Great Lakes Federal Interagency Task Force Comments on the GLRC
Draft Strategy to Restore and Protect the Great Lakes
General Comments

The draft Strategy provides a detailed inventory of actions that might be taken to
address one or more of the eight priority issues outlined in the Framework
adopted by the Regional Collaboration. However, the draft Strategy does not
contain the complete set of information required for decision makers to prioritize
actions, justify resources, and formulate an implementation plan, such as:
- comparisons and evaluations of alternative actions;
- detailed cost and benefit data to support selected actions;
- integration of the proposed actions to assure compatibility;
- spatial, temporal, and other factors that influence scheduling of actions,
and;
- metrics for measuring progress.
While it is not expected that the Strategy would include all this information, it is
recommended that the final Strategy describe a process for developing it.

Many chapters recommend responsibilities, activities and funds be assigned to
certain federal departments or agencies, in some cases to the exclusion of other
federal agencies that have relevant programs. This includes activities such as
research and monitoring (e.g., recommendation 3 in the Coastal Health section),
sediment remediation (e.g. recommendation 1), nonpoint sources (e.g.
recommendation 1) and coastal health, where others have a clear role. In areas
where there is a federal role, the IATF recommends emphasizing federal
collaboration, and replacing references to specific federal agencies with
“(appropriate) federal agencies.”

In numerous places in the draft Strategy (e.g. pages 4, 10, 17, and 22) there appear
to be editorial comments and the use of dramatic language to describe current
conditions. The ultimate success of the Strategy in guiding the restoration and
protection of the Great Lakes will require that the final Strategy reflect best
available scientific information and provide measured, contextual commentary.
The final document should be edited to present factual statements backed by
science and data about current or potential conditions of the Great Lakes.

The draft Strategy does not emphasize the important role that ground water plays
in maintaining the health of the Great Lakes. A 2000 report from the USGS
http://water.usgs.gov/ogw/pubs/WRI004008/WRIR_00-4008.pdf estimated that
ground water directly or indirectly contributed 80 percent of the flow into Lake
Michigan. There are significant issues in the basin related to overuse of ground
water and how it affects in-stream flows for waterbodies in the watershed and the
lakes themselves. The report should also stress the importance of protecting
ground water sources from contamination.

All of the key issue areas have aspects that overlap with other chapters.
Recommend that these linkages are more clearly acknowledged and illustrated,
perhaps by providing crosswalks between relevant sections.

The draft Strategy should place more emphasis on leveraging voluntary and
environmental stewardship actions to meet the goals. The document appears to
focus heavily on regulatory solutions and additional funding and incentives.
Though voluntary efforts are mentioned as a resource, the Strategy should rely
more heavily on the role that individual, corporate and community stewardship
efforts could play in achieving results.

The draft Strategy should place more emphasis on pollution prevention and
energy efficiency (P2/E2) approaches to obtain results and to maintain progress
made through restoration and other activities proposed in the document. The
Strategy proposes to enhance P2/E2 to reduce and prevent waste and pollution
and recognizes the need for P2/E2 technical assistance and tools and incentives.
However, relative to other actions proposed in the Strategy, more emphasis
should be placed on promoting and integrating P2/E2 solutions.

Forecasting of issues such as aquatic nuisance species and human health is
important and needs more recognition. Recommend emphasizing “forecasting”
within the bulk of the document and not just in the Indicators and Information
section at the end. Wherever “assessment” or “monitoring” appear, add
“forecast”. There are a few instances where this is done but it is not universal in
the document. For example:



page 10 (Under Aquatic Invasive Species) (III 1), bullet 3' "Immediate
requirement for monitoring*, forecasting*, reporting and public
dissemination...."
page 11 (also under Aquatic Invasive Species) (2), bullet 7:
"...implementation of AIS monitoring *and forecasting* plans....."
page 23 (Under Coastal Health) Section 2) new bullet after "Research", to
include the concept "Forecast beach closures"
Specific Strategy Team Comments
Aquatic Invasive Species

There is concern over the specific support cited for one particular bill on this
subject (S. 770). The IATF recommends that the team identify issues or subject
areas which would need to be addressed in any legislation intended to improve
upon the existing statutory framework.

