23.5 million people use 3 billion
                                  gallons of fresh water each day from the Great Lakes for domestic pur-
                                  poses. In addition, more than 46 million people in two Canadian prov-
                                  inces and eight U.S. states rely on the Great Lakes for economic,
                                  recreational, and aesthetic benefits (see fig. 1.1).

lure 1.1: The Great Lskos Basin

                                  PIge 8                                        GAO,‘lICED~I97       Waer Pollution
                        chapter 1

                        Years of urbanization, industrial development, and agricultural activi-
ution Problems in       ties have impaired the water quality of the Great Lakes. While progress
Great Lakes             has been made in alleviating certain problems, concerns over high levels
                        of toxic contaminants found in the lakes raise serious questions about
                        their future.

                        The most significant improvement in the Great Lakes’ water quality in
                        recent years resulted from reductions in phosphorus contar&ation.
                        Phosphorus causes excessive algae growth, which greatly reduced the
                        fish populations in the Great Lakes. In fact, at the peak of the phos-
                        phorus problem, scientists feared that parts of Lake Erie would no
                        longer be able to support fish life. However, the construction of sewage
                        treatment plants, reduction of phosphates in detergents, and control of
                        runoff from rural and urban areas around the Great Lakes significantly
                        reduced the level of phosphorus.

                        The phosphorus problem, however, increased concern for the Great
                        Lakes and led the way to an awareness of the dangers posed by toxic
                        contaminants. Toxic contaminants come from many sources and are
                        more difficult to detect than phosphorus. Furthermore, many of the
                        effects of toxic contaminants, and the best ways to reduce their pres-
                        ence, are still unhewn. However, scientists do know that these sub-
                        stances pose significant threats to wildlife and human health. Many
                        species in the Great Lakes have been harmed or eliminated, including
                        bald eagles, gulls, and otters. Regarding human health, ahzming results
                        were reported from a recent study on long-term exposure to low levels
                        of toxic substances. The study concluded that babies born to mothers
                        who ate contaminated fiih from the Great Lakes are more likely to be
                        born prematurely, weigh less, have smaller head sizes, and exhibit
                        slower emotional responses than babies whose mothers ate little or no
                        contaminated fish. In addition, other research studies on human health
                        indicate adverse effects from eating fish from the Great Lakes, including
                        the increased risk of cancer.

                         In 1909, recognizing their mutual interests in the Great Lakes and other
at Lakes Water           boundary waters, the United States and Canada signed the Boundary
dity Agreement           Waters Treaty, which gave both countries equal rights to use the water-
i Subsequent             ways that cross the international border. The Treaty also established
                         the International Joint Commission (IJC), a permanent biiational agency
isions                   organized to resolve and prevent disputes concerned with the waters
                         along the Canada-United States border.                      f-     l   >

                         Page 9                                        GAOV197            Wder Pollution
chapter I

An increased concern over contaminants in the Great Lakes prompted
both the U.S. and Canadian governments to sign the first international
Great Lakes Water Quality Agreement in 1972 to restore and maintain
the chemical physical, and biological integrity of the waters of the
Great Lakes. The Agreement focused on controlling pesticides as a pin-
cipal means of dealing with toxic pollution.

The two countries signed a new Great Lakes Water Quality Agreement
in 1978, which was revised in 1983. The 1978 Agreement reflected an
increased understanding of the scope of pollution problems in the Great
Lakes. It called for (1) controlling all toxic substances that could
endanger the health of any living species and (2) restoring and
enhancing water quality throughout the entire Great Lakes Basin. The
 1983 supplement added the requirement to further limit phOsphOi?Jsdis-
charges and prepare and implement plans for reducing phosphorus.

Revisions to the Agreement in 1987 added requirements for the two
countries to prepare Remzdiai Action Plans (RAPS)to address pollution
problems in certain designated “areas of concern.” Areas of concern are
geographic areas in the Great Lakes Basin that have failed to meet the
objectives of the Great Lakes Water Quality Agreement and where such
failure has caused. or is likely to cause, impairment of beneficial uses.
IX has identified 42 such areas in the Great Lakes Basin-2.5 in the
United States, 5 shared by the United States and Canada, and 12 in
Canada (see fig. 1.2).

 m were to define actions and timetables for restoring water quality in
 these areas. Similar plans-Lakewide Management Plans (Lvrs)--were
 to serve the same purpose for open lake waters. L%PSwere to be pre-
 pared by the two countries for each of the five lakes, except for Lake
 Michigan, which is the United States’ responsibility. In preparing ufps,
 the two countries were to consult with state and provincial govem-
 ments. In the United States, the Environmental Protection Agency (EPA)
 has been charged with the responsibility of carrying out the nation’s
 role in developing and implementing %rs.

 In addition to requiring RAPSand LVPS,the Agreement contains 16other
 Ynnexes,” which define issues to be addressed and activities to be con-
 &cted by the two governments. These annexes address such issues as
 airborne toxic substances, contaminated sediment, and control of

 Page10                                        GAo/lIcED~l97   waw   Pnllnthn
Figura 1.2 Areas ol Concern   in the Great L&es   3asin

                                             In 1972, EPA'S Region V (Chicago) &abhshed Se Office of Great Lakes
Creation of EPA’s                            Coordinator to monitor a demon&xtinn program on the water quality of
Great Lakes National                         the Great Lakes and to conduct reseaxil on the Red River (which
Program Office                               crm     the international boundary between Ontario end Minnesota).
                                             The Office operated with three technical sttf and one secretary. In
                                             1978, EPA'S Region V established a larger coordinating office, the Great
    Lakes National Program Office (cm),      to direct and ovemee fulf?illment
    of the nation’s obligation under the Agreement and any spending for
    that purpose.

    In 1982, we reported that GLNPO was having difficulty obtaining the
    cooperation it needed from EPA offices and other federal and state agen-
    cies to fulfill its mission.’ SpecikalIy, GLWO did not have the visibility,
    authority, and resources necessary to ensure that its Great Lake Water
    Quality Program could compete with other national programs. One of
    our recommendations was that GLNPO be allov~ed to coordinate actions
    within EPA and with other federal agencies and the states to ensure that
    their views were included in the development of strategies to improve
    the Great Lakes’ water quality.

    In the years following our report, however, the Administration
    attempted to eliminate GINO by excluding it from the Administration’s
    budget proposal. The Administration saw the problems regarding the
    Great Lakes as regional concerns and believed that the states and EPA
    regions should be responsible for addressii those problems. However,
    each time the Administration excluded GLNi, the Congress restored
    funding for the Office and EPA’S Region V provided staff and other

    In 1987, under the Water Quality Act, the Congress formally established
    a statutory mandate for GLAXO and gave the Office responsib&y for
    developing and implementing plans to carry out the Agreement. Specifi-
    cally, the act required GLPii to

l cooperate with federal and state agencies in developing and imple-
  menting plans to carry out the United States’ responsibilities under the
l coordinate EPA’S efforts to improve the water quality of the Great Lakes;
. monitor the water quality of the Great Lakes;
0 serve as a liaison with Canada;
. coordinate EPA’S efforts with those of other federal agencies, as well as
  those of state and local agencies,to obtain the views of these agencies in
  developing strategies for improving water quality and their support in
  achieving the objectives in the Agreement; and                                                ,’
l report annually to the Congress on the state of the lakes and on progress
  in meeting the United States’ obligations under the Agreement.

    ‘A More Comprehensive Approach Is Needed to Clean Up the Great Lakes (CED-82-63, May 2X.

