Great Lakes Report to Congress 1994
REPORT TO CONGRESS ON
THE GREAT LAKES ECOSYSTEM
Chapter 3
The Great Lakes Program: A Holistic Ecosystem Approach
This chapter presents the holistic approach to ecosystem protection that EPA has launched to address
Great Lakes environmental problems. Under this approach, the Agency began to develop a joint five year
strategy among the different agencies involved in protection of the Lakes, rank ecological and human
health risks facing the region, promote pollution prevention as the preferred means to reduce risks from
contaminants, target priority geographic areas, meet local needs with a blend of solutions from across
the range of environmental programs, enforce environmental laws in a comprehensive, integrated manner,
encourage public participation, and evaluate progress using ecological indicators. In all these
elements, the Agency is taking advantage of every opportunity for cooperative actions with States,
partner Federal agencies and Canada.
EPA has successfully used many individual elements of this approach in the past. The fundamental changes
now being pioneered for the Great Lakes ale to promote innovative pollution prevention measures, enforce
environmental laws in a comprehensive way while focusing on targeted geographic areas, harness local
community participation in the remedial planning process, and integrate the Agency's programs around the
ecosystem, setting goals on the basis of environmental needs and measuring progress with ecological
yardsticks.
This innovative approach is consistent with, and enhances implementation of, the Great Lakes Water
Quality Agreement between the United States and Canada. Under this Agreement, the two nations have
dedicated themselves to restoring and maintaining the chemical, physical, and biological integrity of
the Great Lakes ecosystem by virtually eliminating releases of bioaccumulative toxic substances to the
Lakes. EPA's new ways of doing business are aimed at fuller achievement of the Agreement.
In 1991, EPA joined States and Federal agencies that have stewardship responsibilities for the Lakes in
developing a shared five year strategy that started in 1992. In addition to the eight Great Lakes
States, partners to the plan include the Army Corps of Engineers, the Coast Guard, the Fish and Wildlife
Service, the National Oceanic and Atmospheric Administration, and the Soil Conservation Service. The
strategy joins environmental protection agencies with natural resource agencies in pursuit of common
goals. These partners envision updates that will keep the strategy a current, action-forcing document
that targets different problems in succession.
The ultimate purpose of the strategy is that of the Great Lakes Water Quality Agreement--to restore and
maintain the chemical, physical, and biological integrity of the Great Lakes ecosystem. To realize this
purpose, the strategy has three long-term goals:
- Reduce Toxic Loadings: Prevent and reduce releases of toxic pollutants and remedy past contamination
with an emphasis on bioaccumulative pollutants
- Protect and Restore Habitat: Protect and restore wetland, land, and aquatic habitats vital for healthy
communities of plants and animals, emphasizing the habitat needs of threaten species
- Protect the Health of Human Residents and the Ecosystem's Living Resources: Protect the health of
human residents of the region from pathogens and protect the abundance and biological diversity of its
plant and animal communities.
The strategy relies on pollution prevention as the preferred means to reduce releases of toxic
substances. While the partners to the strategy recognize that full attainment of its goals is a long-
term proposition, the strategy spells-out numerous practical steps to make progress toward these goals.
The partners envision that their ultimate attainment will provide an ecosystem in which fish are safe
for human consumption in unlimited quantities and there are thriving populations of vulnerable species,
such as bald eagle and lake trout.
During 1991, EPA conducted a comparative, risk-based characterization of human health and ecological
hazards facing the Great Lakes region. The study looked at evidence on 23 different problems. It helped
EPA and its partners identify priority problems and the best opportunities for making environmental
progress. Among its findings, the comparative risk study concluded that the the Greatest ecological
risks are the following:
- Bioaccumulative toxic substances that cause health problems for fish and wildlife
- Bottom sediments that harbor such contaminants and that contribute to poisoning the food web
- Water runoff from agricultural and urban lands that carries pesticides and other pollutants
- Industrial and municipal discharges to surface water
- The possibility of large accidental spills of toxic substances
- Introduction of exotic species, such as the zebra mussel, that can greatly affect the balance between existing species
- Destruction of valuable wildlife habitats, such as fish spawning areas, wetlands, prairies, and old growth forests, by agricultural, residential, and other development activities
- Atmospheric deposition of sulfur oxide, nitrogen oxide, and mercury which affect inland lakes
- Global climate change.
The study concluded that the following posed the most significant human health risks:
- Consumption of Great Lakes sport fish because of their widespread contamination with PCBs and contamination in certain areas with chlordane, mercury, dioxins, and mirex
- Consumption of sport fish from inland lakes because of their contamination with mercury
- Accidental spills
- Respiratory exposure to toxic air pollutants.
In addition, the study concluded that the most significant sources of environmental contaminants were
concentrated around Chicago, Illinois, and Gary, Indiana; Detroit, Michigan; Buffalo and Niagara Falls,
New York; and Cleveland, Ohio. This information helped the Agency begin to target several of these areas
for reduction of toxic releases and for habitat restoration.
