Detailed Information on the
EPA Great Lakes Program Assessment

Determining options for ensuring Great Lakes water quality program goals are appropriately considered by other remediation programs, such as Superfund.

Developing a set of recommendations that address ways the program could improve how it targets funds while coordinating more effectively with other Federal programs.

Measure: Improve the overall ecosystem health of the Great Lakes by preventing water pollution and protecting aquatic ecosystems.

Explanation:The overall ecosystem health of the Great Lakes will be evaluated on the 40-point scale of the Great Lakes Index. The Great Lakes Index uses select Great Lakes ecosystem indicators (i.e., coastal wetlands, phosphorus concentrations, AOC sediment contamination, benthic health, fish tissue contamination, beach closures, drinking water quality, and air toxics deposition) and is based on a 1 to 5 rating system for each indicator, where 1 is poor and 5 is good. Improvements in the index and measures would indicate that fewer toxics are entering the food chain; ecosystem and human health is better protected; fish are safer to eat; water is safer to drink; and beaches are safer for swimming. Each index component represents an area involving multiple partners, but for which U.S. EPA has a significant role. Together, the indicators reflect progress toward the main program goal: protection and restoration of the physical, chemical and biological integrity of the Great Lakes Ecosystem. The chemical goal is represented by the indicators for Phosphorus Concentrations, AOC Sediment Contamination, Fish Tissue Contamination, and Air Toxics Deposition. The physical goal is represented by Coastal Wetlands. The biological goal is represented by Benthic Health, Beach Closures, and Drinking Water Quality. Data for the components are tracked internally and generally reported through the State of the Lakes Ecosystem Conference (SOLEC) process. The SOLEC 2005 Technical Report presents detailed indicator reports, including listings of data sources. Data sources may include federal agencies, state and provincial agencies, municipalities, research reports and published scientific literature.

Measure: Number of Areas of Concern in the Great Lakes Basin which are restored and de-listed.

Explanation:A total of 43 Great Lakes Areas of Concern have been identified: 26 located entirely within the United States; 12 located wholly within Canada; and 5 that are shared by both countries. 30 United States or Binational Areas of Concern remain following the de-listing of an Area of Concern in 2006. Remedial Action Plans for each Area of Concern address impairments to any one of 14 beneficial uses associated with these areas. See also the explanation and evidence for questions 2.3 and 2.4. Additional information is also available at: http://www.epa.gov/glnpo/aoc/index.html

Measure: Number of Beneficial Use Impairments removed within Areas of Concern.

Explanation:Restoration of U.S. or Binational Areas of Concern will ultimately be measured by the removal of all beneficial use impairments, leading to de-listing of all of the U.S. or Binational Areas of Concern by 2025. A total of 43 Great Lakes Areas of Concern have been identified: 26 located entirely within the United States; 12 located wholly within Canada; and 5 that are shared by both countries. 30 United States or Binational Areas of Concern remain. Remedial Action Plans for each of these Areas of Concern address impairments to any one of 14 beneficial uses associated with these areas. At the end of Fiscal Year 2006, there was a total universe of 261 beneficial use impairments reported in the United States or Binational Areas of Concern. An impaired beneficial use means a change in the chemical, physical or biological integrity of the Great Lakes system sufficient to cause any of the following: -restrictions on fish and wildlife consumption -tainting of fish and wildlife flavor -degradation of fish wildlife populations -fish tumors or other deformities -bird or animal deformities or reproduction problems -degradation of benthos -restrictions on dredging activities -eutrophication or undesirable algae -restrictions on drinking water consumption, or taste and odor problems -beach closings -degradation of aesthetics -added costs to agriculture or industry -degradation of phytoplankton and zooplankton populations -loss of fish and wildlife habitat

Measure: Number of Beneficial Use Impairments removed within Areas of Concern.

Explanation:Restoration of U.S. or Binational Areas of Concern will ultimately be measured by the removal of all beneficial use impairments, leading to de-listing of all of the U.S. or Binational Areas of Concern by 2025. A total of 43 Great Lakes Areas of Concern have been identified: 26 located entirely within the United States; 12 located wholly within Canada; and 5 that are shared by both countries. 30 United States or Binational Areas of Concern remain. Remedial Action Plans for each of these Areas of Concern address impairments to any one of 14 beneficial uses associated with these areas. At the end of Fiscal Year 2006, there was a total universe of 261 beneficial use impairments reported in the United States or Binational Areas of Concern. An impaired beneficial use means a change in the chemical, physical or biological integrity of the Great Lakes system sufficient to cause any of the following: -restrictions on fish and wildlife consumption -tainting of fish and wildlife flavor -degradation of fish wildlife populations -fish tumors or other deformities -bird or animal deformities or reproduction problems -degradation of benthos -restrictions on dredging activities -eutrophication or undesirable algae -restrictions on drinking water consumption, or taste and odor problems -beach closings -degradation of aesthetics -added costs to agriculture or industry -degradation of phytoplankton and zooplankton populations -loss of fish and wildlife habitat

Measure: Average annual percentage decline for the long-term trend in concentrations of PCBs in whole lake trout and walleye samples.

Explanation:Concentrations of selected organic contaminants are measured in Great Lakes open water fish. This element of the Open Lakes Trend Monitoring Program was created to: (1) determine time trends in contaminant concentrations, (2) assess impacts of contaminants on the fishery using fish as biomonitors, and (3) assess potential risk to the wildlife that consume contaminated fish. The program collects and monitors contaminants in Great Lakes fish at alternating locations throughout the Great Lakes Basin; fish are collected at one set of sites during even years and at another set in odd years. The program began with the collection of data in Lake Michigan in 1972 and the additional lakes were added in 1976. It includes data from ten 600-700 mm lake trout (Salvelinus namaycush) whole fish composites (5 fish in each composite) from each of the lakes. Since sufficient lake trout are not found in Lake Erie, data for 400 - 500 mm walleye (Stizostedion vitreum vitreum) are used for that Lake. In FY09, the database will contain QA/QCed field data from fish collected in 2007 and all QA/QCed analytical data for fish collected between 1972 and 2006. Data from fish collected in 2007 are expected to be able to be used for reporting in 2009. Data are reported on a calendar year basis and are specific to the even or odd year sampling schedule (even year sites are only compared to other even year sites etc.) Each Great Lake is a unique environment with a distinct growth rate, food web, and chemical integrity. For this reason, a direct comparison of annual concentrations between basins is not appropriate. However, an average annual basin-wide percent decrease can be determined using an exponential decrease function, and the 1990 data as the baseline. The percent decrease of this element can be calculated and compared to the 5% reduction target to determine if the target has been met. All years of data from all lakes are plotted on the same graph, with each year containing 5 data points. An exponential decrease is then found for the entire data set and the percent decrease is calculated from the best fit line.

Measure: Average annual percentage decline for the long-term trend in concentrations of PCBs in the air in the Great Lakes basin.

Explanation:Air is a major pathway for chemicals entering the Great Lakes. PCBs are no longer produced in the U.S., but they may be released from equipment and contaminated sites containing PCBs and redistribute in the environment. Electrical equipment containing PCBs is gradually being phased out in the U.S. and Canada. Although levels of PCBs in Great Lakes water have also decreased since the 1970s, current levels can approach or exceed water quality standards for the Great Lakes. PCBs bioaccumulate up the food chain and may reach high concentrations in fish. This has brought about fish consumption advisories in the Great Lakes since PCBs can cause reproductive problems and developmental problems in infants and children. The percent decrease of this element can be calculated and compared to the 7% reduction target to determine if the target has been met.

Measure: Cubic yards of contaminated sediments remediated (cumulative) in the Great Lakes.

Explanation:Contaminated sediments are a major source of chemicals entering the Great Lakes. Contaminated sediments currently impact beneficial uses at all 30 of the U.S. Areas of Concern (AOCs). Sediment contamination is potentially linked to 11 of the 14 beneficial use impairments within the AOCs. These impacts include a wide range of recreational, habitat, economic, and environmental impairments. Contaminated sediments are the main cause of fish consumption advisories in many AOCs. Downstream dispersal of highly contaminated sediments could result in the creation of vast volumes of moderately contaminated sediments which continue to impact the environment for many decades, but where remedial alternatives become economically infeasible. Remediation of contaminated sediments provides a direct measure of sediment contamination that is no longer available to impact the Great Lakes environment. This indicator applies to remedial actions within the Great Lakes Basin (AOCs and non-AOCs).

Measure: Cost per cubic yard of contaminated sediments remediated (cumulative).

Explanation:This measure allows comparison of the actual cost of remediating Great Lakes contaminated sediments (pursuant to the Great Lakes Legacy Act) to a threshold cost of $200 per cubic yard. The target is achieved when the actual cost of contaminated sediment remediation (cumulative) pursuant to the Legacy Act is less than or equal to $200 per cubic yard. The program does not anticipate that actual costs per cubic yard would decrease each year, particularly since project costs are expected to increase as they become more complicated and disposal costs increase in future years. The estimated sediment remediation cost target of $200 per cubic yard has been determined using best professional judgment. Reference points include a 2004 effort by the U.S. Great Lakes Policy Committee and a January 2007 paper on Environmental Dredging Costs analyzing 64 completed environmental dredging projects. Targets and results will be reported on a calendar year basis. The program will use total funding as the basis of this measure, but will also track federal and non-federal dollars. Final project costs and the quantity of cubic yards of contaminated sediments will be calculated using cumulative numbers.

Is the program purpose clear?

Explanation: The authorizing legislation in the Clean Water Act (CWA) clearly states that Congress, in passing the legislation, found that (A) the Great Lakes are a valuable national resource, continuously serving the people of the United States and other nations as an important source of food, fresh water, recreation, beauty, and enjoyment; (B) the United States should seek to attain the goals embodied in the Great Lakes Water Quality Agreement of 1978, as amended by the Water Quality Agreement of 1987 and any other agreements and amendments, with particular emphasis on goals related to toxic pollutants; and (C) the Environmental Protection Agency should take the lead in the effort to meet those goals, working with other Federal agencies and State and local authorities.

In addition, the CWA lists specific functions of the Great Lakes National Program Office, including the following: in cooperation with appropriate Federal, State, tribal, and international agencies, develop and implement specific action plans to carry out the responsibilities of the United States under the Great Lakes Water Quality Agreement of 1978, as amended by the Water Quality Agreement of 1987 and any other agreements and amendments; establish a Great Lakes system-wide surveillance network to monitor the water quality of the Great Lakes, with specific emphasis on the monitoring of toxic pollutants; serve as the liaison with, and provide information to, the Canadian members of the International Joint Commission and the Canadian counterpart to the Agency; coordinate actions of the Agency (including actions by headquarters and regional offices thereof) aimed at improving Great Lakes water quality; and coordinate actions of the Agency with the actions of other Federal agencies and State and local authorities, so as to ensure the input of those agencies and authorities in developing water quality strategies and obtain the support of those agencies and authorities in achieving the objectives of the Great Lakes Water Quality Agreement (hereafter "the Agreement", or the GLWQA). s118 of the CWA refers to the GLWQA's purpose and stated goal "to restore and maintain the chemical, physical and biological integrity of the Great Lakes Basin Ecosystem". In 2002, the CWA was amended with the passing of the Great Lakes Legacy Act, which facilitates the remediation of contaminated sediment in "Areas of Concern" located wholly or partially in the United States. The importance of the Great Lakes, and the responsibilities of the Federal government with respect to them were underscored by the issuance in 2004, of Executive Order 13340 which affirmed the role of GLNPO to assist the Great Lakes Interagency Task Force (IATF) in carrying out specific functions set forth in the Order.

Evidence:
1. Great Lakes Water Quality Agreement (http://www.ijc.org/php/publications/pdf/ID609.pdf) - This is the Great Lakes Water Quality Agreement between the U.S. and Canada which was amended by protocol in l987.

2. Clean Water Act - Title 33, Chapter 26, Subchapter I, Section 1268-Great Lakes provisions ( http://uscode.house.gov/uscode-cgi/fastweb.exe?getdoc+uscview+t33t36+902+0++%28%29%20%20AND%20%28%2833%29%20ADJ%20USC%29%3ACITE%20AND%20%28USC%20w%2F10%20%281268%29%29%3ACITE) - This portion of the Clean Water Act is specific to the Great Lakes, authorizes the establishment of the Great Lakes National Program Office, and includes the Great Lakes Legacy Act.