    P8ge 12                                                    GAO-197            Wmta ?dktim
  As presently  structured, GLSKJ is a UtiqUe entity  within EPA becauseit is
  associated with a specific area of the country but operates as a func-
 tional part of the Office of Water at EPA headquarters. It does not have
 authority over other EPA of&es, but rather coordinates the activities of
 other offices and helps to ensure that matters concerning the Great
 Lakes are considered in the agency’s policy and program decisions.
 GL..FO currently has a staff of about 30 scientists, engineers, and other
 professionals who work with offices throughout EPA, the Great Lakes
 states, other federal agencies, the Canadian government, the Ontario
 Provincial Government, LIC, colleges and universities, and public interest
 organizatiors It is organized into the Surveillance and Research Staff,
 the Environmental Planning Staff, and the Remedial Program Staff.
 Each participates in, coordinates. and facilitates actions by the majority
 of these organizations to ensure that environmental management deci-
 sions concerning the Great Lakes Basin reflect the Agreement’s objec-
 tives. (Seeapp. I for an organizational chart on the structure of GLSPO
 and its coordination activities.)

  GISPO  formally coordinates EP.%‘s
                                  activities concerning the Great Lakes
  primarily through two committees:

m The Great Lakes Coordinating Committee was established in 1980 to (1)
  serve as an titra-agency forum for EPA’s three Great Lakes regions and
  ~~4’s Office of Research and Development and (2) review and recom-
  mend proposed demonstration and research projects to be funded by
. The Great Lakes Advisory Committee was established in 1989 primarily
  to coordinate activities between GLSFQ and EPA’Sheadquarters offices.

  The Coordinating Committee supports the Advisory Committee in a
  number of functions, including the determination of GLWO’S budget and
  work plan.

  In addition, GLWO created the U.S. Policy Committee in 1989 to improve
  coordination and cooperation between WA and other federal agencies,
  and to improve contacts with state agencies, environmental groups, and
  other interested parties. The Committee meets twice a year, just before
  the semiannual meeting between the United States and Canada. It
  focuses on what the United States’ position should be on policy and
  issues regarding the Great Lakes.

   Page 13                                        GA0/ucEww197    w8ter Pollntioa
                  chapter I

Methodology       Transportation. requested that we evaluate a number of issues affecting
                  the ability of GLSPO to meet its responsibilities under the Water Quality
                  Act. On the basis of subsequent meetings with the Chairman’s ctffice, we
                  agreed to assess the progress (;I.M’~)has made in

              l   defining its role within EP.\and involving other appropriate ES!-\offices
                  in meeting the objectives of the Xgreement and the 198’7Water Quality
                  Act, and
              l   coordinating the efforts of other federal agencies and state and local
                  governments in addressing thts ohjt~tivt~ of the .L\gret=mentand its

                  To address the first objective, we identified CISI’O’Sefforts to involve
                  other EIY offices through projects. intra-agency agreements anu intra-
                  agency committees. In assessing the effectiveness of these efforts. we
                  reviewed information from CI,MX EN headquarters offices (Air and
                  Radiation. Water, Research and Development. and International
                  Affairs): and EIY Water Division Offices in Regions II, III, and v (Sew
                  York, Philadelphia, and Chicago. respectively). The key illformation we
                  reviewed included (;Lsryjs workplan for achieving the objectives of the
                  Great Lakes Water Quality Agreement; fu.iding agreements for research
                  and other activities between ~I.SIY,and other EI?% offices; and the mem-
                  bership. objectives. and accomplishments of the committcns established
                  to improve intra-agency coordination.

                   To address the second objective. we collected information from federal
                   agencies (Sational Oceanic and -4tmospheric -4dministration. I :.S. Army
                   Corps of Engineers. Soil Ccmscnatirm Service, 1-S. Fish and Wildlife
                   Service. I,‘.S. Coast Guard. and I ‘.S. Geological Survey) and lead state
                   agencies for the Great Lakes. The information included views of cogni-
                   zant officials at these agencies on ~LSPO’Sappropriate role and on how
                   well CLSPOis coordinating programs regarding the Great Lakes. We also
                   spoke to GLSPO officials to obtain their views on how they are. and
                   should be, working with these federal agencies to implement the Agree-
                   ment (e.g., through interagency agreements and funding of agencies’
                   research proposals).

                   We also selected several of the Agreement’s anrexes to assessGL~PO’S
                   effectiveness in coordinating the implementation of the Agreement’s key
                   requirements by federal agencies. 1Vechose annex 7 (dredging). annex

                   Page 14                                         GAO, IiCED     Water Pnllutien
chapter 1

11 (surveillance and monitoring), and annex 15 (airborne toxic sub-
stances) for our review because Gwpo staff said they had made the most
progress on these annexes. We chose annex 14 (contaminated sediment)
because it included the Assessment and Remediation of Contaminated
Sediment Program, which GLPml was dire&d to develop and implement.
We chose annex 2 (RAPSand L,HPS)because it addresses cleaning up all
sources of water pollution and involves the coordination and eoopera-
tion of many agencies.

We spoke with several environmental groups, such as Great Iakes
United and the Sierra Club, to obtain their views on how well GLWO was
coordinating federal and state efforts to address the Great Lakes Water
Quality Agreement and meet the requirements of the 1987 Water
Quality Act. We also gathered information from the Northeast-Midwest
Institute and reexamined data from our own recent analysis of pollution
in the Rouge River: to help determine the potential costs of cleaning up
the Great Lakes.

Our evaluation focused on GLSPO’S    role in coordinating the United States’
efforts to meet the objectives of the Great Lakes Water Quality Agree-
ment. We did not attempt to evaluate the role of Canada or its progress
in cleaning up the Great Lakes or in implementing the Great Lakes
Water Quality Agreement.

 We conducted our work between May 1989 and March 1990, with
 updates through July 199% in accordance with generally accepted gov-
 ernment audit standards. During our review, we sought the views of
 GLSPO and other EPA officials responsible for activities concerning the
 Great Lakes, and their comments have been incorporated where appro-
 priate. However, in accordance with the wishes of the Chairman’s office,
 we did not request formal comments from EPA on a draft of this report

 -‘water Potlution: Effom to Clean L’p Michigan’s Rouge River IGAO/RCELHfWX.   Aup. 14 1=X

 P8ge 15                                                     GAO/iKTD9@191     Water Pohthn
Chapter 2

steps Taken to Improve GLl!l!s                                 Cbcdination
Within EPA

                      Since the 1987 Water Quality Act was passed, GLSSO    has augmented its
                      profile within EPA by participating in the development of EPA'S water
                      policy, expandlng its contacts beyond Region V (C&ago) to include
                      Regions ll (New York) and III (Philadelphia), devising a workplan for
                      programs concerning the Great Lakes, and funding EPA regions’ water
                      pollution projects for the Great Lakes. GINO alsOestablished the Great
                      Lakes National Program Advisory Committee, composedof representa-
                      tives of EPA'S three Great Lakes regional offices and all key headquar-
                      ters offices with programs affecting the lakes’ water quality. The
                      Advisory Committee helps to coordinate and review EPA’Spolicies and
                      activities regarding the lakes and recommends which projects to fund. In
                      April 1990, EPA expanded the composition of the Advisory &nmittee, a
                      step that should further increase GLSPO’S effectiveness in coordinating
                      EPA’S activities to improve the Great Lakes’ water quality.

GLXPO’s Role Within   hurt the Office’s ability to implement the Great Lakes Water Quality
EPA Expanded by       Agreement. WA Regions II and III were reluctant to commit resources to
1987 water Quality    initiatives regarding the Great Lakes because they did not receive spe-
                      cific funding for such purposes. In addition, GINO bad not delegated any
Act                   responsibilities to Regions II and III. As a result, implementation of the
                      Great Lakes Water Quality Agreement was largely left to Cm         and
                      Regio,? V. To ensure that GINO could more effectively fulfh its leader-
                      ship role, we recommended that the EPA Administrator raise GISPO to a
                      higher organizational level and give it the authority and resources nec-
                      essary to coordinate EPA actions aimed at improving the Great Lakes’
                      water quality.