The IATF does not support the section of Recommendation #1 that seems to
suggest “use of the Clean Water Act discharge permits” to hasten the
development of ship-board treatment systems. The use of Clean Water Act
discharge permits to regulate mobile sources such as vessels engaged in
international or interstate voyages is inconsistent with existing Clean Water Act
regulations, and is not considered by the Administration to be the most effective
method for dealing with the invasive species issue.

Regional coordination efforts should be better emphasized within the goals and
milestones. How will activities addressing coordinated data management and
overall coordination through the National Invasive Species Council relate to data
management and integrated management/interagency efforts and regional forums
that are already in place?
Habitat/Species

Coordination efforts within and between the habitat areas and associated
restoration goals could be strengthened.
Coastal Health

Urban nonpoint source pollution did not receive enough direct attention in this
section, which mentioned the issue, but largely in the context of reducing bacterial
loading. The draft Strategy should recommend implementing best management
practices to reduce the amount of nonpoint source pollution before it reaches
sewage systems.

The section places great emphasis on water quality and monitoring. Recommend
that the section better address the modeling and prediction aspects of coastal
health.
Areas of Concern/Sediments

This section is very focused on sediment remediation even though the AOCs, by
definition, have 14 equally important human use impairments such as eating fish,
drinking water and swimming; and ecological impacts such as loss of diversity in
aquatic life and destruction of fish and wildlife habitat. Recommend that this
section present a wider range of activities and a more balanced discussion of other
impaired uses in AOCs. This could be accomplished by describing how other
sections of the document relate to or complement the AOCs.

This chapter does not acknowledge the Corps of Engineers’ Great Lakes
Remedial Action Plan and Sediment Remediation program as an existing
authority that has provided technical assistance to RAP groups and states for
planning and design of sediment cleanup and other projects related to AOC
delisting.

This chapter should acknowledge the importance of collaborating with the
Superfund program, particularly the importance of Superfund's “polluter pays”
principle, while pursuing remediation and restoration of contaminated sediment
sites within the Great Lakes Areas of Concern (AOCs) under the Clean Water
Act.
Nonpoint Source

Urban nonpoint source pollution should receive more direct attention in this
section, which focuses more heavily on agricultural sources. Include a discussion
of the role of land use, pervious pavement/surfaces, stormwater wetlands, and
other run-off management approaches.

Though funding is one of the three listed fundamental barriers to addressing
nonpoint source pollution, the other two (authority and coordination) should be
more thoroughly addressed in the recommendations.
Toxic Pollutants

Consider creating a stronger link to the AOC/Sediments and Coastal Health
sections.
Indicators & Information

In addition to the discussion of open water monitoring, there is a need for greater
discussion of management indicators relevant to environmental programs
operating within the basin.

The recommended activities in Global Earth Observing System of Systems and
the Integrated Ocean Observing System should mesh with regional monitoring
activities already taking place in the Great Lakes region.
Sustainable Development

Describe how other sections of the document are supportive of a sustainable
development approach. Indicate that this section builds on actions in other
sections.
Members of the Great Lakes Federal Interagency Task Force
Stephen Johnson (Chair)
Administrator
U.S. Environmental Protection Agency
John P. Woodley
Principal Deputy Assistant Secretary of the Army for Civil Works
Department of the Army
Rear Adm. Thomas Gilmour
Assistant Commandant for Marine Safety, Security and Environmental Protection
U.S. Coast Guard
Conrad C. Lautenbacher
Undersecretary of Commerce for Oceans and Atmosphere
Department of Commerce
Merlyn Carlson
Deputy Undersecretary for Natural Resources and Environment
U.S. Department of Agriculture
Paul Hoffman
Deputy Assistant Secretary for Fish and Wildlife and Parks
Department of the Interior
Roy Bernardi
Deputy Secretary
Department of Housing and Urban Development
Anthony Rock
Assistant Secretary for Oceans and International Environmental and Scientific Affairs
U.S. Department of State
Jeff Shane
Undersecretary for Policy
Department of Transportation
Jim Connaughton
Chairman
Council on Environmental Quality