3. Great Lakes Executive Order 13340 of May 2004. (http://www.whitehouse.gov/news/releases/2004/05/20040518-3.html) - The document is a copy of the Executive Order establishing a Great Lakes Interagency Task Force.

4. Great Lakes Governors' Priorities for the Great Lakes (http://www.cglg.org/projects/priorities/GovernorGreatLakesrestorationletter-10-1-03--Example.pdf) - Letter from the Governors to Congress with Great Lakes restoration priorities.

5. Great Lakes Legacy Act of 2002 (http://www.govtrack.us/data/us/bills.text/107/h/h1070.pdf)

Does the program address a specific and existing problem, interest, or need?

Explanation: The Great Lakes are the world's largest system of freshwater, holding 20% of the world's supply, and 90% of the U.S. supply. Thirty million people in the U.S. and Canada live in the basin. The Great Lakes are a national treasure and its ecosystem requires careful attention. The Great Lakes are inland freshwater seas, and span about 800 miles. In the U.S., the Great Lakes are considered a fourth seacoast and they contain major urbanized areas that are home to more than one-tenth of the population of the U.S. and one-quarter of the population of Canada, who rely on the Great Lakes as a source of drinking water. There are many ecologically rich areas in the basin and over thirty of the basin's biological communities and over 100 species are globally rare or found only in the Great Lakes basin. The region is the heartland of both the U.S. and Canadian economies, with activity in the basin exceeding $200 billion a year. The Region generates more than 50 percent of the total U.S. manufacturing output. About one-third of the Great Lakes basin's land is in agricultural use. The international shipping trade annually transports 50 million tons of cargo through the Great Lakes. Almost 50% of this cargo travels to and from oversea ports, especially Europe, the Middle East, and Africa. Recreation is also an important part of the economy. The annual value of the commercial and sport fishery is estimated at over $4.5 billion.

The Great Lakes have been impacted by industrial pollution and impacts of human development. Pollutants enter the Great Lakes, remaining there for long periods of time. The large surface area of the lakes, long retention times, low biological productivity, low suspended solids, and the presence of self-contained vulnerable populations, all contribute to toxic pollutants' persistence in the Great Lakes ecosystem, and their cycling in the food chain. The presence of certain chemicals in fish tissue is a threat to human health and has caused the States to issue numerous fish advisories in the lakes. Even though the levels of certain persistent toxic substances have declined in orders of magnitude in the last decade, there are still numerous fish advisories issued by the States in the Great Lakes basin. Numerous streams, rivers, and tributaries in the basin are included on EPA's List of Impaired Waters. It's estimated there are approximately 42 million cubic yards of contaminated sediments in the Great Lakes which require remediation. In addition to chemical pollution, the Great Lakes have been impacted by invasive species, habitat and species loss, nonpoint source, and biological pollution. There are over 180 invasive species in the Great Lakes causing deleterious impacts. There is also a large dead zone in Lake Erie that indicates a decline in the health of the lake and its water quality.

Because the Great Lakes cut across 2 countries, eight large industrial states, two Canadian provinces, and numerous local units of government, the Federal presence is particularly important to ensure a coordinated cooperative approach to restoration. To strengthen Great Lakes protection, Congress amended the CWA in l990 with the Great Lakes Critical Programs Act which strengthened water quality programs with respect to toxic discharges in the Great Lakes. Other statutes or Federal initiatives which include Great Lakes provisions are the Water Resources Development Act, the Oceans Protection Act, and the Great Lakes Fish and Wildlife Restoration Act of 2006.

In 2004, the President signed the Executive Order on the Great Lakes which was to improve coordination of Federal programs and to facilitate working with other partners outside the federal government so that coordinated approaches and responses to Great Lakes problems could occur. Successful protection and restoration of the Great Lakes will require the efforts of numerous federal, state, and local authorities, working together with private entities.

Evidence:
1. Clean Water Act - Title 33, Chapter 26, Subchapter I, Section 1268-Great Lakes provisions (http://uscode.house.gov/uscode-cgi/fastweb.exe?getdoc+uscview+t33t36+902+0++%28%29%20%20AND%20%28%2833%29%20ADJ%20USC%29%3ACITE%20AND%20%28USC%20w%2F10%20%281268%29%29%3ACITE) - This portion of the Clean Water Act is specific to the Great Lakes, authorizes the establishment of the Great Lakes National Program Office, and includes the Great Lakes Legacy Act.

2. Great Lakes Water Quality Agreement (http://www.ijc.org/php/publications/pdf/ID609.pdf) - This the Great Lakes Water Quality Agreement between the U.S. and Canada which was amended by protocol in l987.

3. Sediment Indicator - This sediment indicator document describes the methodology for estimating the "universe" of contaminated sediment requiring remediation in the Great Lakes Basin.

4. Estimates of Great Lakes Sediment Remediation Needs - March 14, 2005 - Great Lakes States produced best professional judgement estimates of sediment volumes to be remediated in the Great Lakes Basin, low and high end costs, and a time line, for remediating those sediments. This information allows the GLNPO sediment program to determine the "universe" of contaminated sediment that might require remediation, know the magnitude of the problem, and know who our potential partners may be.

5. U.S. Ocean Action Plan of 2004 (http://ocean.ceq.gov/actionplan.pdf) - The Great Lakes were included in the Ocean Action Plan (see p. 18) 10. Contaminated Sediments Sites in Great Lakes (http://www.glin.net/aocstrategyteam/documents/RemediationEstimatesJan05.xls) - State estimates to USPC.

6. Executive Order Report to the President ( http://www.epa.gov/grtlakes/collaboration/final_rttp_10282005.pdf) - Report to POTUS outlining progress under Executive Order 13340. The report outlines activities and roles of the various federal agencies involved in the Great Lakes and outlines initial efforts by the IATF to implement the Order. Also contains a glossary of acronyms

7. Great Lakes Binational Toxics Strategy ( http://binational.net/bns/strategy_en.pdf) - Copy of the Great Lakes Binational Toxics Strategy developed by Canada and the U.S.

8. Great Lakes Governors' Priorities for the Great Lakes (http://www.cglg.org/projects/priorities/GovernorGreatLakesrestorationletter-10-1-03--Example.pdf) - Letter from the Governors to Congress with Great Lakes restoration priorities.

9. Great Lakes Executive Order 13340 of May 2004. (http://www.whitehouse.gov/news/releases/2004/05/20040518-3.html) - The document is a copy of the Executive Order establishing a Great Lakes Interagency Task Force.

10. Contaminated Sediments Sites in Great Lakes (http://www.glin.net/aocstrategyteam/documents/RemediationEstimatesJan05.xls) - State estimates to USPC.

11. Estimated Sediment Volume in Great Lakes Index.

12. Need for Addressing Contaminated Sediments in Great Lakes

13. Draft Great Lakes Logic Model

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: No other program does the activities that GLNPO does. No other entity or organization is mandated by law to work across three EPA Regions, with the eight Great Lakes States, with other Federal Agencies, and with binational partners, as is GLNPO. GLNPO was specifically created to provide coordination across jurisdictions within the U.S. that have programs and resources related to Great Lakes protection and restoration efforts, and it was also directed to work with Canadian counterparts in overseeing implementation of the Great Lakes Water Quality Agreement. The U.S State Department has delegated EPA, and GLNPO specifically, the role of overseeing the implementation of the Agreement, which is an inherently governmental function. Private organizations are largely directed at advocacy and public education, or address State interests. GLNPO provides a platform of skilled scientists, analysts, specialists and managers that are uniquely situated to perform a coordination and analysis role for the Great Lakes. GLNPO does this through a number of forums, including the Binational Executive Committee, which oversees implementation of the Great Lakes Water Quality Agreement, and also through the Great Lakes Interagency Task Force (IATF) and Regional Working Group (RWG) which was formed by Executive Order in 2004 to improve the Federal governments' management of programs and activities related to the Great Lakes. The IATF/RWG has a near term action plan and workplan which ensures Agencies are coordinating programs and that work is not duplicative or redundant . The RWG has a weekly conference call where programs, issues, and resources are discussed to keep regional officials informed of program activities, status, and opportunities for collaborative work. The program works through partnerships and other complementary efforts with non governmental partners to ensure the most important priorities are undertaken, and activities are directed to the most important problems.

Evidence:
1. Executive Order Report to the President ( http://www.epa.gov/grtlakes/collaboration/final_rttp_10282005.pdf) - Report to POTUS outlining progress under Executive Order 13340. The report outlines activities and roles of the various federal agencies involved in the Great Lakes and outlines initial efforts by the IATF to implement the Order. Also contains a glossary of acronyms.

2. Final Rule - Implementation of the Great Lakes Legacy Act of 2002.(http://www.epa.gov/greatlakes/sediment/legacy/GLLARuleFederalRegister.pdf)

3. Great Lakes Executive Order 13340 of May 2004. (http://www.whitehouse.gov/news/releases/2004/05/20040518-3.html) - The document is a copy of the Executive Order establishing a Great Lakes Interagency Task Force.

4. Clean Water Act - Title 33, Chapter 26, Subchapter I, Section 1268-Great Lakes provisions ( http://uscode.house.gov/uscode-cgi/fastweb.exe?getdoc+uscview+t33t36+902+0++%28%29%20%20AND%20%28%2833%29%20ADJ%20USC%29%3ACITE%20AND%20%28USC%20w%2F10%20%281268%29%29%3ACITE) - This portion of the Clean Water Act is specific to the Great Lakes, authorizes the establishment of the Great Lakes National Program Office, and includes the Great Lakes Legacy Act.

5. Great Lakes Program Organization

6. Draft Great Lakes Logic Model

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The Great Lakes program was the first geographic based program specifically recognized by law and has become an international model of environmental and natural resources management. GLNPO spearheads U.S. partners to work together both nationally and binationally to protect and restore this valuable resource. Using adaptive management approaches, GLNPO is uniquely positioned to work with public and private organizations to protect and restore the integrity of the ecosystem by providing state of the art information and services, and by demonstrating innovative approaches to environmental stewardship. GLNPO, as well as other governmental entities must ensure that actions are being directed toward the most important problems in the Great Lakes. GLNPO does this by working with many partners to produce a State of the Great Lakes Report every two years. This report provides a updated status of the Great Lakes so the most effective actions can be applied to the highest priority problems and will ensure the program's effectiveness and efficiency. GLNPO also works with the States and private interests to clean up contaminated sediments in Areas of Concern. Areas of Concern, defined by the GLWQA as having beneficial use impairments, caused by a variety of environmental stressors, the most significant one being the presence of contaminated sediments. These sediments represent "toxic hot spots" in Great Lakes rivers and harbors and are a leading cause of fish advisories, where human health can be impacted. The Legacy Act works with other programs such as the Superfund program, to ensure that polluter pays policies are adhered to, while seeking to clean up sediments where no responsible parties have been identified. Legacy Act clean-up in AOCs is helping to fulfill commitments under the GLWQA.

Evidence:
1. Need for Addressing Contaminated Sediments in Great Lakes

2. Executive Order Report to the President ( http://www.epa.gov/grtlakes/collaboration/final_rttp_10282005.pdf) - Report to POTUS outlining progress under Executive Order 13340. The report outlines activities and roles of the various federal agencies involved in the Great Lakes and outlines initial efforts by the IATF to implement the Order. Also contains a glossary of acronyms.

3. Great Lakes Legacy Act of 2002 (http://www.govtrack.us/data/us/bills.text/107/h/h1070.pdf)

4. Final Rule - Implementation of the Great Lakes Legacy Act of 2002.(http://www.epa.gov/greatlakes/sediment/legacy/GLLARuleFederalRegister.pdf)

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The Great Lakes National Program Office targets resources toward high priority environmental problem areas determined through interaction with partners at the State, Tribal, Federal, and binational levels. Executive Order 13340 directs resources and activities to "focus on outcomes such as clean water, sustainable fisheries, and biodiversity of the Great Lakes system". The work of all the government, tribal, and non-government partners working to improve the Lake ecosystem is coordinated, duplication of funding is avoided, and funding is directed towards programs and issues that need to be addressed through efforts including: the 2002 Great Lakes Strategy, Near-term actions of the Interagency Task Force, continuing collaboration through the Great Lakes U.S. Policy Committee, bi-ennial Lakewide Management plan updates, Remedial Action Plans, and and the commitments set forth in the binational Great Lakes Water Quality Agreement.