                      It was not until the Water Quality Act of 1987, however, that progress
                      was made toward addressing the issues identified in our 1982 report. At
                      that time, the Congress assigned GLNPO an organizational identity within
                      EPA, giving GLM-YJ its own budget, and charged it with developing an
                      “ecosystem approach” (i.e., an approach that would address pollution
                      problems in the entire Great Lakes Basin and consider all sources of pol-
                      lution), as envisioned in the Agreement. The act also required GLWO to
                      coordinate EPA headquarters and regional programs for improving the
                      water quality of the Great Lakes. As discussed below, we found that
                      since the act’s passage, GLXlW has taken steps to increase its involvement
                      with EPA headquarters and regional offices responsible for the Great

                      Page16                                         GA0/mIms~197   W8tu Pouotioo
                       The Agreement’s emphasis on an ecosystem approach to environmental
Efforts Made to        management necessitated that GLNPO be concerned with all types of
Improve Coordination   environmental management decisions involving the Great Lakes Basin.
With EPA               thIseqUently,GXSPO     needsto COOrdinate activitiesat&? ni3tiOrdlevel
                       with many of EPA’smedia programs, including programs for surface
Headquarters           water, groundwater, drinking water, air, hazardous waste, Super-fund,
                       toxic substances, and pesticides. For example, the Office of Air and
                       Radiation has jurisdiction over programs dealing with pollutants trans-
                       ported from other geographical areas through the atmosphere, a major
                       contributor of certain toxic chemicals in the Great Lakes. Similarly, the
                       Office of Pesticides and Toxic Substances regulates the use of pesticides
                       to reduce the amount of toxic substances entering the Great Lakes from
                       storm water runoff.

                       Thus far, GLWO has made inroads with someof the key EPA headquar-
                       ters offices. in fii  year 1989, GLWO began working with EPA's Office
                       of Marine and Estuarine Protection and individual estuary programs to
                       support the development of policies and programs that address poIlu-
                       tion problems in the Great Lakes. For example, GLwo is working with
                       the Office of Marine and Estuarine Protection to develop a method to
                       share new technological developments. In fiscal year 1988, GLSFO
                       entered into an agreement with the Office of Research and Develop-
                       ment’s Environmental Research Laboratory in Duluth, Minnesota, to
                       fund research on the Great Lakes at the Laboratory and its Large Lakes
                       Research Station in Grosse Be, Michigan. The Research Station and Lab-
                       oratory are assisting GLmO with its mass balance modei in Green Bay,
                       Wisconsin, and the Assessment and Remediation of Contaminated Sedi-
                       ment Program’ -models for the rerrdval, stabilization, or treatment of
                       toxic sediments. The Green Bay Mass Balance Study will also be used as
                       a tool to develop LVPS.

                       Nevertheless, GISPO recognized that it needed to increase its efforts to
                       involve headquarters offices if it was to succeed in developing the
                       ecosystem approach mandated by the Water Quality Act. As noted
                       above, coordination with EPA headquarters offices, such as the Office of
                       Air and Radiation and the Office of Pesticides and Toxic Substances, is
                       crucial to addressing pollution problems in the Great Lakes.

                       ‘The Awssment and Remedlatlon of Contaminated ZTedhent Pmjgam stems from the 1987 Water
                       Quality Act requirement for GLTTPOto conduct S-year study and demonstrahm pl-OfXtSOntheCO~
                       MI of toxic pollutants in sx%ments in the Great Lakes.

                       Page 17                                                   GAo/bBxmm%197 waer       PollnIion
                  To assist in this effort, GLNPO established the Great Lakes Advisory
                  Committee in 1989 Yo address policy issues and headquarters level
                  coordination.” In particular, the committee (1) reviews GLNFO'S yearly
                  budget, (2) addresses multimedia policy issues regarding the Great
                  Lakes, and (3) reviews GLNPO'S and headquarters’ activities pertaining to
                  the Great Lakes, including their funding and m&stones.

                  Committee members initiahy included GLNPO'S former Director; Regional
                  AdminiSrators from Regions II, III, and V; and Assistant Administrator
                  from EPA'S Office of Research and Development, Office of International
                  Activities, and Office of Water. GLNPo's Deputy Director stated that
                  these members were invited to the first meeting in March 1989 because
                  they were the most active in implementing the Great Lakes Water
                  Quality Agreement. He told us, however, that it was important for other
                  offices to participate in subsequent committee deliberations, given their
                  responsibilities for key issues and programs affecting the Great Lakes.
                  He specifically noted that the Office of Air and Radiation and the Office
                  of Solid Waste and Emergency Rer,;ronseshould participate because both
                  offices had expanded their original auties and responsibilities regarding
                  the Great Lakes.

                  In its January 1990 meeting, the Great Lakes Advisory Committee mem-
                  bers determined that to satisfy the requirements of the Great Lakes
                  Water Quality Agreement, more direct participation was needed from aII
                  EPA offices. The Administrator responded to this concern in an April
                   1990 memorandum, stating that the membership of the committee
                  would be expanded to include all Assistant Administrators and that the
                  EPA Deputy Administrator would be the Chairman- He also requested
                  that each Assistant Administrator review his or her programs and
                  funding policies and, by May 1990, advise the Great Lakes Advisory
                  Committee of the specific contributions their office could make toward a
                  coordinated, multimedia approach to environmental problems in the
                  Great Lakes. In addition, he requested that each office designate a
                  senior-level contact to provide day-today communication with GLKPO.

                  Most of GINO'S contacts with EPA regms have focused on funding
EPARe@onal        research projects that identify the nature and extent of pollution
Involvement Has   problems or that seek to develop innovative ways to address such
Expanded and      problems. GLNFQ established the Great Lakes Coordinating Committee in
                  1980 to coordinate these activities with the three Great Lakes regions,
Improved          and to review and recommend proposed research projects to be funded
                  by GLNPO. The committee membership consists of six Division Directors

                  P8ge 18                                        GAO/-197      Water Pollatkm
from Region V, the Director from Region II3 EnvironmentsI Services
Division, the Director from Region III’s Water Division, a representative
from EPA’S Environmental Research Laboratory (a research offIce used
heavily by GLMO), a representative from the office of Marine and Estua-
rine Protection, and GLNPO’S Director and Deputy Director.

The committee’s funding recommendations have largely been based on
how wel! they help the United States meet its commitments under the
Great Lakes Water Quality Agreement. According to one member, GLNPO
generally follows the committee’s recommendations. The available funds
range between $1 million and $5 m.iIIion each year, depending on GLNPO'S
appropriations, fixed costs, and congressionally mandated projects, such
as the Assessment and Remediation of Contaminated Sediment Program.

While the committee was intended to help GLNPO coordinate these activi-
ties with all the Great lakes regions, Region V had received most of the
funding from GLNPO until recently. The emphasis on Region V reinforced
a view withi EPA that GLNW was largely an appendage of Region V,
rather than a headquarters office with broader relationships within the

In recent years, however, GLNPO has taken :;veral steps to improve coor-
dination and cooperation with Regions II and IIL For example, in 1989
the committee recommended and GLNPO appr, fed funding for Region II’s
Niagara River Toxic Assessment Program, which screens and quantifies
toxic chemicals. The information developed in the program will be
helpful in developing an LMPfor Lake Ontario. Region II also received
GLNPO funds to set up workshops, reserve meeting rooms, and send out
mailings to encourage public involvement in developing LMPS.

Before fiscal year 1989, Region III had not received funding from GLNPO,
but the Region’s Water Division Director explained, and GLNPCI officials
agree, that GISPO funding would be considered unnecessary because of
the region’s limited jurisdiction over the Great Lakes-approximately
40 miles of lake Erie’s shoreline. During fiscal year 1989, GINPO tried to
transfer funds to Region III to support a study of Presque Isle Bay at
Erie, Pennsylvania, which LJC had recommended to be named an area of
concern. Because Region III did not have a system in place to transfer
funds to a state, GNP0 gave the funds directly to Pennsyivania for the
study. However, Region III and GJNQ have been trading research and
other information because of Region IIFs involvement with the Chesa-
peake Bay, a body of water with somesimilarities to the Great Lakes.