GLNPO uses Agency and Program guidance, its funding processes, and grant and contract management policies to assure that resources are used effectively to meet its mission and to reach intended beneficiaries. GLNPO management aligned resource levels for the principal GLNPO programs to support needs identified through the 2002 Great Lakes Strategy. It reviews GLNPO results and budgets annually, and makes adjustments in conjunction with Agency budgets and priorities, with a focus on protection and restoration of beneficial uses of the Great Lakes and their Areas of Concern so that Great Lakes ecosystem is available to intended beneficiaries for commercial and recreational uses. Beginning with the GLNPO 2003 Funding Guidance, Great Lakes funding priorities for Regions 2, 3, and 5 were consolidated to improve coordination and to avoid potential duplication. To ensure appropriate targeting, U.S.EPA also invites comment on Great Lakes priorities through dissemination of draft Agency National guidance.

Grants and IAGs are issued under GLNPO's CWA section 118. Outcomes related to program purpose and goals are documented through grant reporting requirements as described in GLNPO Grant terms and conditions. Annual grant work plans and associated budgets are approved by EPA Project Officers and used to ensure that resources reach beneficiaries while supporting Program goals. Workplans and grantee performance monitoring reflect achievement of tasks that have been designed to contribute to the Program's purpose. Selection criteria for GLNPO competitive grants place the highest weight on achieving identified environmental outcomes and downgrade proposals for duplicative funding. The state clearinghouse process prevents duplicative funding by affording State review of grant applications.

GLNPO uses the Legacy Act Implementation Rule to better address the overall GLLA goals and to specify a process and a roadmap to effectively and efficiently target GLLA resources to priority contaminated sediment sites in Areas of Concern. This rule details the GLLA process for identification, evaluation, selection, and implementation of projects for funding. The rule outlines a 3-step process, each specifying requirements and supporting documentation: Step 1: Project Identification Step 2: Project Evaluation Step 3: Project Selection and funding In the Step 2 evaluation GLNPO, with assistance from applicable U.S.EPA programs, assigns each project to 1 of 4 categories based on the project's enforcement or regulatory status, thus determining cost share requirements for the non-federal sponsor. Also in Step 2, projects are scored to identify projects that are technically sound and which represent the best use of program resources. The process encourages and rewards selection of projects that exceed the minimum non-Federal cost-shared requirements for its respective project category. This further ensures the most efficient use of the GLLA funds.

Evidence:
1. GLNPO 2003 Funding Guidance ( http://www.epa.gov/glnpo/fund/2003guid/index.html)

2. GLNPO 2006 Funding Guidance ( http://www.epa.gov/glnpo/fund/2006guid/2006guid.pdf)

3. Need for Addressing Contaminated Sediments in Great Lakes

4. U.S.EPA National Guidance (http://www.epa.gov/ocfopage/npmguidance/owater/2008/draft_npmguidance.pdf) - Baselines, Annual Measures, and Targets. pp 39-41.

5. Great Lakes Executive Order 13340 of May 2004. (http://www.whitehouse.gov/news/releases/2004/05/20040518-3.html) - The document is a copy of the Executive Order establishing a Great Lakes Interagency Task Force.

6. Great Lakes Legacy Act of 2002 (http://www.govtrack.us/data/us/bills.text/107/h/h1070.pdf)

7. Executive Order Report to the President ( http://www.epa.gov/grtlakes/collaboration/final_rttp_10282005.pdf) - Report to POTUS outlining progress under Executive Order 13340. The report outlines activities and roles of the various federal agencies involved in the Great Lakes and outlines initial efforts by the IATF to implement the Order. Also contains a glossary of acronyms.

8. Final Rule - Implementation of the Great Lakes Legacy Act of 2002.(http://www.epa.gov/greatlakes/sediment/legacy/GLLARuleFederalRegister.pdf)

9. Report To The House Appropriations Committee On The Great Lakes Legacy Act Of 2002. May 2006.

10. Great Lakes Governors' Priorities for the Great Lakes (http://www.cglg.org/projects/priorities/GovernorGreatLakesrestorationletter-10-1-03--Example.pdf) - Letter from the Governors to Congress with Great Lakes restoration priorities.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program has 5 specific long term performance measures that that focus on outcomes and meaningfully reflect the program purpose.

The Great Lakes Index uses select Great Lakes ecosystem indicators (i.e., coastal wetlands, phosphorus concentrations, AOC sediment contamination, benthic health, fish tissue contamination, beach closures, drinking water quality, and air toxics deposition) and is based on a 1 to 5 rating system for each indicator, where 1 is poor and 5 is good. Improvements in the index and measures would indicate that fewer toxics are entering the food chain; ecosystem and human health is better protected; fish are safer to eat; water is safer to drink; and beaches are safer for swimming.

Each index component represents an area involving multiple partners, but for which U.S. EPA has a significant role. Together, the indicators reflect progress toward the main program goal: protection and restoration of the physical, chemical and biological integrity of the Great Lakes Ecosystem. The chemical goal is represented by the indicators for Phosphorus Concentrations, AOC Sediment Contamination, Fish Tissue Contamination, and Air Toxics Deposition. The physical goal is represented by Coastal Wetlands.The biological goal is represented by Benthic Health, Beach Closures, and Drinking Water Quality.

Data for the components are tracked internally and generally reported through the State of the Lakes Ecosystem Conference (SOLEC) process. The SOLEC 2005 Technical Report presents detailed indicator reports, including listings of data sources. Data sources may include federal agencies, state and provincial agencies, municipalities, research reports and published scientific literature.

GLNPO conducts remedial or monitoring programs pertaining to the chemical indicators referenced above, and has developed these associated long term measures: - The number of Great Lakes in which the long term targets for Total Phosphorus concentration are not exceeded. Lake concentration targets are: L.Superior, 5 ug/l; L.Huron, 5 ug/l; L.Michigan, 7 ug/l; L.Ontario, 10 ug/l; L.Erie Eastern Basin, 10 ug/l; L.Erie Central Basin, 10 ug/l; L.Erie Western Basin, 15 ug/l. A General Objective of the Great Lakes Water Quality Agreement (GLWQA) is for each Great Lake to be "Free from nutrients . . . in amounts that create growths of aquatic life that interfere with beneficial uses." Targets are derived from GLWQA maximum loadings objectives for phosphorus. Recent episodes of dissolved oxygen depletion, harmful algal blooms, and nearshore growths of the nuisance alga, Cladophora, may be related to tributary loadings of phosphorus, especially in wet weather years, as well as the infestation of zebra and quagga mussels. GLNPO is supporting research, monitoring, and modeling and is collaborating with U.S. and Canadian federal, state, provincial and municipal agencies to quickly identify causes of the current situation and to seek remediation options.

- Cumulative cubic yards of contaminated sediment remediated in the Great Lakes (cumulative total since 1997). This measure will track all U.S. contaminated sediment remediated in the U.S. portion of the Great Lakes by any program. Contaminated sediments can impact human health via the bio-accumulation of toxic substances through the food chain.

- Average annual percent decline for the long-term trend in average concentrations of PCBs in whole lake trout and walleye samples. Top predator fish can be used as biological monitors of overall water quality and ecosystem health because contaminant concentrations in fish generally reflect overall contaminant levels in the environment.

- Average annual percent decline for the long-term trend in average concentrations of toxic chemicals (PCBs) in the air in the Great Lakes Basin. Air is a major pathway for chemicals entering the Great Lakes.

Evidence:
1. State of the Great Lakes 2005 -A Technical Report ( http://binational.net/solec/sogl2005_e.html)

2. Great Lakes Index (described in FY08 V&V)

3. FY 2005 Performance and Accountability Report - Goal 4 ( http://www.epa.gov/ocfopage/finstatement/2005par/par05goal4.pdf) - LT Objective met (pp.118, 136-138). Includes report on GL performance against targets.

4. Great Lakes Binational Toxics Strategy ( http://binational.net/bns/strategy_en.pdf) - Copy of the Great Lakes Binational Toxics Strategy developed by Canada and the U.S.

5. 2006-2011 U.S. EPA Strategic Plan ( http://www.epa.gov/ocfopage/plan/2006/goal_4.pdf) - Great Lakes baseline and targets in Agency Strategic Plan. Goal 4. Pages 97-98.

6. 2003-2008 U.S. EPA Strategic Plan ( http://www.epa.gov/ocfopage/plan/2003sp.pdf) - Great Lakes long term Strategic Targets, particularly the Great Lakes Index. Numbered page 94.

7. Great Lakes Index Narrative.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The Great Lakes program has specific quantified baselines, ambitious targets and timeframes for its long-term measures, as well as well-defined end targets. The Index targets and timeframes were transmitted for independent review to partners during development of the Index in 2003. It has been included in, and reviewed as part of, U.S. EPA's Strategic Plans for 2003-2008 and 2006-2011. The initial Index goal of a 2 point improvement from a baseline score of 20 by 2008 was included in the U.S. EPA 2003-2008 Strategic Plan. Improvements in the condition of the Great Lakes ecosystem come slowly; retention times for each of the Lakes ranges from 2.6 years to 191 years. The 2011 target was set by GLNPO after considering the possibility for improvement of its components. 4 components may improve by 2011: - Coastal Wetlands, because it is believed that increased monitoring will lead to restoration of identified problem areas. - Beach Closures, because it is believed that EPA-funded pollutant source identification will lead to a reduction of sources and decreased closures. - Sediment Contamination, because greater than 10% of the contaminated sediments requiring remediation is expected to be remediated by 2011. - Air Toxics Deposition, because long-term average decreases in concentrations are expected to continue.

There are also ambitious targets and timeframes for the 4 additional long term performance measures: - By 2017, long term targets for Total Phosphorus concentration will not be exceeded in all 5 Great Lakes. The target is ambitious - excess phosphorus concentration is the historical Great Lakes issue; from 1983 to the present, concentration targets have only been met in 2-4 of the Great Lakes in any single year.

- By 2011, remediate a cumulative total of 6.6 million cubic yards of contaminated sediment in the Great Lakes. The target is ambitious: from 1997 - 2005, U.S. EPA and partners, including Federal, State, Municipality, and Industrial entities, remediated an average yearly volume of 450,000 cubic yards. The 2011 target of 6.6 million cubic yards would require that Great Lakes partners remediate an average yearly volume of 516,000 cubic yards from 2006 through 2010 - a 14% increase from the 1997 - 2005 timeframe.

- Through 2011, maintain or improve an average annual 5 percent decline for the long-term trend in average concentrations of PCBs in whole lake trout and walleye samples. Concentrations have decreased as a result of very slow, natural degradation and because of remediation of contaminated sediments.

- Through 2011, maintain or improve an average 7 percent annual decline for the long-term trend in average concentrations of toxic chemicals (PCBs) in the air in the Great Lakes Basin. PCBs are highly persistent, and sediments and soils contaminated as a result of historical use and disposal are found throughout the highly industrialized Great Lakes basin. Although PCB manufacture was banned in 1977, PCBs are still in use in older electrical equipment. Great Lakes air concentrations of PCBs are also impacted by long-range transport from other areas of the world. Concentrations have decreased for the reasons cited above.

Evidence:
1. NYSDEC Review of Great Lakes Index

2. ORD and Drinking Water Reviews of Great Lakes Index

3. State Review of Great Lakes Index

4. FY 2005 Performance and Accountability Report - Goal 4 ( http://www.epa.gov/ocfopage/finstatement/2005par/par05goal4.pdf) - LT Objective met (pp.118, 136-138). Includes report on GL performance against targets.

5. Contaminated Sediment Remediation Activities in the Great Lakes Basin from 1997 through 2005 ( http://www.epa.gov/glnpo/glindicators/sediments/remediateb.html) - The contaminated sediment remediation website documents the work being undertaken in the Great Lakes Basin by GLNPO and our program partners. These maps depict the status of all contaminated sediment sites in the basin, with details of those sites worked on in a given year, including the types of contamination found. These maps currently exist for calendar years 1997 through 2005. There are also charts depicting the annual and cumulative volume of contaminated sediment remediated in the Great Lakes Basin from 1997 through 2005.

6. Sediment Indicator - This sediment indicator document describes the methodology for estimating the "universe" of contaminated sediment requiring remediation in the Great Lakes Basin.

7. Estimates of Great Lakes Sediment Remediation Needs - March 14, 2005 - Great Lakes States produced best professional judgement estimates of sediment volumes to be remediated in the Great Lakes Basin, low and high end costs, and a time line, for remediating those sediments. This information allows the GLNPO sediment program to determine the "universe" of contaminated sediment that might require remediation, know the magnitude of the problem, and know who our potential partners may be.

8. Great Lakes Binational Toxics Strategy ( http://binational.net/bns/strategy_en.pdf) - Copy of the Great Lakes Binational Toxics Strategy developed by Canada and the U.S.

9. 2006-2011 U.S. EPA Strategic Plan ( http://www.epa.gov/ocfopage/plan/2006/goal_4.pdf) - Great Lakes baseline and targets in Agency Strategic Plan. Goal 4. Pages 97-98.

10. 2003-2008 U.S. EPA Strategic Plan ( http://www.epa.gov/ocfopage/plan/2003sp.pdf) - Great Lakes long term Strategic Targets, particularly the Great Lakes Index. Numbered page 94.

11. Great Lakes Indicator - Phosphorus Concentrations (page 7)( http://www.solecregistration.ca/documents/0111 Phosphorus Concentrations (SOLEC 2006).pdf)

12. Great Lakes Index Narrative.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The Great Lakes Program has seven annual measures. These annual performance measures demonstrate progress toward achieving U.S.EPA's long term strategic goals in protecting and restoring the chemical, physical, and biological integrity of the Great Lakes ecosystem. These U.S.EPA goals represent the major portion of the indicator components making up the Great Lakes Index and are reportable annually.

Measures addressing PCBs in lake trout and walleye, PCBs in atmospheric deposition, remediation of contaminated sediment, and NPDES permitted discharges pertain to protection and restoration of chemical integrity. Two of these measures are included in U.S. EPA's Strategic Plans for 2003-2008 and 2006-2011. The NPDES measure is a Program Activity Measure and is included in the Water Program's National Guidance. All of these measures directly relate to the chemical components of the Great Lakes Index (Phosphorus Concentrations, Sediment Contamination, Fish Tissue Contamination, and Air Toxics Deposition). By examining contaminant trends and removals though these indicators, we can determine whether the Great Lakes basin ecosystem is becoming healthier with regard to chemical contaminants. Annual improvements tracked by these indicators will lead directly to improvements in the Great Lakes Index.

The measures addressing Great Lakes beaches and CSO permits pertain to protection and restoration of the biological integrity of the Great Lakes basin. These measures are Program Activity Measures included in the Water Program's National Guidance. These measures relate to the Beach Closures indicator component of the Great Lakes Index. Annual progress addressing beaches and CSO permits will lead directly to improvements in the Great Lakes Index. GLNPO coordinates with, but does not implement, these programs.

The measure addressing restoration and delisting of Areas of Concern addresses a high priority International, Clean Water Act, and programmatic requirement. Annual tracking supports a long-term goal, referenced in the Agency's 2006-2011 Strategic Plan, of de-listing 8 Areas of Concern by 2011 and all Areas of Concern by 2025. The measure directly relates to this long term goal.

Great Lakes Index performance is tied to GLNPO budgets in an annual measure comparing the GLNPO budget to index value.

Evidence:
1. U.S. EPA 2008 Annual Performance Plan and Congressional Justification ( http://www.epa.gov/ocfo/budget/2008/epm.pdf) - Performance measures, tied to budgets, contained on pp. 72ff, pp.258ff.

2. FY 2005 Performance and Accountability Report - Goal 4 ( http://www.epa.gov/ocfopage/finstatement/2005par/par05goal4.pdf) - LT Objective met (pp.118, 136-138). Includes report on GL performance against targets.

3. EPA Can Better Implement Its Strategy for Managing Contaminated Sediments. IG Report No. 2006-P-00016. March 15, 2006 ( http://www.epa.gov/oig/reports/2006/20060315-2006-P-00016.pdf) - P 1. contaminated sediments is a health problem. P.12. measures demonstrate progress toward LT goals. Pp. 13-14. Superfund and lack of coordination aren't enough; however, EPA cannot assure that resources it expends on contaminated sediments provide the most effective and efficient solutions. p 14. Watershed approach would help.

4. 2003-2008 U.S. EPA Strategic Plan ( http://www.epa.gov/ocfopage/plan/2003sp.pdf) - Great Lakes long term Strategic Targets, particularly the Great Lakes Index. Numbered page 94.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The program has baselines and ambitious quantified targets for all of its annual performance measures. The Great Lakes Program relies upon expert opinion and knowledge within GLNPO to develop targets and timeframes for its annual measures. Targets for three of these measures are included and reviewed as part of the President's budget submission. Targets for all of the annual measures are included within EPA's national water guidance that is circulated for review and comment each year in the spring, thus allowing Great Lakes partners to verify and confirm baselines and targets, and to request more, or less, ambitious targets. Targets are then revised and become commitments in the Agency's ACS. Targets for each of the annual measures are set at levels that ensure continued improvement and realization of efficiencies. They have been set at levels that are challenging, yet achievable.

Measures addressing PCBs in lake trout and walleye, PCBs in atmospheric deposition are set at levels which, if achieved, demonstrate continuous environmental improvement (5% and 7% average annual long-term reductions, respectively). These goals resulted from consultation with partners following consideration of long term monitoring results.

The program chooses ambitious targets, evidenced by cases where some targets are not met. Following successive years of missing AOC delisting targets, GLNPO has since done additional coordination internally and coordinated more closely with State programs, targeted additional resources, and established new, more achievable, targets.

The Great Lakes program has specific and ambitious annual targets for remediating a cumulative total of 6.6 million cubic yards of contaminated sediment in the Great Lakes Basin by 2011. The target is ambitious: from 1997 - 2005, U.S. EPA and partners, including Federal, State, Municipality, and Industrial entities, remediated an average yearly volume of 450,000 cubic yards. The 2011 target would require that Great Lakes partners remediate an average yearly volume of 516,000 cubic yards from 2006 through 2010 - a 14% increase over the average during the 1997 - 2005 timeframe.

Long term targets for NPDES permitted discharges and CSO's were set through a collaborative process among U.S.EPA programs and State partners as part of the 2002 Great Lakes Strategy. When those targets were not achieved, U.S.EPA established new, more achievable annual targets in conjunction with development of the annual Office of Water Guidance. NPDES targets (reflecting Great Lakes Water Quality Guidance standards) are unique to the Great Lakes and a number of permits are backlogged for difficult technical issues regarding issues such as Thermal dischargers, Whole Effluent Toxicity Reasonable Potential, Mercury Reasonable Potential, TMDL Implementation, and other permit complexities. The current CSO goal is a clarified, now consistent version of what was originally developed as a goal in the 2002 Great Lakes Strategy, and is a Great Lakes subset of U.S. EPA's national CSO measure. The Great Lakes target (78% for FY2008) is more ambitious than the national target (75%).

Evidence:
1. U.S.EPA National Guidance (http://www.epa.gov/ocfopage/npmguidance/owater/2008/draft_npmguidance.pdf) - Baselines, Annual Measures, and Targets. pp 39-41.

2. U.S. EPA 2008 Annual Performance Plan and Congressional Justification ( http://www.epa.gov/ocfo/budget/2008/epm.pdf) - Performance measures, tied to budgets, contained on pp. 72ff, pp.258ff.

3. FY 2005 Performance and Accountability Report - Goal 4 ( http://www.epa.gov/ocfopage/finstatement/2005par/par05goal4.pdf) - LT Objective met (pp.118, 136-138). Includes report on GL performance against targets.

4. 2003-2008 U.S. EPA Strategic Plan ( http://www.epa.gov/ocfopage/plan/2003sp.pdf) - Great Lakes long term Strategic Targets, particularly the Great Lakes Index. Numbered page 94.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: All of the many Great Lake Program partners commit to and work toward the annual and/or long-term goals of the program. There are two main categories of partners for the Great Lakes Program Office: (1) the other federal agencies, states, local authorities, and academic institutions that participate in the restoration effort, and (2) grantees that are required to work towards the annual and long-term goals of the program as required in the grant agreements. The federal/state/local partners committed to annual and long-term goals as partners to the 2002 Great Lakes Strategy. After the Executive Order was issued, partners signed the Great Lakes Regional Collaboration's Declaration of Intent, and later supported the GLRC Resolution and committed to work toward specific restoration goals. The Federal Near Term Actions were an outgrowth of the GLRC Strategy. Other plans such as the Lakewide Management Plans and Remedial Action Plans also contain specific actions needed and committed to by a variety of partners at a variety of different scales. Great Lakes States commit to specific action supporting the annual and long term goals as part of their Great Lakes grant workplans. They, and other grantees, who can also be partners, are required to measure and report their performance as it relates to EPA's strategic plan through grant deliverables and written commitments as required under EPA's Environmental Results Policy. U.S.EPA's Memorandum of Agreement with the Corps. of Engineers also indicates support for the long term goal of protection and restoration of the Great Lakes.

Evidence:
1. State (IN) LaMP/RAP Grant Workplan

2. Great Lakes Ecosystem Professional Services Support Contract - See objective on page C1.

3. State (OH) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

4. State (MI) LaMP and RAP Grant Workplan - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

5. State (WI) LaMP and RAP Grant Workplan - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

6. State (MN) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

7. State (IL) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

8. Great Lakes Strategy 2002- A Plan for the New Millenium ( http://www.epa.gov/grtlakes/gls/gls2002.pdf) - A strategy developed in response to partners as well as an IG audit finding that an updated strategic plan for the Great Lakes was needed. Issued in 2002 by the U.S Policy Committee.

9. Executive Order Report to the President ( http://www.epa.gov/grtlakes/collaboration/final_rttp_10282005.pdf) - Report to POTUS outlining progress under Executive Order 13340. The report outlines activities and roles of the various federal agencies involved in the Great Lakes and outlines initial efforts by the IATF to implement the Order. Also contains a glossary of acronyms.

10. GLNPO Funding Guidance ( http://www.epa.gov/glnpo/fund/2006guid/index.html) - Grants must support program goals. Criteria require accountability, efficiency and effectiveness, and financial management. Establishes competitive process and requires oversight. Performance information required to be collected and reported.

11. 2003-2008 U.S. EPA Strategic Plan ( http://www.epa.gov/ocfopage/plan/2003sp.pdf) - Great Lakes long term Strategic Targets, particularly the Great Lakes Index. Numbered page 94.

12. U.S.EPA Environmental Results Order 5700.7 ( http://www.epa.gov/ogd/grants/award/5700.7.pdf)

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: There are numerous independent evaluations conducted on a regular basis, and as needed, for these purposes, including:

(1) The International Joint Commission (IJC) reports at least biennially on matters relating to water quality in the Great Lakes, including progress towards achieving the purpose and the specific provisions of the Great Lakes Water Quality Agreement (the Agreement). In these reports, the IJC reviews the U.S. and Canadian Governments' implementation on various requirements in the Agreement. The International Joint Commission is an independent binational organization established by the Boundary Waters Treaty of 1909.

(2) The Executive Committee, which oversees the Great Lakes Regional Collaboration Strategy, developed an Implementation Framework document which outlines how implementation and reporting of the Strategy will be done. The Executive Committee is comprised of entities representing parts of the Collaboration but not necessarily the federal government. In that manner, they are independent of the Federal government. EPA is participating in this effort and is also coordinating the implementation and reporting of the Federal Near Term Action Plan which represents the Federal Agencies contributions to implementing the strategy over the next two years. For more information see www.glrc.us.

(3) In the biennial State of the Lakes Ecosystem Conference process, some 500 public and private participants evaluate environmental progress in the Great Lakes using indicators believed to be necessary and sufficient to assess the health of the lakes and to help make better management decisions.

(4) The Office of Inspector General (OIG) conducts reviews of important topics and periodic program reviews of GLNPO.

(5) The GAO conducts periodic evaluations on Great Lakes program topics.

(6) Program evaluations for the monitoring program are conducted by independent, outside reviewers such that the components of the program are evaluated every five years.

Evidence:
1. SOLEC Reports ( http://www.epa.gov/glnpo/solec/)

2. IJC Thirteenth Biennial Report on Great Lakes Water Quality ( http://www.ijc.org/en/publications/pdf/13br_e.pdf)

3. IJC Twelfth Biennial Report on Great Lakes Water Quality ( http://www.ijc.org/php/publications/html/12br/english/report/index.html)

4. IJC Eleventh Biennial Report on Great Lakes Water Quality ( http://www.ijc.org/php/publications/html/11br/english/report/index.html)

5. Improving EPA's Great Lakes Program, OIG Report No. 99P00212. September 1999. ( http://www.epa.gov/oig/reports/1999/9p00212.htm)

6. The Great Lakes Water Quality Agreement: Promises to Keep, Challenges to Meet. March 2007. Alliance for the Great Lakes, the Biodiversity Project, the Canadian Environmental Law Association, and Great Lakes United. ( http://www.greatlakes.org/news/pdf/Promises_to_Keep_Challenges_to_Meet.pdf) - Progress has been made by Great Lakes programs, but more is needed.