P8ge 19                                        GAODlS7        Watu Pollmioa
=Onclusions   Quaiity  Act, GLNNPOhas taken steps to improve coordination of EPA'S
              efforts tr, implement the Great Lakes Water Quality Agreement GLSPO
              has invited officials from EPA headquarters and regions to participate in
              the Great Lakes Advisory Committee, and is developing a comprehen-
              sive workplan for the Great L&es that would include participation from
              EPA headquarters and regions as well as from other federal and state
              agencies. In addition, GLhTO has expanded its relationship in recent
              years with Regions II and III, helping to change the perception within
              EPA that it is merely an extension of Region V.

               Page 20                                       GAO/HZEDHb191   Water Polhth
@er 3

jr&m EPA Iiwolvement Neededin
‘bordinating RemediailAction Plans

                      In addition to requiring GLWO to coordinate EPA'S own work to improve
                      the Great Lakes’ water quality, the Water Quality Act of 1987 required
                      GLWO to coordinate EPA’S programs with those of federal, state, and local
                      agencies in developing specific strategies for improving water quality.
                      GLNHI has taken several steps to meet the act’s requirements. For
                      example, GLWO staff have taken leadership roles in WC,which reviews
                      both the United States’ and Canada’s progress in implementing the
                      Great Lakes Water Quality Agreement. In September 1989, GLSPOestab
                      lished the U.S. Policy Commi~onsisting          of federal agencies, states,
                      and public interest groups-to detzrmine U.S. policy in achieving the
                      objectives of the Agreement. GLYm has also made progress in coordi-
                       nating activities among federal and state agencies to address specific
                       annexes under the Agreement, such as developing inventories of air-
                       borne toxic substances and improving the surveillance and monitoring
                       of the Great Lakes’ water quality.

                      Although progress has been made in meeting many of the Agreement’s
                      objectives, the development of RAPS-a top UCpriority in addressing the
                      Great Lakes’ water quality problems-has fallen far behind schedule.
                      State and local RAPofficials, as well as environmentalists, believe that
                      progress can be made only if GLMQ takes a more active role in devel-
                      oping RAPS.WhiIe GLSPO has augmented its coordinating role somewhat,
                      and is considering further involvement, it maintains that the actual
                      development of these detailed and complex cleanup plans is principally
                      the responsibility of state and local governments and that EPA regions
                      also should play a larger role.

LNpO’s Coordination   prehensive approach toward cleaning up the Great Lakes and meeting
‘ith Other Agencies   the objectives of the Agreement. We stated that GL%TO had been frus-
itially Centeredon    trated in its attempts to ensure that the United States’ commitments
                      under the Agreement were met because it could not direct the activities
c                     of other federal agencies or states. To help address the problem, we rcc-
                      ommended that GLW coordinate with other federal agencies and states
                      to obtain their views on strategies for improving the lakes’ water quality
                      and solicit their support in implementing those strategies.

                      In an attempt to improve its coordination and visibility, GLPUPObecame
                      involved in LIC’Sactivities, which involve staff from a variety of U.S.
                      and Canadian federal agencies, as well as staff from state and provincial
                      agencies. The Great Lakes National Program Manager served as the
                      United States’ cochairperson on LJC’SWater Quality Board, and the

                       P8ge 21                                         GAO/RCEWKX197 Water Polhtim
                         former ~uwo Director became the United States’ cochairperson on we’s
                         Water Quality Programs Committee (which      reports to the Water Quality
                         Board). GLNFQ'S senior staff also chaired other UC subcommittees.

                         GINO’S former Director, however, became concerned that GLNFQstaff
                         were spending too much time on UC’S activities, particularly as chairper-
                         sons of various committees and subcommittees. She said that even
                         though participation in UC’s activities helped her staff understand initia-
                         tives for the Great Lakes, they did not spend enough time on coordina-
                         tion with other US. federal agencies. GWPO’s Deputy Director agreed,
                         indicating that aa late as 1988, he was spending at least 50 percent of
                         his time as chairman of an LICsubcommittee. Another GLNFQofficial said
                         that he was spending 50 to 60 percent of his time as chairman of
                         another subcommittee and that this participation adversely affected his
                         ability to coordinate the activities of US. agencies.

                         As a result of these concerns, GLNFO staff plan to relinquish their posi-
                         tions as chairpersons, asking staff from EPA regional    offices, other U.S.
                         agencies (e.g., the Fish and Wildlife Service), or the Great Lakes states
                         to fill these positions. GLNFO intends to keep its staff involved with LJC’S
                         activities, but not as chairpersons of the committees and subconunittees.

5.Policy committee       eral and state agencies and environmental groups, GLKFQ established the
sablishedto              U.S. Policy Committee, with GLhlQ’s Director as the Chairperson in 1989.
prove Interagency        The Committee is required to meet twice a year-and more often if the
                         members desire-just before each semiaunual meeting between the
xdination                United States and Canada to decide what the United States’ position
                         should be on policies and issues regarding the Great Lakes.

                         The Committee met for the first time in September 1989. A wide range
                         of organizations are represented on the committee, including GLNPO; EPA
                         Regions II, III, and V; other federal agencies with responsibility for the
                         Great Lakes (e.g., U.S. Coast Guard, U.S. Army Corps of Engineers, U.S.
                         Fish and Wildlife Service, and National Oceanic and Atmospheric
                              . .
                         AdmIm.%3 tion); the eight Great Lakes states; public interest groups;
                         and industry. The Committee’s objectives include identifying

                     l   key provisions of the Great Lakes Water Quality Agreement that require
                         the coordinated efforts of more than one agency or program and the
                         steps needed to implement these provisions,

                         Page 33
                l   situations in which Agreement revisions are not being met becauseof a
                    lack of adequate coordination, and
                l   situations in which one or more organizations did not implement the
                    Agreement because they did not give it sufficient priority.

                    Although the Committee was established by GINO, it represents diverse
                    interests and expertise from a variety of governmental  and nongovem-
                    mental organizations. One member of the Policy Committee told us that
                    he was particularly impressed with the caliber of the participants at the
                    September 1989 meeting and that the GLNFO staff has been committed to
                    motivating other federal agencies to make greater commitments in
                    resolving issues regarding the Great Lakes. He added however, that
                    most agencies have limited resources and will therefore not be able to do
                    everything that GLWO suggests.

                    Other members of the U.S. Policy Committee-including state, industry,
                    federal agency, and environmental group members-told us that
                    although GLSPO organized the Committee, it operates independently of
                    GI h’poand can make important policy decisions without undue pressure
                    or influence from the Office. Furthermore, these members noted that
                    while GLMO'S Director presently chairs the Committee, nothing pre
                    eludes a member from another agency from becoming the Committee’s
                    chairperson in the future.

                    Improved coordination and cooperation between GLKPO and states and
JPOHas              other federal agencies have resulted in progress in implementing many
rdinated With       of the Agreement’s annexes. However, implementation of the most
es and Other        importa& and difficult annex, calling for the development of RAPSand
                    LAWS,has been delayed for years.
ncies in
lementing           Implementing the annexes often requires actions by one or more federal
                    agencies or states. GLNPO, as the lead federal office in ensuring that the
lexes,but Key       United States fulfills the terms of the Great Lakes Water Quality Agree
~~AreEkhind         ment, including the annexes, must rely on cooperation from states and
zdule               from other agencies because it is not funded to directly implement the
                    Agreement and does not have the resources to accomplish the objectives
                    on its own. In 1989, GLNFO began developing a workplan listing (1) cur-
                    rent EPA regional programs that address each annex of the Agreement
                    and (2) WA regional offices that should assist GLNFO in implementing
                    these programs. GLNPO plans to expand the workplan in 1990 to include
                    all federal, state, and local agencies that also should provide assistance.