7. Great Lakes - An Overall Strategy and Indicators for Measuring Progress are Needed to Better Achieve Restoration Goals (GAO-03-515). April 2003. ( http://www.gao.gov/new.items/d03515.pdf)

8. Great Lakes - EPA Needs to Define Organizational Responsibilities Better for Effective Oversight and Cleanup of Contaminated Areas (GAO-02-563). May 2002. ( http://www.gao.gov/new.items/d02563.pdf)

9. Great Lakes: Organizational Leadership and Restoration Goals Need to be Better Defined for Monitoring Restoration Progress (GAO-04-1024). September 2004. ( http://www.gao.gov/new.items/d041024.pdf)

10. International Joint Commission Independence, Description, and Purpose. ( http://www.ijc.org/en/background/biogr_commiss.htm)

11. IADN Program and Peer Review (2002) ( http://www.epa.gov/glnpo/monitoring/air/iadn/iadn.html) - First two links.

12. Fish Monitoring Program Review (2005) ( http://www.epa.gov/glnpo/glindicators/fishtoxics/GLFMP Review Document 6.14.05.pdf)

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Budget requests are explicitly tied to accomplishment of the annual and long-term performance goals in the Agency's Strategic Plan. Annual budget requests specify projected outputs and outcomes related to the budget request. The quantity of sediment to be remediated is directly tied to the amount of funding the program receives. There is an annual discussion with OMB regarding the amount of sediment that can be remediated with a given amount of funding, and the amount varies depending on the funding amount. When proposed funding substantially increases for the Legacy Act program, the targeted number of projects and the targeted amount of remediation increases proportionately. When proposed funding decreases, the targets decrease proportionately. The GLNPO budget is directly related to priority problem areas identified in strategic plans and responds to environmental problems in the Great Lakes. The budget also requests funds for work relating to GLNPO's role in monitoring, information management and coordination regarding Great Lakes problems and issues that are articulated in the GLRC Plan and the Near Term Action Plan. The budget submission is coordinated with and developed through the Office of Water in EPA HQ.

Evidence:
1. U.S. EPA 2008 Annual Performance Plan and Congressional Justification ( http://www.epa.gov/ocfo/budget/2008/epm.pdf) - Performance measures, tied to budgets, contained on pp. 72ff, pp.258ff.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: In April of 2003, the Government Accountability Office (GAO) issued its report "Great Lakes: An Overall Strategy and Indicators for Measuring Progress are Needed to Better Achieve Restoration Goals" (GAO-03-515). GAO evaluated the restoration strategies used by federal and state programs and how they are coordinated, and assessed overall environmental progress made in basin restoration. In its evaluation, GAO described the 2002 Great Lakes Strategy to be "largely a description of existing and planned program activities..." GAO recommended that the U.S.EPA Administrator ensure that the Great Lakes National Program Office fulfills its coordination responsibilities and develop an overarching Great Lakes strategy.

These issues have been addressed. The Great Lakes U.S. Policy Committee released a Great Lakes Strategy in 2002, outlining goals and efforts that would be undertaken by Federal Agencies as well as State and Tribal partners. Work has been done to further implementation of the 2002 Great Lakes Strategy at existing resource levels. Although U.S.EPA did not agree with GAO that an additional strategy was required, in May 2004 the President issued Executive Order 13340 establishing two major Great Lakes efforts: A "Great Lakes Interagency Task Force" and a Great Lakes Regional Collaboration of National Significance" (GLRC). The USEPA Administrator is designated to lead the task force. GLNPO was cited in the Executive Order and given the responsibility of providing assistance in carrying out the goals of the Order. The Task Force brings together ten Cabinet secretaries and federal agency heads to coordinate restoration of the Great Lakes, focusing on outcomes like cleaner water and sustainable fisheries and targeting measurable results. In December of 2005, participants in the collaboration developed a Great Lakes Regional Collaboration Strategy which did satisfy the issues raised by GAO. Federal agencies are using it to guide their Great Lakes activities, including implementation of a Near Term Action Plan, addressing priority issues in 8 areas included in the Strategy. EPA involvement includes coordinating responses to new aquatic invasive species; coordinating Federal programs and activities regarding wetlands; developing policy on managing peak flows at sanitary sewer plants; conducting surveillance for emerging chemicals of concern; and implementation of the Great Lakes Legacy Act. In addition, Lakewide Management Plans are updated every two years for each lake to assists in setting goals at a lakewide level and to identify the most important activities needed to reach these goals.

The Report to the President on the implementation of the Great Lakes Executive Order states that the Great Lakes Regional Collaboration Strategy "does not take into account the ongoing Federal, state, tribal, and local investments in the Great Lakes and how to focus those substantial resources to maximize results." The commitment by Federal agencies to implement Near Term Actions mentioned above corrects that deficiency on the part of the federal partners.

The question of the need for an overarching Great Lakes Strategy was also raised in a proposal by GAO, the EPA Inspector General, and OMB for consideration as a "challenge" during the 2006 FMFIA process. For the reasons given above, it was determined that it was not necessary to identify this issue as a "challenge."

Evidence:
1. U.S. Response to the Eleventh Biennial Report of the IJC ( http://www.epa.gov/glnpo/glwqa/ijc11th/report.html)

2. Great Lakes Strategy 2002- A Plan for the New Millenium ( http://www.epa.gov/grtlakes/gls/gls2002.pdf) - A strategy developed in response to partners as well as an IG audit finding that an updated strategic plan for the Great Lakes was needed. Issued in 2002 by the U.S Policy Committee.

3. United States Policy Committee Charter - The U.S. Policy Committee was reestablished and reinvigorated in 1999 and spearheaded the development and implementation of a Great Lakes Strategic Plan which was completed in 2002. The USPC is comprised of representatives of State, Tribal, and Federal agencies. The USPC coordinates overall Great Lakes priorities and coordinates the development of actions and commitments by each Agency to achieve the goals, objectives, and actions in the Strategy. EPA chairs the USPC and it is also used as a forum to coordinate U.S. agencies positions relative to implementation of the GLWQA.

4. Executive Order Report to the President ( http://www.epa.gov/grtlakes/collaboration/final_rttp_10282005.pdf) - Report to POTUS outlining progress under Executive Order 13340. The report outlines activities and roles of the various federal agencies involved in the Great Lakes and outlines initial efforts by the IATF to implement the Order. Also contains a glossary of acronyms.

5. Report To The House Appropriations Committee On The Great Lakes Legacy Act Of 2002. May 2006.

6. Great Lakes - An Overall Strategy and Indicators for Measuring Progress are Needed to Better Achieve Restoration Goals (GAO-03-515). April 2003. ( http://www.gao.gov/new.items/d03515.pdf)

7. Great Lakes: Organizational Leadership and Restoration Goals Need to be Better Defined for Monitoring Restoration Progress (GAO-04-1024). September 2004. ( http://www.gao.gov/new.items/d041024.pdf)

8. U.S. Response to the Twelfth Biennial Report of the IJC ( http://www.epa.gov/glnpo/glwqa/ijc12th/Draft 5-13-05.pdf)

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: While the agency does collect performance information, it is unclear how it is used to manage the program and improve performance.

Evidence: 9. State (IN) LaMP/RAP Grant Workplan

11. U.S.EPA Quarterly Management Report (QMR) - U.S.EPA uses QMR, including Near Term Actions, for program managment fish. 16. Grantee Progress Report

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Federal managers and staff are held accountable for cost, schedule, and performance results through their annual performance agreements which are linked to the environmental outcomes listed in EPA's strategic plan. Staff project officers are held accountable for ensuring that all grant and contract policies and procedures are followed. Grantees are held accountable as they are required to submit semi-annual reports that contain narratives documenting progress against the grant workplan. These reports enable the Project Officer to know if the recipient is meeting the goals of the project. Restrictions are imposed upon grantees who do not perform. Such grantees also receive poorer scores in subsequent grant competitons and are likely to be replaced by other grantees. The Director and three Branch Chiefs in GLNPO have performance standards that are linked to Agency strategic goals and are accountable also for material, money, information, and systems to produce work which accomplishes the strategic objectives. Federal program partners which are a part of the Federal Interagency Task Force made commitments which are documented in the Federal Near Term Action Plan. GLNPO, on behalf of chair of the Regional Working Group, tracks those commitments and reports to that group so that agencies are held accountable for their commitments. Reporting on Great Lakes restoration efforts is also done through such means as the IJC's biennial and semi-annual meetings, the Binational Executive Committee, the GLRC Executive Committee, and the Great Lakes Interagency Task Force. GLNPO also provides the public access to a wide array of information including LaMP updates, using its website (over 1.2 million visits in the past year) and through other news media. Because an interested public monitors and discusses this information and corresponds with U.S. EPA, Congress, and the Administration, the public, U.S. EPA, Congress and the Administration also hold the Great Lakes program accountable for cost, schedule, and performance results.

Evidence:
1. State (MN) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

2. 2002 Great Lakes Strategy Tracking - Accountability to GL USPC.

3. Federal Interagency Task Force Near Term Actions - The Near Term Actions describe the priority actions contained in the GLRC Strategy that were committed to by the Federal government to be of a high priority for accomplishment over the first few years of the implementation of the Strategy.

4. Lakewide Management Plans ( http://www.epa.gov/glnpo/gl2000/lamps/index.html) - Partner progress on a Lake-scale is collected and reported via LaMP updates.

5. Biology Program Recommendation Memo - Failure to deliver reports led to poor reviews and a new grantee. (Background-Paragraph C)

6. Grantee Accountability Letter - Grantee held accountable for performance and restrictions imposed.

7. Project Officer Performance Standard - Copy of generic performance standards used by GLNPO for Project Officers for 2005 through 2007 rating periods.

8. Monthly GLNPO Grant Balances - PO's and management are provided with grant balances monthly as a financial check on progress.

9. Near Term Action Plan Status - Status collected and reported bi-annually.

10. Regional Working Group Plan Status - Tracks the activities that fall under the Executive Order.

11. GLNPO Funding Guidance ( http://www.epa.gov/glnpo/fund/2006guid/index.html) - Grants must support program goals. Criteria require accountability, efficiency and effectiveness, and financial management. Establishes competitive process and requires oversight. Performance information required to be collected and reported.

12. State (IL) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

13. State (WI) LaMP and RAP Grant Workplan - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

14. State (MI) LaMP and RAP Grant Workplan - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

15. State (OH) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

16. State (IN) LaMP/RAP Grant Workplan

17. U.S.EPA Quarterly Management Report (QMR) - U.S.EPA uses QMR, including Near Term Actions, for program managment.

18. 2002 GL Strategy Tracking Letter

19. Grantee Audit - Report on Compliance.

20. Grantee Non-Compliance Letter - Grantees which do not comply with grant requirements are held accountable.

21. GLNPO Director Perfomance Accountability Standard

22. Branch Chief Performance Standard on Accountability

23. GLNPO Web Usage

24. GLNPO Site Visit Policy/Plan

25. Grantee Progress Report

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: GLNPO funds are obligated consistently with the overall program plan, as tracked by annual budget sheets. GLNPO Project officers oversee spending by grantees and contractors, ensuring that they use the funding for its intended purpose and in a timely fashion. The program has controls so that grantees and contractors use funds for their intended purpose and that management is alerted to take action should that be required. GLNPO obligates almost all of its funds within the first year of their appropriation, even though the funds are authorized for 2 years. (For Geographic Program Great Lakes, first year usage was: FY02- 99%; FY03-95%; FY04-87%; FY05-93%; FY06-93%. A lesser percentage of Legacy Act funds is obligated in the first year.) U.S.EPA obligates all of the funds for both parts of the program before authorization expires in the second year. Programs and partners establish schedules for obligations that properly correspond to the resource needs of the program plan, thus providing for sufficient and timely funding for monitoring activities, grant funding, and State program activities. GLNPO has procedures in place to track and report actual expenditures, comparing them against the intended use. As needed, GLNPO takes timely and appropriate action to correct audit findings when funds are not spent as intended. Program awards are reported promptly and accurately in IGMS and other EPA financial systems.