                    Page 23                                         GAO/RCXD~197   WW   Pdlntien
                             Fifteen of the 17 annexes address specific functional topics, such as the
                             control of phosphorus going into the Great Lakes, the surveillance and
                             monitoring of the Great Lakes’ water quality, and pollution from con-
                             taminated groundwater. The other two annexes call for the development
                             of (1) specific objectives regarding water quality (e.g., which pollutants
                             should be regulated and what their allowable limits should be) and (2)
                             RAPSand LVPS.GINO has been coordinating with states and with other
                             federal agencies to implement the objectives of the annexes. To

                 l Annex 3 (control of phosphorus).           and the Department of Agricul-

                   ture’s Soil Conservation Service jointly developed and implemented a
                   series of demonstration projects to reduce the amount of phosphorus
                   entering the Great Lakes.
                 l Annex 7 (dredging). ~LSPOhas been helping LJCmaintain a register of
                   dredging projects, as required by the annex, and uses information pro-
                   vided by the U.S. Army Corps of Engineers to update its register.
                 . Annex i 1 (surveillance and monitoring). GLWO has cooperated with the
                   U.S. Fish and Wildlife Service and the states to monitor the quality of
                   open lake and coastal waters. GLWO also has an agree.nent with the
                   National Oceanic and Atmospheric Administration and the U.S. Fiih and
                   Wildlife Service to do joint field monitoring with EPA for the Green Bay
                   Mass Balance Study.
                   Annex 14 (contaminated sediment). GLNPO has begun to determine

                   methods for assessing and reducing contaminated sediment. GLSPO has
                   an interagency agreement with the U.S. Army Corps of Engineers, the
                   Kational Oceanic and Atmospheric Administration, the U.S.Fiih and
                   Wildlife Service, and the U.S. Bureau of Mines to plan a demonstration
                   program. GLXPO also has an agreement with five states and several uni-
                   versities to help plan and design the program.
                    Annex 15 (airborne toxic substances). GWFO has an agreement with the

                   governors of all eight Great Lakes states to help develop emission inven-
                    tory procedures for toxic emissions. As part of this effort, GLVO has
                    built five monitoring stations and plans to build 12 more by 1993.
                    Annex 16 (pollution from contaminated groundwater).
                         l                                                          has

                    worked with the U.S. Geological Survey to study the effects of cmntami-
                    nated groundwater ONthe Great Lakes.

opment of RAPS               One of the most important annexes in eliminating persistent toxic sub-
                             stances in the Great Lakes is annex 2. the development of RAPS.These
; to Be Better               plans are intended to develop systematic and comprehensive approaches
inated                       to restoring the water quality of particularly polluted areas. For

                             P8gt 24                                        GAO/fKXB~l97     Wawr Pollution
example, 41 of thz 42 aress of concern in the Great Lakes Basin have
seriously conmated       sediment.* To illustrate, the sediment in one area
contains about 1.1 million pounds of polychlorinated biphenyl (pcBr pc8
isaknowniiumancarcin      ogen and can damage the liver and repro&c-
tive and nervous systems.

A RAPis a systematic and comprehensive approach to ichentify speclflc
actions necessary to control existing sources of pollution, abate envlron-
mental contamination already present, and restore beneficial uses of the
waters located in a particular area of concern. It calls for all agencies,
communities, and programs corcemed with an area to work together on
common goals and objectives to ensure the successful implementation of
all pollution control efforts.

The development of RAPSrequires coordination and cooperation among
state and local officials, industry representatives, and local citizens.
However, progress in developing RAPShas been slow, particularly in
comparison with the progress made on other annexes. Some RAYSare
years behind schedule. For example, the Milwaukee Harbor RAF,once
planned for completion by 1987, is now scheduled to be completed in
January 1991. According to WC,one reason for the delays is that all the
federal, state, local, and private organizations involved have not
reached agreement on their appropriate roles and responsibilities. In
addition, WCdetermined that six of the first eight RAPS  submitted for
review were inadequate and needed to be revised. One problem cited by
IJCwas inadequate information on the impacts of various pollution
sources on the Great Lakes’ water quality.

The delay in developing RAPShas prompted congressional concern.
During the summer of 1989, congressional field hearings in Michigan
and Wisconsin focused on the need for more progress and increased fed-
eral involvement in developing RAPS.ln September 1989, legislation was
introduced in the United States Senate (S. 1646, Great lakes Critical
Programs Act) requiring GL.wo to ensure that the Great Lakes states
develop and incorporate RAPSinto their water qua&y plans by January
 1,1993. The legislation would require that once the MP has been
included in its water quality plan, the state would becomeeligible for
WA funding to help implement the RAP.It was then included in another
bill (S. 1178, Marine Protection Act of 19891,which was reported out of
the Committee in June 1999 and was placed on the Senate legislative

**figurel.!   forthelocaa~ofthe42area5of-m.

Page 25                                         GAo/xfcEDm197   w8ter Peuutloil


                      _I   -
          _...   .-

_/   .-

                                           In March 1999, similar legislation was introduced in the House of Repre-
                                           sentatives (H.R. 4323, Great Lakes Water Quality Improvement Act of
                                            1990). in April, it was referred to the Subcommittee on Water Resources,
                                           Committee on Public Works and Transportation, which then held hear-
                                           ings in May.

          Disagreement Exists Over         To deal with the problem, environmentalists and some state and local
                                           officials engaged in developing RAPSand environmentalists have asked
          GLNPO’s Role in                  GLSPOto get more involved in completing the plans. An official from one
          Developing RAPS                  state, for example, toJd us that GINO should provide technical and orga-
                                           nizational expertise, actively participate in citizen committees, and act
                                           as a clearinghouse for transferring pertinent information on developing
                                           RAPSfrom state to state. Other states expressed a desire for GLNPO to
                                           provide more funds for their work in developing RAPS.

                                           One environmental group, in testimony at Senate field hearings, stated
                                           that while most RAPS   adequately describe and define problems, they fail
                                           their ultimate purpose-to evaluate current remedial programs and pro-
                                           pose and evaluate additional cleanup programs. The group stated that
                                           while GLNFCI  has provided some help in developing RAPS,it has not
                                           devoted sufficient time and resources to ensure that they are as thor-
                                           ough and extensive as they should be. It stated that most RAPSmerely
                                           recommend more studies or additional testing and sampling, rather than
                                           delineating re-medial actions. The group also stated that GLMO has not
                                            been aggressive in insisting that citizens participate early in the develop
                                            ment of RAPS.

                                           GLWO   officials maintain that the Office has done what can be reakti-
                                           tally expected, given a staff of only 33 and the liited financial
                                           resources it can devote to developing RAP%GUiPO has given some funds
                                           to EPA regions and states for developing RAPS,prepared guidance for
                                           RAPS, and reviewed and commented on completed RAPS.      It has also com-
                                           pleted a mqjor study on the Great Lakes that provides data that shouid
                                           aid in developing RAPS,working with the U.S. Fiih and Wildlife Service,
                                           the U.S. Geological Survey, the Xational Oceanic and Atmospheric
                                           Administration, the U.S. Army Corps of Engineers, the city of Detroit,
                                            and the state of Michigan.

                                            GLSPO  officials indicated to us that the Office has recently augmented its
                                            role in developing RAPSto some extent and is assessing whether further
                                            involvement is warranted. GLmo's Deputy Director told us, for example,
                                            that GLNPO funded seven positions in Regions II and V in fiscal year 1989

                                            Page 26                                         GAO,AtCEMWlS?   Wats -II

    Gn=axer EPA Invdvemnt   !icded in
    Cmxdinating Rrmdid    Action PLUW

    to help develop IL\PS.The former Director said that the four additional
    staff hired in fi%?ul year 1990 ~111 assist states in developing RAF-S
    LMIX Another c:t.X111) official suggested that GLSPO may become more
    involved in developing HAPSin areas that border both the United States
    and Canada because the development of these UPS requires individuals
    that can represent the federal government rather than an individual
    state. lie said that ~I.MV)would need two additional staff for this work
    and additional funds for the states and ~5.4 regions.