Evidence:
1. GLNPO Internal 06 Budget Tracking- Spreadsheet is also tracking commitments at end-of-year to obligation.

2. Legacy Act Budget Status from Financial data warehouse- Provides evidence that all monies appropriated under the Great Lakes Legacy Act have been expended prior to end of the pertinent fiscal year.

3. GLNPO Budget Obligations 04-06- Non-Legacy GLNPO Budgets in Financial Data Warehouse, demonstrate obligation of funds.

4. Monthly GLNPO Grant Balances from R5- Tracks DCN drawdowns against time.

5. GLNPO Internal 05 Budget Tracking

6. GLNPO Internal 04 Budget Tracking

7. GLNPO Internal 03 Budget Tracking

8. GLNPO Internal 02 Budget Tracking

9. Legacy Act End-of-year Balances

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: GLNPO has numerous processes in place to achieve efficiencies and cost effectiveness, including regular competition for all of the major program areas. All GLNPO grants are issued pursuant to EPA's competition policy. GLNPO Management reviews and selects grants based on program priorities and also compares costs. One of the review criteria evaluates applicants' budgets. Cooperative agreements and grants are required to undergo a Cost Review Analysis by the project officer before a cooperative agreement or grant can be awarded. Grant solicitations across GLNPO, Regions, Headquarters, and other Great Lakes partner programs are also coordinated to achieve efficiencies. GLNPO has increasingly been utilizing contractors to conduct our mission. All contracted work is competed in accordance with the FAR, whether directly through EPA contracts, or indirectly, through services obtained from GSA. Ultimately, the private sector conducts the work, with the benefit of competition. Contracts are competitively bid every five years for the two vessels operated by GLNPO. Information technology improvements resulting in efficiencies and cost effective program execution include: virtual publication of products and reports online, instead of on paper, including binational.net publication of binational products, Great Lakes Binational Toxics Strategy reports, Lakewide Management Plans, the State of the Lakes Ecosystem Conference, and the Great Lakes Atlas (annual savings of about $44,000); utilization of collaboration technologies to develop better information products and facilitate cooperative decision-making while reducing travel costs and carbon emissions; and development and utilization of the GLENDA Database - an organized format for Great Lakes Environmental data with support for data quality information which has recently been expanded to include historical Great Lakes Fish data and through which data are available by request and directly on-line through GLENDA accounts.

Evidence:
1. Monitoring Efficiency Measure

2. GLNPO Funding Guidance ( http://www.epa.gov/glnpo/fund/2006guid/index.html) - Grants must support program goals. Criteria require accountability, efficiency and effectiveness, and financial management. Establishes competitive process and requires oversight. Performance information required to be collected and reported.

3. GLNPO Web Usage

4. IADN Cost Efficiencies

5. Ship Request for Proposal - Competitive RFP Process to ensure cost savings.

6. Competitive offers on ship contract

7. Ship Award

Does the program collaborate and coordinate effectively with related programs?

Explanation: Pursuant to the mandate in Section 118 of the Clean Water Act to "coordinate action of the Agency with the actions of other Federal agencies and state and local authorities..." the Great Lakes National Program Office (GLNPO) is engaged in extensive coordination efforts with state, Tribal, and other Federal agencies, as well as with our counterparts in Canada pursuant to the Great Lakes Water Quality Agreement (GLWQA). We coordinate and collaborate with our Canadian counterpart agencies through implementation of the GLWQA and the Binational Executive Committee. For U.S. efforts, EPA leads a Federal Interagency Task Force charged with increasing and improving collaboration and integration among Federal programs involved in Great Lakes environmental activities. Responding to Executive Order 13340, the President established two major Great Lakes efforts: a "Great Lakes Interagency Task Force" and a Great Lakes Regional Collaboration of National Significance" (GLRC). The IATF brings together ten Cabinet department and Federal agency heads to coordinate restoration of the Great Lakes, focusing on outcomes, such as cleaner water and sustainable fisheries, and targeting measurable results. In December 2005, the GLRC (including representatives from Federal agencies, led by EPA; Great Lakes Governors, Mayors, and Tribes; and the Great Lakes States Congressional Delegation) developed a Great Lakes Regional Collaboration Strategy. This Strategy is being used to guide the Great Lakes environmental efforts. Coordination by GLNPO supports both the GLWQA and GLRC: GLNPO monitoring involves extensive coordination among state, federal, Canadian and provincial partners, both in terms of implementing the monitoring program, and in utilizing results from the monitoring to manage environmental programs: GLNPO's sediments program works closely with the states and the Corps regarding dredging issues; implementation of the Binational Toxics Strategy involves extensive coordination with Canada and the Great Lakes States; GLNPO works closely with states, Tribes, FWS, and NRCS in addressing habitat issues; and EPA also coordinates with these partners regarding development and implementation of Lakewide Management Plans for each of the Great Lakes and for Remedial Action Plans for the 30 remaining U.S./binational Areas of Concern.

Evidence:
1. Binational Executive Committee Roles and Responsibilities Document

2. Federal Interagency Task Force Near Term Actions

3. Lakewide Management Plans ( http://www.epa.gov/glnpo/gl2000/lamps/index.html)

4. School Chemical Collection Program Report, Wyoming, MI - GLNPO/Air/Waste co-funded mercury collection program.

5. Great Lakes Executive Order 13340. (http://www.whitehouse.gov/news/releases/2004/05/20040518-3.html)

6. Great Lakes Cooperative Monitoring Program Fish Contaminant Monitoring Inter-Laboratory Comparison Study Survey Results - To determine potential causes for reported differences in fish contaminant results by monitoring agencies. The 3-phase plan proposed by the Cooperative Monitoring Steering Committee would include the key Great Lakes States, Tribes and agencies.

7. Integrated Atmospheric Deposition Network (IADN) ( http://www.epa.gov/grtlakes/monitoring/air_2/index.html) - US/Canada program includes: EPA & Environment Canada agencies. Authority for IADN is in Annex 15 of the GLWQA, the Canada-Ontario Agreement and Section 112(m) of the US Clean Air Act. Supports US/Canada Great Lakes Binational Toxics Strategy monitoring needs.

8. Great Lakes Coastal Wetlands Consortium ( http://www.epa.gov/glnpo/fund/wetland/index.html) - Funded through GLNPO cooperative agreement, includes scientific and policy experts from key US and Canadian federal agencies, state and provincial agencies, NGOs and others with responsibility for coastal wetlands monitoring.

9. 2002 Great Lakes Strategy Tracking - Accountability to GL USPC.

10. Federal-State AOC Coordinating Committee - Letter inviting Federal & State Remedial Action Plan Program Managers to participate in committee to review & set US AOC policies, priorities & procedures.

11. US Policy Committee Charter - USPC reestablished & reinvigorated in 1999, spearheaded the development & implementation of Great Lakes Strategic Plan which was completed in 2002. USPC members: representatives of State, Tribal and Federal agencies. USPC coordinates overall Great Lakes priorities & development of actions and commitments by Agencies to achieve goals, objectives and actions in the Strategy. EPA chairs USPC and which is also used as a forum to coordinate US agencies positions on implementation of GLWQA.

12. Near Term Action Plan Status - Status collected and reported bi-annually.

13. Regional Working Group Plan Status - Tracks Executive Order activities.

14. U.S.EPA Quarterly Management Report (QMR) - Used for program managment.

15. 2002 GL Strategy Tracking Letter

16. Lake Ontario Biodiversity Conservation Strategy ( http://conserveonline.org/workspaces/lakeontario.conservation/Lake ON Biodiversity Strategy.ppt?bcsi_scan_2D513B1514AF8B21=0&bcsi_scan_filename=Lake ON Biodiversity Strategy.ppt#256,1)

17. Lake Michigan Mass Balance Study ( http://www.epa.gov/glnpo/lmmb/) - Measured chemicals in Great Lakes and predicts effects of reducing pollutants.

18. Progress On Toxics Reduction ( http://www.epa.gov/glnpo/bns/reports/2006glbtsprogressreport.pdf)

19. Watershed Restoration White Paper

Does the program use strong financial management practices?

Explanation: Yes. The Great Lakes National Program Office follows EPA's financial management guidelines for committing, obligating, reprogramming, and reconciling appropriated funds. Each commitment, obligation, reprogramming, or disbursement is reviewed and approved by separate individuals with appropriate authority. The Agency complies with GAO's internal control standards, Treasury and OMB guidelines, as well as generally accepted accounting practices, to minimize the risks of waste, fraud, abuse, and improper payments. EPA trains staff to ensure that they understand their roles and responsibilities for invoice review and for carrying out the financial aspects of the program. The Program maintains an additional internal tracking system that supplements the Agency-wide Integrated Financial Management System (IFMS). This additional system tracks all expenditures and is regularly updated to allow a monthly management review. EPA's Region V Financial Management Office (FMO) conducts regular quality assurance reviews to assess compliance with applicable laws, regulations, and administrative guidelines. The FMO also provides the Program with timely financial information that drive program decisions and integrate financial and program performance information. EPA received an unqualified audit opinion on its FY 2006 financial statements.

Evidence:
1. U.S.EPA GLNPO FMFIA Assurance Letter (August, 2003).

2. Improving EPA's Great Lakes Program, OIG Report No. 99P00212. September 1999. ( http://www.epa.gov/oig/reports/1999/9p00212.htm)

3. Report To The House Appropriations Committee On The Great Lakes Legacy Act Of 2002. May 2006.

4. Great Lakes - An Overall Strategy and Indicators for Measuring Progress are Needed to Better Achieve Restoration Goals (GAO-03-515). April 2003. ( http://www.gao.gov/new.items/d03515.pdf)

5. Great Lakes - EPA Needs to Define Organizational Responsibilities Better for Effective Oversight and Cleanup of Contaminated Areas (GAO-02-563). May 2002. ( http://www.gao.gov/new.items/d02563.pdf)

6. Great Lakes: Organizational Leadership and Restoration Goals Need to be Better Defined for Monitoring Restoration Progress (GAO-04-1024). September 2004. ( http://www.gao.gov/new.items/d041024.pdf)

7. RAP/LaMP Responsibitly Memo. September, 2002.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: GAO's September 2004 report recommends that EPA develop controls to ensure the Great Lakes monitoring system inventory is complete, accurate, and consistent. EPA, led by GLNPO, has taken steps to plan, develop, coordinate, and develop indicators for measuring the health of the Great Lakes. GLNPO and Environment Canada continue to work together to ensure that the monitoring system inventory is complete, accurate and consistent. In October 2006, a request was made through the Great Lakes Binational Executive Committee for the 2006 annual verifications and updates to maintain and enhance the monitoring inventory database. The monitoring inventory is maintained at < www.binational.net > and allows for queries of the inventory. EPA has now completed the actions that are needed to respond to this GAO report.

The need for a plan for Great Lakes Legacy Act implementation was identified in the House Report accompanying the FY 2006 Department of Interior, Environment, and related Agencies Appropriations Bill (Public Law 109-54, HR 109-80 at page 106). Such a plan has been developed.

GAO's April 2003 report called for indicators to measuring progress. The Great Lakes program, working through the SOLEC process, is continuing to improve and enhance indicators necessary and sufficient for managment decisions.

GAO's May 2002 report and a September 1999 report by the U.S. EPA's Inspector General raised issues regarding roles with respect to LaMPs and improving EPA involvement in RAPs. Those issues were resolved by assigning GLNPO overall program management and through U.S. EPA management and organizational changes. GLNPO is now responsible for both the LaMP and RAP programs. The LaMPs are updated every two years, and they include progress of their included Areas of Concern. GLNPO staff oversee and coordinate the RAP program.

The steps taken with respect to strategic planning are discussed in question 2.8.

Evidence:
1. U.S.EPA GLNPO FMFIA Assurance Letter (August, 2003).