    Still. GL~I'U officials maintain that there are limits to what the Office can
    do to speed the development of KM%beyond providing basic guidance
    and technical assistance. Devek>ping a ~i’is a major undertaking, and
    each requires coordination among many federal. state. and local agen-
    cies. and the incorporation of views from industry and private citizens.
    Moreover. (;ISIYJ must also fulfill responsibilities for other annexes of
    the Agreement. U’hile they acknowledge a role in helping to develop
    FLU%.cIl.\fq) officials maintain that this task is primarily a state and local
    responsibility. They explain that the states are responsible for imple-
    menting pollution control programs and that cars often involve issues
    that are typically not dealt with at the federal level. such as zoning,
    farming practices. snd other land use issues.

    In addition. in Februav 1990 the Great Lakes Sational Program Man-
    ager wrote to the t hrce EPAGreat Lakes regions. stating they should
    assist the states in developing and implementing ~41% and asking lhem
    to determine what additional resources they would need to help state
    and local officials develop 1~1s. Region V’s Water Division requested
    and received t~vo additional staff from GLWO and another three from
    Region V to assist the states in developing and implementing RAPS.
    Region I! agreed that the regions should help states develop and imple-
    ment K&f5and that it would need two or three additional staff and sig-
    nificant funding. Region II recommended that primary funding for KMY
    come from the states and that (XWOsupplement the funding a..

    Thus. some disagreement exists over the appropriate ro!e of GLUU and
    other organizations in developing ILAPS. GLSFQ believes that state and
    local agencies primarily should be responsible for developing and imple-
    menting u-\rs and that EM regional offices should play a larger role. It
    maintains that because of its small size and limited resources, its role in
    developing K4Psin numerous areas of concern is limited. In contrast,
    states and environmentalists want GLSPO   to make a larger commitment
    because of its expertise and ecosystem perspective.

    Page 27                                          GAO/BcED90197   water Pounti

                          We believe that since the development of k~ps is important to the
                          cleanup of the Great Lakes---and since so little progress has been made
                          in achieving this objective-this policy issue needs to be resolved. The
                          newly formed US. Policy Committee, which involves representation        -
                          from numerous interested parties and was established to make po!icy
                          recommendations on how the United States can best address the Agree
                          ment, is umquely situated to help resolve this policy issue. Indeed, some
                          officials from GLNPO and other agenciestold us that such a role would be
                          particularly appropriate for this Committee, given its diverse composi-
                          tion and strong credibility.

Lakewide Management       Annex 2 of the Great Lakes Water Quality Agreement also calls for the
                          development of LMPSfor each of the Great Lakes. Whereas m focus on
Plans Not Developed       specific near-shore areas, LMPSfocus on reducing or eliminating the
                          worst pollutants in the Great Lakes’ open lake waters so that beneficial
                          uses are restored. LMPSare intended to ensure that pollutants are not
                          increased in any areas of the lakes. Annex 2 requires comprehensive
                          plans addressing such items as

                      . the threat that certain pollutants pose to human health or aquatic life,
                      . the estimated amount of pollutants each source contributes,
                      l remedial measures that are needed to restore the beneficial uses of the
                        lakes, and
                      . a process for evaluating remedial implementation and effectiveness.

                          Although GLNPO has been involved with studies that may serve as a
                          foundation for ~%%pzs  (particularly for Lakes Michigan and Ontario). LIZPS
                          have not yet been developed. In t&t, the development of LMPSis behind
                          the development of f~k~s,with basic decisions still to be made on how
                          the development of each plan will proceed. For example, IJChas called
                          for a precise definition of LMPSand procedures for tracking their pro-
                          gress. In Senate hearings in April 1989, EPA stated that the Lake Micb-
                          igan LVP would be completed by JuIy 1990. However, in June 1990
                          hearings, EPA'S Deputy Administrator stated that the target date for the
                          initial draft of the Lake Michigan LMPis in the first quarter of fiscal year
                           1992. GLIFO officials point out that LMpsare more complex to develop
                          than RAPSbecause, generally, several jurisdictions and agencies are

                          The U.S. Policy Committee has made some progress in moving LVP~ for-
                          ward. For example, it submitted a policy framework for the United
                          States and published standards for identifying substances that can

                           Page33                                         GA0/RCED9&197W8terPoUutiw
                            GrrrtcrEPAlU   tmb-ement Nmkd   b

                            potentially affect the Great Lakes (an objective of annex 1 of the Agree-
                            ment that is crucial to deveioping LHPS). Nevertheless, according to the
                            Director of EPA'S Environmental Research Laboratory, LMPSare not fea-
                            sible now because the technology necessary to deal with difficult
                            issues-such as how to assessthe amount of pollutants being added to
                            the open waters of the Great Lakes or how to reduce the pollutant loads
                            to acceptable levels-has not yet been developed. The Director said that
                            models for LMPSwill be developed one at a time and each will take about
                            2 years to develop. He noted that this approach will permit subsequent
                            plans to benefit from lessons learned on earlier plans. GLzr~0’sformer
                            Director told us that initial plans would use avwlable information and
                            then be modified as new information becomesavailable and new tech-
                            nology evolves.

                            The Water Quality Act of 1987 requires    EPA   to submit an annual report
Improvement in              to the Congress that, in part,
Gathering Information
From Federal            l
                            describes the achievements during the previous fscal year in imple
                            menting the Great Lakes Water Quality .4greement,
Agencies for                identifies amounts spent on initiatives to improve the Great Lakes’
AnnualReport            l
                            water quality,
                        .   describes long-term prospects for improving the condition of the Great
                            Lakes, and
                        .   provides a comprehensive assessmentof efforts planned to improve the
                            condition of the Great Lakes, including the programs administered by
                            other federal agencies.

                            This is the only document that reports to the Congress on the progress
                            the United States has made in implementing the Great Lakes Water
                            Quality Agreement. As such, it is essential for congressional oversight,
                            and for informing the public at large about how the lMed States is
                            fulfilling this obligation. EPA has delegated this reporting responsibility

                            To assist GLSPO in this effort, the act also requires each federal agency
                            with any responsibility involving the environmental quality or natural
                            resources of the Great Lakes to submit an annual report to GLSPO
                            describing how its activities affect compliance with the Agreement. Spe
                            cifically named in the legislation were the U.S. Army Corps of Engi-
                            neers, the Soil Conservation Service, the U.S. Coast Guard, the U.S. Fish
                            and Wildlife Service, and the Kational Oceanic and Atmospheric


              Gmter l2P.4hdvement    Needed in
              -w%wdtrl            ‘4ctl0a Plam

              The legislation required the first report, covering fiscal year 1988, to be
              completed by December 31, 1988. However, EPA did not issue the report
              until April 1990. The responsible GLWI official explained that the infor-
              mation provided by the other federal agencies was late and often lacked
              detailed information on the progress made in implementing the Agree-
              ment. He said that the other federal agencies did not give this effort a
              high priority and claimed they were not sure what data GLSPO wanted-

              GLFPO  clarified its guidance for the report covering fiscal year 1989. For
              example, in early September 1989 ~lsm sent each agency a computer
              disk programmed and formatted to better describe the information it
              wanted. The form asked for information, by program or by project. on
              expenditures in fiscal year 1989 and expenditures planned for fiscal
              year 1990 in categories such as enforcement, research, remediation/mit-
              igatlon, and general administration. The form also requested a list of
              mqjor achievements during fiscal year 1989. GLSPO asked for a response
              by October 1, 1989. Although not every agency met the deadline. the
              GLWO official noted that the agencies responded much faster than they
              had for the 1988 report.