2. Improving EPA's Great Lakes Program, OIG Report No. 99P00212. September 1999. ( http://www.epa.gov/oig/reports/1999/9p00212.htm)

3. Report To The House Appropriations Committee On The Great Lakes Legacy Act Of 2002. May 2006.

4. Great Lakes - An Overall Strategy and Indicators for Measuring Progress are Needed to Better Achieve Restoration Goals (GAO-03-515). April 2003. ( http://www.gao.gov/new.items/d03515.pdf)

5. Great Lakes - EPA Needs to Define Organizational Responsibilities Better for Effective Oversight and Cleanup of Contaminated Areas (GAO-02-563). May 2002. ( http://www.gao.gov/new.items/d02563.pdf)

6. Great Lakes: Organizational Leadership and Restoration Goals Need to be Better Defined for Monitoring Restoration Progress (GAO-04-1024). September 2004. ( http://www.gao.gov/new.items/d041024.pdf)

7. RAP/LaMP Responsibitly Memo. September, 2002.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The Great Lakes National Program Office program has many oversight practices and accountability measures that provide sufficient knowledge of grantee activities, including periodic progress reports and final reports. Specifically, the Great Lakes National Program office requires all grantees, including non-competitive grant recipients, to provide detailed work plans and semi-annual progress reports. These reports document the progress made in achieving the objectives of the project work plans and enable the Project Officer to determine if the recipient is meeting the EPA GPRA goals, as well as the priorities and goals of GLNPO. GLNPO also requires and reviews annual and/or final project reports. Project officers are required to confirm that the workplan deliverables were produced. GLNPO also conducts on-site reviews. GLNPO has a grants tracking system which helps assist project officers in their oversight responsibilities. GLNPO's internal budget team prepares frequent reports on the status of the grants (both competitive and noncompetitive) for weekly GLNPO management meetings. When necessary, GLNPO holds meetings with the Region 5 grants office to resolve grants tracking, data base, accountability and other issues. Project officers are given the latitude to request that reporting be done more frequently than semi-annually and are encouraged to contact grantees by phone and through regular meetings. In addition to these practices, which are common to all GLNPO grants, Project Officers provide additional oversight regarding GLNPO's State grants. This additional oversight includes:

1. Regular calls regarding Lakewide Management Plan (LaMP) and Areas of Concern (AOC) progress.

2. Annual meetings to discuss project progress and to negotiate proposed workplans.

3. Regular state conference calls with the states as a whole (staff members, budget liaison and management) by the LaMP/RAP Team, the team mostly directly responsible for state grant oversight.

4. Reporting at appropriate meetings.

Evidence:
1. State (MN) Grant Communication

2. GLNPO Grant Reporting Requirements. ( http://www.epa.gov/grtlakes/fund/applicationpac/Help/HI4.pdf#page=13) (pp13-14)

3. State (OH) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

4. State (MI) LaMP and RAP Grant Workplan - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

5. State (MN) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

6. State (IL) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

7. Monthly GLNPO Grant Balances - PO's and management are provided with grant balances monthly as a financial check on progress.

8. Monthly GLNPO Grant Balances from R5 - Tracks DCN drawdowns against time.

9. GLNPO Site Visit Policy/Plan

10. State (MN) Grant Oversight Call Record

11. State (MN) Grant Oversight e-mail

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: GLNPO does collect grantee performance data on at least an annual basis. GLNPO grant requirements mandate that semi-annual reports , and sometimes more frequent reports, are to be submitted by the grantees. The state grants provide invaluable deliverables and outputs that are consistent with, and help to achieve the main mission and objectives of, the Great Lakes National Program Office under the Great Lakes Water Quality Agreement. Such work and deliverables include the delisting of Beneficial Use Impairments (BUIs) which will lead to delisting of priority Areas of Concern (AOCs) and Lakewide Management Plan work that lead to the direct reduction of toxics inputs into the Great Lakes and restoration of priority habitat areas. The information and deliverables from these reports are included in the Lakewide Management Plans (LaMPs), which are released to the public every two years, as well as the accompanying public outreach documents. However, the performance data is not easily accessible to the public on an annual basis.

Evidence:
1. GLNPO Grant Reporting Requirements. ( http://www.epa.gov/grtlakes/fund/applicationpac/Help/HI4.pdf#page=13) (pp13-14)

2. Lake Superior Critical Chemical Reduction Milestones Report ( http://www.epa.gov/glnpo/lakesuperior/2006/lschemmiles.pdf) - The Lake Superior Lakewide Work Group has completed its Critical Chemical Reduction Milestones Report, a report that details the progess toward achieving zero discharge of nine critical pollutants in the Lake Superior basin. The Lake Superior Zero Discharge Program calls for interim reduction targets for nine critical pollutants along the path toward zero discharge of these substances by 2020. The Critical Chemical Reduction Milestones Report documents progress for these nine chemicals (PCBs, mercury, toxaphene, OCS, dioxins and some cancelled pesticides) since 1990 and reviews the challenges remaining to achieve zero discharge.

3. Lake Superior Zero Discharge Demonstration Chemical Reduction Fact Sheet - The Lake Superior Zero Discharge Program set timeframes and targets for reducing nine critical pollutants to zero by 2020. This report details the reduction of these pollutants since the inception of the program (1990) to 2005. This report was carried out under the auspices of the Lake Superior LaMP with funding from GLNPO.

4. State (IN) LaMP/RAP Grant Workplan

5. State (OH) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

6. State (MI) LaMP and RAP Grant Workplan - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

7. State (WI) LaMP and RAP Grant Workplan - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

8. State (MN) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

9. State (IL) grant workplans for LaMPs and RAPs - State workplans detail support for long term goals and deliverables under LaMP and RAP programs, including actions, projects and deliverables needed for delisting BUIs, AOCs, toxics reductions and habitat restoration.

10. Grantee Reports are included in LaMP updates

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: The Great Lakes Program has both block and competitive grants. GLNPO has competed the vast majority of its grants since at least 1991. Since EPA's Competitive Policy went into effect in January, 2005, all awards have been issued pursuant to the Competition Order in effect at the time. GLNPO issues annual Funding Guidances and other Requests for Proposals to the public requesting proposals. Requests are based upon priorities developed by U.S. EPA in cooperation with its Great Lakes partners. General funding priorities and targets are derived from USEPA budgets. The Funding Guidance and other requests for proposals are posted to the GLNPO funding website and are announced via e-mail and Federal Register, among other means. The most recent Funding Guidance was announced on the GLNPO and grants.gov websites, on GLIN-Announce, and via a mailing of almost 3,000 postcards on September 1. Each RFP provides a list of evaluation criteria, which reviews use to conduct a merit evaluation of each proposal. At least three USEPA reviewers independently evaluate each project against published criteria. Reviewers are experts who are selected based on their technical and substantive expertise and who certify they have no "conflict of interest." Results are compiled and a technical review team discusses the projects and the evaluations. The technical review team develops recommendations to present to USEPA management and discusses the recommendations with management. U.S. EPA management then makes selections and funding decisions. Legacy Act Requests for Projects are not grants, but are awarded through the process outlined in the Great Lakes Legacy Act Rule, also requiring open solicitation, technical review, merit evaluations, and U.S. EPA selection.

Evidence:
1. Policy for Competition of Assistance Agreements ( http://www.epa.gov/ogd/competition/5700_5A1.pdf)

2. Final Rule - Implementation of the Great Lakes Legacy Act of 2002.(http://www.epa.gov/greatlakes/sediment/legacy/GLLARuleFederalRegister.pdf)

3. GLNPO Funding Guidance ( http://www.epa.gov/glnpo/fund/2006guid/index.html) - Grants must support program goals. Criteria require accountability, efficiency and effectiveness, and financial management. Establishes competitive process and requires oversight. Performance information required to be collected and reported.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The Great Lakes National Program Office requires grantees, including competitive grant recipients, to provide work plans and to provide progress reports and final reports, which document the progress made in achieving the project work plans. GLNPO has a standard requirement of semi-annual progress reports, which can be varied with the approval of the project officer and the project officers supervisor. The workplan and the progress reports enable the Project Officer to determine whether the recipient of a competitive grant is meeting the goals of EPA's strategic plan, Great Lakes plans, and Great Lakes priorities under the Government Performance and Results Act. The Great Lakes National Program Office meets with grantees and visits project sites as needed, and conducts performance reviews, including on-site visits. The Great Lakes National Program Office has a grants tracking system to assist project officers with their oversight responsibilities. The Great Lakes National Program Office requires quality system documentation for grants involving environmental data, and effectively oversees implementation of quality requirements.

Evidence:
1. GLNPO Grant Reporting Requirements. ( http://www.epa.gov/grtlakes/fund/applicationpac/Help/HI4.pdf#page=13) (pp13-14)

2. Monthly GLNPO Grant Balances - PO's and management are provided with grant balances monthly as a financial check on progress.

3. Great Lakes Watershed Restoration Grant Program ( http://www.nfwf.org/AM/Template.cfm?Section=Browse_All_Programs&Template=/CM/HTMLDisplay.cfm&ContentID=3843) - The Great Lakes Watershed Restoration Grant Program is a partnership of five federal agencies and the National Fish and Wildlife Foundation (NFWF) to award grants for ecological restoration projects addressing needs identified by the Great Lakes Regional Collaboration. NFWF is the grant servicing intermediary for the Great Lakes Watershed Restoration Grant Program. Grantees must adhere to the procedures established by NFWF as well as the procedures of the federal agency providing the funding. Reports regarding project progress are due to NFWF before reimbursement. In addition, semi-annual reports and a final report must be approved by NFWF and the funding agency s technical advisor before final payment.

4. GLNPO Grant Requirements, including Terms and Conditions ( http://www.epa.gov/grtlakes/fund/applicationpac/Help/HI4.pdf)

5. GLNPO Funding Guidance ( http://www.epa.gov/glnpo/fund/2006guid/index.html) - Grants must support program goals. Criteria require accountability, efficiency and effectiveness, and financial management. Establishes competitive process and requires oversight. Performance information required to be collected and reported.

6. Monthly GLNPO Grant Balances from R5 - Tracks DCN drawdowns against time.

7. Grantee Site Visit Report

8. Grantee Site Visit Report

9. GLNPO Site Visit Policy/Plan

10. Grantee Progress Report

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: GLNPO collects grantee performance data from all grantees, including competitive grant recipients. Data and reports from all grants are provided to EPA through semi-annual and/or quarterly progress reports and through final reports. However, it is unclear that this information is made available to the public in a meaningful manner.

Evidence:
1. GLNPO Grant Reporting Requirements. ( http://www.epa.gov/grtlakes/fund/applicationpac/Help/HI4.pdf#page=13) (pp13-14)

2. Pollution Prevention and Toxics Reduction Grant Program Results FY 2002-2005 Preliminary Draft March 2007

3. Lake Superior Zero Discharge Demonstration Chemical Reduction Fact Sheet - The Lake Superior Zero Discharge Program set timeframes and targets for reducing nine critical pollutants to zero by 2020. This report details the reduction of these pollutants since the inception of the program (1990) to 2005. This report was carried out under the auspices of the Lake Superior LaMP with funding from GLNPO.

4. Moving Mud - Remediating Great Lakes Contaminated Sediments (April 1997) ( http://www.epa.gov/glnpo/sediment/movemud/) - A report on the Sediment Assessment and Remediation Grants Program in the Great Lakes Basin (Fiscal Years 1993 - 1996).

5. Realizing Remediation II - July 2000 ( http://www.epa.gov/glnpo/sediment/realizing2/index.html)- An updated summary of contaminated sediment remediation activities at Great Lakes Areas of Concern.

6. Realizing Remediation - March 1998 ( http://www.epa.gov/glnpo/sediment/realizing/realcover.html) - A summary of contaminated sediment remediation activities in the Great Lakes Basin.

7. Great Lakes Watershed Restoration Grant Program ( http://www.nfwf.org/AM/Template.cfm?Section=Browse_All_Programs&Template=/CM/HTMLDisplay.cfm&ContentID=3843) - The Great Lakes Watershed Restoration Grant Program is a partnership of five federal agencies and the National Fish and Wildlife Foundation (NFWF) to award grants for ecological restoration projects addressing needs identified by the Great Lakes Regional Collaboration. Thus far, the projects funded through the Program are less than a year old. None has been completed. The partners are designing a reporting format that will examine and assess all final reports similar to the GLNPO Mining Ideas reports, which detail the environmental, stewardship and economic results of each project. Since the projects are two-year projects, the first report will be available in mid-2008. 8. Summaries of GLNPO Projects ( http://www.epa.gov/glnpo/fund/glf.html) - GLNPO Funding Page links to EPA's Grants Award page for grant information, and to periodic summaries of GLNPO Monitoring, Contaminated Sediments, Pollution Prevention, and Ecosystem Protection Grants.