              GLWO’S   efforts to implement the Water Quality Act of 1987 have
               resulted in improved coordination with federal and state agencies
               having a role in implementing the Great bakes Water Quality Agree-
               ment. These efforts, including the establishment of the 1J.S.Policy Com-
               mittee, have addressed many of the coordination problems cited in our
               1982 report.

               The key annex to the Agreement, however, which addresses the
               remediation of the most polluted areas in the Great Lakes through the
               development of RAPSand LIIPS. has not been adequately addressed.
               Uncertainties about GLWO'S role in addressing this annex-particularly
               questions about how its mission relates to that of EPA regions, states, and
               local governments in coordinating and/or developing m-have           been a
               point of controversy and the development of RAF%    has suffered as a
               result. We believe that the newly formed U.S. Policy Committee, charged
               with identifying situations in which the Agreement is not being fulfiiled
               because of a lack of coordination or of sufficient priority, could play a
               constructive role in speeding up the development of RXPSby identifying
               the appropriate roles and responsibilities for GLSPO and other organiza-
               tions in meeting the requirements of this important annex.

               P8ge 30                                         GAO/BCELbS137   Water PoUutiom
                Greater   WA lmdvement      Needed ln
                mu-                      ActionPlaM

                To improve interagency coordination in dealing with the pollution
ecommendation   problems of the Great Lakes, and in particular to speed progress on t!?e
                development of Remedial Action Plans and Lakewide Management
                Plans, GAO recommends that the EPA Adminktrator request that the US.
                Policy Committee assess, identify, and recommend appropriate roles and
                responsibilities for the Great Lakes National Program Office and other
                organizations in developing thex plans.

                P&#? 31
Chapter 4

GLNFO in Perspective: Cleaning Up the Great
Lakes Will Be Costly and Will Take Decades

                       The effect of years of pollution in the Great Lakes camrot be overcome
                       without massive research, cleanup efforts. and financial investment.
                       Improvements in GLSPO’s efforts to coordinate t!re United States’ imple
                       mentation of the Great Lakes Water Quality Agreement will help, but
                       are only a small part of the overall effort that would be needed. Even
                       the development of Rws and t&n%-which have proven to be an
                       extremely difficult task for public officials and other concerned parties
                       in the region-are just initial steps to plan the cleanup. Carrying out the
                       plans will take decades, cost billions. and require improved pollution
                       control programs by ~p.r\and other agencies.

                       Concern about the potential human health effects of toxic chemicals
Restoring the Great    found in the Great Lakes has increased, as growing evidence has linked
Lakes’ Water Quality   these contaminants with tumors in fish. genetic defects in fish-eating
Is a Monumental Task   birds, and reproductive disorders in lower organisms. Michigan, Indiana,
                       Wisconsin. Illinois, and Sew York have all issued health advisories to
                       people who eat fish from the Great Lakes because they are the main
                       source of human exposure to PCBS.dichlorodiphenyltrichloroethane
                       ( DDT). mercury. and other toxic contaminants. The health advisory from
                       Sew York, for example, indicated that a meal of f&h from Lake Ontario
                       could deliver a toxic dose equal to a lifetime of drinking water from that

                       Cleaning up the Great Lakes not only will require efficient coordination
                       but also will take substantial funding and time and considerable tech-
                       nical knowledge. According to a report by the Northeast-Midwest Insti-
                       tute (which provides information and analyses on natural resource
                       issues and other issues affecting the Northeastern and Upper Hid-
                       western states), the U.S. government spent approximately $9.4 billion
                       between 1980 and 1989 to implement the Agreement.’ Actrvities funded
                       include the construction of sewage treatment plants, the protection of
                       groundwater and wetlands, the monitoring and ana1ys.sof water
                       quality, the development of models for targeting control of toxic sub-
                       stances. the demonstration of technologies for remediating contaminated
                       sediments, the development of standards for evaluating contaminated
                       sediment, the evaluation of cleanup technologies, and the coordination
                       of research.

                        Page 32                                        GAO/scEDsOIsI   Water Pollution
                           chapter I
                           GLNPO in Pempmivc: Cleaning Up the

                           Even efforts of this magnitude represent limited progress. As the
                           Director of EPA'S Environmental Research Laboratory noted. polluting
                           the Great Lakes took over 100 years; consequently, their cleanup will
                           also take many years. For some cleanup tasks, such as implementing
                           LMPSand remediating toxic sediment, the technical solutions have yet to
                           be developed. Furthermore. while precise estimates of the eventual total
                           cost of cleaning up the Great Lakes are unavailable, indications are that
                           it will cost many more billions of dollars.

                           Estimates for implementing M illustrate the magnitude of the
                           problem. We reported in August 1988 that it will cost at least $1.8 bil-
                           lion to bring Michigan’s Rouge River, one of the region’s 42 areas of con-
                           cern. up to the state’s public health standards by the year 2005, as
                           planned in the area’s RAP.

                           Addressing concerns about the Great Lakes’ water quality involves sub-
vernment Program           stantially more than remediating the pollution problems already present
ed to Limit Toxic          in the lakes, such as toxic sediments. As is the case with other bodies of
xharges More               water, a central element of any effort to “clean up” the Great Lakes
                           involves reducing the rate at which toxic substances enter the lakes
kctively                   either directly or through tributaries such as the Rouge River. However,
                           as several recent GAO reports have demonstrated, the government’s
                           efforts to limit toxic discharges from both point sources (i.e., pollution
                           sources for which a specific point of discharge can be identified) and
                           nonpoint sources of pollution will need to improve substantially if the
                           Great Lakes’ water quality is to be restored.

bgramsto Control Point     The Sational Pollutant Discharge Elimination System (SPDEYS) Program,
                           established under the Clean Water Act, is the principal tool EPA and the
tree Pollution Do Not      states use to control water pollution from point sources. Under the pro
ninate Many Toxic          gram, facilities that discharge pollutants directly into a body of water
charges                    have permits that generally specify the entities allowed to discharge
                           pollutants. the types and amounts of pollutants that can be discharged,
                           the conditions under which the discharge is permitted, and the location
                           of the discharge. Even if these facilities always met permit require
                           merits, they would still pollute the waters: SPDES permits do not prevent
                           water pollution; they only limit it.

fective Pretreatment of    AS  our past work and EPA data have documented, industrial facilities
&rialWastesHasEkena        that discharge pollutants directly into bodies of water, such as the Great
icuiarly Serious Problem   Lakes, have sometimes violated permit limits. However, our April 1989

                           Page 33                                        GAO/RCED@S197 Water Pohtion
                          evaluation of EPA’S National Pretreatment Program found that industrial
                          facilities that discharge their water indirectly into bodies of water (i.e..
                          facilities whose pollutants go into sewer systems that feed into waste
                          water treatment plants) are a particularly serious problem.’ Many of
                          these industrial facilities have wastewater that contains particularly
                          large quantities of toxic metals and organic chemicals. The treatment
                          plants, in turn, discharge this wastewater directly into receiving
                          waters-such as the Great Lakes.

                          Because the treatment plants cannot cleanse many of the toxic pollu-
                          tants released into the wastestream, the Xational Pretreatment Program
                          requires these industrial facilities to c!eanse,or “pretreat,” the waste-
                          water before it enters the sewer system. However, our April 1989 anal-
                          ysis found that many industrial facilities did not comply with discharge
                          limits under the program. ’ Because of such violations, untreated toxic
                          pollutants end up in lakes, rivers, and other bodies of water. The same
                          report made a number of recommendations to improve enforcement
                          against violators of these and other program requirements.