9. U.S. EPA Grant Award Database ( http://yosemite.epa.gov/oarm/igms_egf.nsf/HomePage?ReadForm)

10. GLNPO Funding Guidance ( http://www.epa.gov/glnpo/fund/2006guid/index.html) - Grants must support program goals. Criteria require accountability, efficiency and effectiveness, and financial management. Establishes competitive process and requires oversight. Performance information required to be collected and reported.

11. Grantee Reports are included in LaMP updates

12. Grantee Progress Report

13. Progress On Toxics Reduction ( http://www.epa.gov/glnpo/bns/reports/2006glbtsprogressreport.pdf)

14. Results from Pollution Prevention Grants

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The Great Lakes program has demonstrated steady progress in achieving its long-term performance goal as measured by the Great Lakes Index. The Index rating started at a "20" using data available in 2002. Since then, the index rating has risen to "21.1" using data available through FY2006. The 1.1 point increase over the baseline is directly traced to improvements in phosphorus concentrations, air toxics deposition, and a wetlands sub-component. Although other components did improve over this time period (for instance, PCB concentrations in fish continued to decline and additional contaminated sediments were remediated), those improvements were not substantial enough to trigger a greater improvement in the index. (The rating was as high as 21.9, using information available through FY2005, before dropping to 21.1. This rating was the result of greater than anticipated volatility regarding the drinking water component of the index, necessitating a re-calibration of that portion of the index.)

The Great Lakes program has demonstrated good progress toward achieving its performance goal for maintaining or reducing total phosphorous levels in each Great Lake to levels not exceeding those derived from the Great Lakes Water Quality Agreement. Current levels are below those expected in Lake Superior (5 ug/l), Lake Huron (5 ug/l), Lake Michigan (7 ug/l), and Lake Ontario (10 ug/l). Progress continues to be made to meet target levels in the three basins of Lake Erie, although infestation by zebra and quagga mussels appears to have altered normal nutrient (phosphorus) processes. Levels in Eastern Lake Erie have been reduced and meet the objective (10 ug/l) in about ?? of recent years. In the shallow Western Basin, phosphorous levels are highly variable, but they, too, have been greatly reduced and now occasionally are measured at or below the target (15 ug/l). In the Central Basin of Lake Erie, where problems of the so-called Dead Zone exist, phosphorus levels have been at or below the objective (10 ug/l) in 3 of the past 7 years. Loadings of phosphorus from tributaries during wet years still impacts phosphorus levels in the Central Basin in subsequent years. Phosphorus levels and dissolved oxygen concentrations are monitored closely by GLNPO.

The Great Lakes program has demonstrated steady progress in achieving the performance goal for remediating contaminated sediments. In the five years used to establish the baseline (1997 - 2001), Great Lakes partners remediated 2.1 million cubic yards of contaminated sediments. In the five years since then (2002 - 2006), Great Lakes partners are expected to have remediated an additional 2.3 million cubic yards of contaminated sediments (1.9 million cubic yards have already been remediated from 2002 through 2005, and an additional 400,000 cubic yards in 2006 is expected). Although there is significant annual variability, based on long-term averages, volumes are expected to increase due to the remediation being accomplished through the Great Lakes Legacy Act and other activities. The GLNPO sediment program developed an ambitious target to remediate a cumulative 6.6 million cubic yards by 2011 by working with existing partners and programs, which means remediating an additional 2.2 million cubic yards from 2007 through 2010.

The Great Lakes program has demonstrated steady progress in maintaining or improving an average annual 5 percent decline for the long-term trend in average concentrations of PCBs in whole lake trout and walleye samples. Annual measurements since the baseline year have been at 5%, except for the 6% decline reported in 2005.

The Great Lakes program has demonstrated steady progress in maintaining or improving an average annual 7 percent decline of toxic chemicals (PCBs) in the air in the Great Lakes Basin. Annual measurements since the baseline year have been at 7%, except for the 8% decline reported in 2006.

Evidence:
1. Sediment Assessments ( http://www.epa.gov/glnpo/glindicators/sediments/sedqualitya.html - To assist in determining the nature and extent of sediment contamination at polluted sites, GLNPO provides the Research Vessel (R/V) Mudpuppy. Since 1993, the R/V Mudpuppy has conducted surveys at 39 locations, including 27 of the 31 Great Lakes Areas of Concern (AOCs).

2. State of the Great Lakes 2007 ( http://www.solecregistration.ca/documents/0111 Phosphorus Concentrations (SOLEC 2006).pdf) - Draft for Discussion, Indicator #111 Phosphorus Concentrations and Loadings.

3. Our Great Lakes - What is happening to them, what it means, and what you can do to help keep them great ( http://binational.net/ourgreatlakes/ourgreatlakes.pdf) - A report issued by the U.S. and Canada, led by EPA and Environment Canada that puts the status of the Great Lakes into an easy to understand format. Draws on SOLEC information.

4. Contaminated Sediment Remediation ( http://www.epa.gov/glnpo/glindicators/sediments/remediateb.html) - This website documents the steady progress made in addressing the contaminated sediment problem in the Great Lakes Basin. This information can also be found in the Great Lakes Binational Toxics Strategy (GLBTS) Annual Reports. The GLBTS Annual Reports also contain tables in the Sediments chapter that display both volume of sediment remediated and mass removed.

5. U.S. EPA FY2006 Performance and Accountability Report ( http://www.epa.gov/ocfo/finstatement/2006par/par06goal4_goal.pdf)

Does the program (including program partners) achieve its annual performance goals?

Explanation: The Great Lakes Program has consistently achieved 6 of its 7 annual performance goals for the past 5 years. The performance goals have been met each year for (i) PCBs in atmospheric deposition , (ii) remediation of contaminated sediments, (iii) NPDES permitted discharges, (iv) CSO permits, and (v) Great Lakes Beaches. The annual performance goal was also met for (vi) PCBs in lake trout and walleye for those years for which data is available (during the summer of 2007, GLNPO will report on this top predator fish data for the years 2004 and 2005). The annual performance goals for (vii) AOC delistings proved overly ambitious and have not been met. EPA has since done additional coordination internally, coordinated more closely with State programs, targeted additional resources, and established new, more achievable, annual performance goals for AOC delistings. These goals are included in Office of Water Guidance for 2007 and 2008 and are reflected in the 2006-2011 EPA Strategic Plan.

Evidence:
1. Great Lakes Binational Toxics Strategy Annual Reports ( http://www.epa.gov/glnpo/bns/documents.html#Annual%20Progress) - The Great Lakes Binational Toxics Strategy Annual Reports documents, in just one of many chapters, the steady progress made in addressing the contaminated sediment problem in the Great Lakes Basin. This information can also be found on GLNPO's website, but the Annual Report contains tables in the Sediments chapter that display both volume of sediment remediated and mass removed.

2. U.S. EPA FY2006 Performance and Accountability Report ( http://www.epa.gov/ocfo/finstatement/2006par/par06goal4_goal.pdf)

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: GLNPO anticipates meeting our efficiency measure for 2007, and we can also demonstrate other improved efficiencies or cost effectiveness in achieving program goals on an annual basis. The program's first proposed annual efficiency measure is is the annual cost per unit of environmental information collected and reported. The measure divides the total cost of the monitoring program, (including collection, analysis, reporting, ship costs and infrastructure costs), by the number of environmental measurements taken and reported annually. Environmental measurements are those measurements which are necessary and sufficient for the GLNPO monitoring program to fulfill GLWQA and CWA reporting requirements. These measurements include contaminant levels in fish (eg. PCBs, pesticides) and air, the biological communities and the basic water chemistry of the lakes. An environmental measurement is probably best explained by example: for us it might be a chemical concentration measured in one water sample, the concentration of total PCBs in a sample of lake trout tissue, or the number of individuals of a certain species of zooplankton in one net tow.. The baseline year was 2002, when the efficiency (or cost-effectiveness) was $50.15 per environmental measurement. The inflation-adjusted improved efficiency in 2006 was $36.47, a 27% improvement, because of monitoring efficiencies. Other improved efficiencies or cost effectiveness have occurred in achieving program goals on an annual basis. 1) Great Lakes Atlases were distributed online to some 150,000 users, rather than distributing paper documents, resulting in a savings of at least $44,000 2) Ecosystem restoration grants are now advertised and selected in a joint process specifying a 50/50 match and involving partner agencies in Great Lakes protection - the number of projects and the total funding for projects has thus more than doubled.

Evidence:
1. Monitoring Efficiency Measure

2. U.S. EPA FY2006 Performance and Accountability Report ( http://www.epa.gov/ocfo/finstatement/2006par/par06goal4_goal.pdf)

3. Watershed Restoration White Paper

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: The Great Lakes is one of the most complex ecosystems in the world. Spanning 800 miles between two highly industrialized countries and the home to over thirty million citizens, it has a complex governance structure which relies on numerous Federal, state, local and private interests and resources to ensure restoration goals are accomplished. The complexity of the task of ensuring the chemical, physical, and biological integrity of the basin was recognized over thirty years ago in the Great Lakes Water Quality Agreement that has served as a model of international natural resource management and governance. The Great Lakes has a wide range of institutions that work together to make progress and reports have shown that the ecosystem has favorably responded to management actions, although more needs to be done.

Evidence:
1. Hunter, D., Salzman, J. & Zaelke, D. (2007). International Environmental Law and Policy (3d ed.), pp. 885-888. New York: Foundation Press. ("One of the most widely respected efforts at joint management is the effort to manage the Great Lakes ..." - Textbooks on international policy and law citing the Great Lakes as examples of binational resources management.

2. SOLEC Peer Review - Report reviewing the State of the Great Lakes process conducted by independent peer reviewers.

3. Large Scale Ecosystem Restoration: Lessons for Existing and Emerging Initiatives - April 2005-Northeast Midwest Institute ( http://www.nemw.org/restoration.pdf) - A report comparing and analyzing various large scale restoration efforts, such as the Great Lakes, Chesapeake Bay, South Florida/Everglades, Coastal Louisiana, and the Mississippi River.

4. Save San Francisco Bay Association Evaluated Effectiveness of the Great Lakes Program ( http://www.savesfbay.org/atf/cf/%7B2D306CC1-EF35-48CC-B523-32B03A970AE5%7D/PIBT_Report.pdf) - As part of the Save San Francisco Bay Association's effort to develop a process to work toward restoration of San Francisco Bay, they evaluated six other geographic restoration programs, including the Great Lakes, as Case Studies.

5. U.S. EPA FY2006 Performance and Accountability Report ( http://www.epa.gov/ocfo/finstatement/2006par/par06goal4_goal.pdf)

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: The Great Lakes and is one of the most studied natural resource systems in the world, and one of the most unique. The Great Lakes program has been reviewed and analyzed by numerous institutions, including academia, non profit groups, industry groups, and governmental entities. Various aspects of the Great Lakes have been studied by numerous institutions from around the world and researchers and policy makers have used it as an international model of large scale restoration efforts. Most studies have marked significant progress, but some have highlighted improvements that should be made, and challenges that remain. During the past few years, there have been several seminal reviews and studies that have documented both progress and areas which need improvement. EPA responds to the areas that need improvement by taking corrective actions that will improve program performance. In many cases the studies are large in scope and address areas outside of EPA mission. EPA works with other Federal agencies to coordinate responses that involve multi agency actions.

Evidence:
1. Hunter, D., Salzman, J. & Zaelke, D. (2007). International Environmental Law and Policy (3d ed.), pp. 885-888. New York: Foundation Press. ("One of the most widely respected efforts at joint management is the effort to manage the Great Lakes ..." - Textbooks on international policy and law citing the Great Lakes as examples of binational resources management.

2. IJC Independent Studies ( http://canamglass.org/glwqa/) - The link leads to a number of studies and historical reference documents by the IJC or its boards regarding the Great Lakes Water Quality Agreement. The IJC is an independent binational commission that has a permanent reference under the Boundary Water Treaty to provide advice to the Parties under the agreement.

3. SOLEC Peer Review - Report reviewing the State of the Great Lakes process conducted by independent peer reviewers.

4. EPA Can Better Implement Its Strategy for Managing Contaminated Sediments. IG Report No. 2006-P-00016. March 15, 2006 ( http://www.epa.gov/oig/reports/2006/20060315-2006-P-00016.pdf) - P 1. contaminated sediments is a health problem. P.12. measures demonstrate progress toward LT goals. Pp. 13-14. Superfund and lack of coordination aren't enough; however, EPA cannot assure that resources it expends on contaminated sediments provide the most effective and efficient solutions. p 14. Watershed approach would help.