                          While the effectiveness of industrial pretreatment is a national concern,
                          it is of particular importance in heavily industrial areas of the country,
                          such as the Great Lakes states, where mimerous industrial facilities dis-
                          charge toxic wastes into municipal sewer systems. As documented in our
                          1988 Rouge River report, De+.roithas a particularly large number of
                          industries that discharge wastes into its sewer system and has had great
                          difficulty controlling these toxic wastes through an effective pretreat-
                          ment program.

hnbined Sewer Overflows   Compounding this problem for many cities like Detroit, these ineffec-
Compound the Problem      tively pretreated toxic wastes may feed into &ystems where wastewaters
                          and stormwaters combine. Such combined sewer systems are a partic-
                          ular problem for several cities in the Northeast and Upper Midwest.
                          They were intended to overflow intermittently during periods of heavy
                          rain, when the amount of wastewater exceedspipe capacity. In many
                          cases, however, these systems overflow more frequently and more
                          extensively because the sewers were not adequately enlarged to accom-
                          modate the increased wastewater that has resulted from population

                                                     ?dONtDNIg   and Enforcement kded    for Toxw I%Uutants EInte-

                          30n the basis of a sample of 502 treatment plants selectsA randomly from the appmxunately I ,500
                          plants parucipatmg U-Ithe program. we found that about 41 percent of the plants industnal de
                          chargers exceeded one or more applicable dlseharge limits &mng the 12-month period examined.

                          Page 34                                                       GAO/EcED90197       Water Pollotion
                      chapter 4
                      GLNPO ln Perapecdvc: Cleani~ Up the Great
                      Ides Will Ek Gw.IY and WU Take Kkades

                      growth. In addition. urban construction on previously open giound has
                      increased unabsorbed rainwater. As a result. frequent overflows may
                      send heavily polluted water directly into bodies of water.

                      Combined sewer overflows are a particularly serious problem along the
                      Rouge River. According to a 1987 Southeast Michigan Council of Gov-
                      ernments study. virtually all of the following toxic substances-arsenic,
                      chromium, mercury. and r--and         71 percent of the nickel and 67 per-
                      cent of the cadmium entering the Rouge River originate from combined
                      sewer overflows. While state regulators and local officials are planning
                      strategies to deal with this problem. effective solutions are many years

ltion From Nonpoint   Alth JUgh there are gaps in the regulation of point sources of water pal-
                      luti in, no controls exist at all for many toxic “nonpoint” sources of pol-
ces Is Largely        !ut,on. Point sources, such as manufacturing plants. are visible, discrete,
mtrolled              ant easily identifiable. However, pollution from nonpoint sources (such
                      as runoff of pesticides and fertilizer from farms or runoff from streets
                      in urban areas) is diffuse ard often hard to trace to its place of origin.
                      Such pollution sources cannot be regulated through permits limiting end-
                      of-the-pipe discharges. Rather, they result from past and present land
                      use habits that reflect the way farming, mining, timber harvesting, and
                      other economic activities are conducted.

                      To cope with the pollution of the Great Lakes from nonpoint sources,
                      GLSFQhas worked with EPA offices and several other agencies to support
                      surveys to better understand the problem. For example. it funded a pro-
                      ject by the Ohio State University Extension Service to survey land-
                       owners’ and operators’ pesticide use in Ohio’s Lake Erie drainage basin.
                       GLSPOhas also funded projects demonstrating environmentally sound
                       land use practices and other institutional arrangements to prevent the

                      While these projects are sound beginnings, considerably more effort will
                      be needed to resolve the problem of the Great Lakes’ nonpoint sources.
                      For example, agricultural contamination, the single largest source of
                      nonpoint source pollution nationwide and a major contributor of the pol-
                      lution in the Great Lakes, is promoted by farming methods that rely
                      heavily on the use of pesticides and other chemicals. Such practices
                      have been reinforced for many years by federal agricultural programs
                      that have traditionally emphasized production while paying little heed
                      to water quality goals. While the Department of Agriculture has recently

                      Page 35                                         GAO/ESXB9&197   Water PoUution
           GLNPO trPmqwcthe     Cl-
                                         Up the Gmt

           taken steps to better integrate concerns about water quality into its pr*
           grams, the fundamental reorientation of existing farm programs and
           practices that wi!l be needed to deal effectively with the problem will
           require a strong political commitment and many years of effort.’

           Under the best of circumstances, cleaning up the Great Lakes will still
mchsions   be extremely costly and w!!! take well into the next century. GLWO    can
           play an important role toward this end by helping to coordinate the
           efforts of organizations at all levels of government and by providing
           direct technical support in certain instances. However, GLWO’S    potential
           contribution should be evaluated in the context of the enormous task at
           hand. !3eal!stica!!y, success in cleaning up the Great Lakes will depend
           much more heavily on the level of commitment and resources the nation
           and the Great Lakes region are willing to devote to the effort, the pros-
           pects for resolving formidable technica! challenges currently impeding
           the cleanup of the Great Lakes, and the ability of federal and state regu-
           lators to improve programs to limit the release of toxic discharges into
           the lakes.

           effotts to amtrol other nonpoint sources ofwaterpollution.hon~theothrnonpointpohti0n
           -thatwlubeadmpssed             areminingtimberharvexing,anduhanrunoff.

    Pye 37
dix I

NPO OrganizationalChart

akes Natlonal Program Office Organizational   Chart


                                                                   Semor Advcser
                                                                 (Program Analyst)


 d Research

                                   Page 38
     Appendix II

     FederalAgencies.With Key Rolesin the Cleanup
     of the Great Lakes

     National Atmospheric and   The Sational Atmospheric and Oceanic Admmistration (SOA+) conducts
                                environmental research. manages resources, and provides environ-
     Oceanic Administration     mental services in coasta! and estuarine waters. including the Great
                                Lakes. Much of SOM’S w?orkpertaining to the Great Lakes is done by the
                                Great Lakes Environmental Research Laboratory. SCM nms the Sea
                                Grant Program, and SO%L~‘s  Sationai Weather Service monitors the
                                weather and climate.

     ‘J.S. Army Corps of        The U.S. Army Corps of Engineers maintains navigation channels in the
                                Great Lakes and their tributaries. The Corps dredges, disposes of
     Engineers                  dredged material. and manages water levels. It plays an important role
                                in managing contaminated sediment in the Great Lakes.

     U.S. Fish and Wildlife     The C.S. Fish and Wildlife Semite focuses on habitat and contamination
                                issues relevant to the protection and enhancement of wetlands, fresh
     Service                    water fisheries, and wildlife populations. It collects data for national
                                inventories of vcetlands and waterfowl populations. It also operates the
                                National Fisheries Research Center-Great Lakes, which assesses,pro-
                                tects, and rehabilitates fish resources and habitats in the Great Lakes.

     U.S. Department of         Three offices in the U.S. Department of Agriculture are involved with
                                the Great Lakes. The Soil Conservation Service works with states and
     Agriculture                farmers to prevent erosion and improve water quality. The Cooperative
                                Extension Service and the Agricultural Stabilization and Conservation
                                Service deliver financial. technical. and information services to farmers.

     U.S. Coast Guard           The C.S. Coast Guard helps clean up spills of pollutants, encourages
                                measures to prevent such spills. controls shipping, enforces the prohibi-
                                tion of waste discharges from ships into the Great Lakes. and enforces
                                laws regarding the handling and transfer of hazardous substances and
                                oil on the lakes.


     U.S. Geological Survey     The U.S. Geological Survey conducts several activities concerning the
                                Great Lakes and their tributaries. For example, it analyzes water flow,
                                monitors water quality, and studies surface water and groundwater. It
                                also provides technical leadership on major issues, such as the effects of
                                contaminated gi oundwater on the quality of the Great Lakes’ surface

                                Page 39                                         GAO/BWIW      Water Pollnan
Appendix III

Major Contributors to This Report

Keswrces,                 Steven L Elstein. Assistant Director
Community, and
Development Division,
Washington, D.C.
                          Anthony A. Krukowski, Regional %nagement Representative
Detroit Regional Office   Robert R. Readler. Evaluator-inCharge
                          Suzanne S. McGillen, Evaluator
                          Sarah H. Colson, Summer Intern

                           Page 40                                 GAO/RCELbSSlS7   W8ter   PoUntioo