EPA sees the Great Lakes as a proving ground for its pollution prevention efforts. Buttressed by other
Agency activities, pollution prevention is to be the preferred means to reduce toxic pollutants. EPA is
weaving pollution prevention into the fabric of all its Great Lakes activities and encouraging all
sectors of society to contribute their ideas for reducing the quantity and harmfulness of resources used
to satisfy human needs.
In April 1991, in concert with the eight Governors of Great Lakes States, EPA launched a Pollution
Prevention Action Plan for the Lakes. The Action Plan augments State pollution prevention programs.
During recent years, States have started various prevention initiatives, involving education, research,
technical assistance, and recognition of prevention successes. Some States are also exploring ideas such
as issuing one permit to cover all the pollutant releases from a facility as a means to increase
pollution prevention, incorporating pollution prevention into enforcement settlements, and linking
permit fees to the generation of pollution. EPA will continue to work closely with States in support of
their prevention programs.
The Action Plan also complements EPA's national pollution prevention strategy, which includes the 33/50
Program. EPA has identified 17 high risk chemicals that offer strong opportunities for prevention. In
February 1991, EPA announced a goal of encouraging firms across the Nation to cut their releases of
these substances 33 percent by the end of 1992 and 50 percent by the end of 1995. Among the 17 high risk
chemicals are three metals--cadmium, lead, and mercury--that can concentrate at upper levels of an
aquatic food web. Mercury contamination is the basis for the issuance of several Great Lakes fish
advisories.
Large manufacturing firms report their annual releases or transfers of more than 300 toxic substances.
Under the 33/50 Program, EPA has asked firms that have reported releases of the target chemicals to
voluntarily reduce these through pollution prevention. EPA anticipated widespread cooperation because
pollution prevention offers economic benefits to firms. By the end of 1991, the Agency had received
voluntary commitments from companies to cease 280 million pounds of releases of the 17 chemicals by
1995.
Pollution Prevention Action Plan
The Great Lakes Pollution Prevention Action Plan is predicated on challenging all sectors of society;
focusing on high risk pollutants, sources, and areas; and measuring progress. The Plan contains five
elements:
- The Challenge: The Governors challenged all sectors of society to reduce, on a voluntary basis,
releases of pollutants harmful to the Great Lakes.
- Lake Superior: EPA and the Lake Superior States agreed to define procedures to prevent degradation of
this relatively pristine lake, end loadings of bioaccumulative pollutants, and establish air deposition
sites to monitor loadings of air pollution to the Lake.
- Car Manufacturing: EPA and States announced that they would work with the Chrysler, Ford, and General
Motors Corporations to promote prevention of substances that injure the Great Lakes ecosystem. These
companies are joining EPA and States to determine substances of concern, to evaluate which
substances are being used in their operations, and to reduce this use.
- Urban Non-point Pollution: EPA and New York announced that they would co-sponsor education campaigns in
four New York State counties to prevent urban non-point source pollution from households.
- Binational Symposium: In September 1991, EPA co-sponsored with
Environment Canada a symposium to bring together representatives from government, industry, and the
public to share information on pollution prevention.
A hallmark of the ecosystem approach is to focus on priority ecological problems and geographic areas,
though Special Geographic Initiatives and Remedial Action and Lakewide Management Planning.
Special Geographic Initiatives
Under Special Geographic Initiatives, EPA and States focus prevention, inspection, enforcement, and
cleanup efforts on a targeted area. During FY 1992, EPA and States targeted southeast Chicago-northwest
Indiana and the Niagara River watershed because of their high ecological risk and noncompliance with
permits and regulations.
Remedial Action Planning
The United States and Canada have committed to develop and implement plans--termed
Remedial Action Plans
(RAPs)--to restore the most impaired areas around the Great Lakes. In general, these Areas of Concern
are bays, harbors, and river mouths with damaged fish and wildlife populations, contaminated bottom
sediments, and past or continuing loadings of toxic and bacterial pollution. The United States has 31
Areas of Concern, including five shared with Canada. The Remedial Action Planning process defines
ecological problems, identifies appropriate solutions, and measures progress toward ecological goals.
States develop and implement RAPs, drawing on grass-roots collaboration from local communities.
Through 1992, States had completed initial versions of 23 Stage I (problem definition) and 12 Stage II
(remedial action definition) RAPs. RAPs will be updated periodically as the results of preventive and
remedial measures warrant.
Even while RAPs are being developed, EPA and States concurrently take many warranted actions to protect
and restore Areas of Concern. Examples of such actions are summarized in the next chapter.
In further support of RAPs, EPA is continuing its Assessment and Remediation of Contaminated Sediments
(ARCS) program that has assessed contaminated sediment problems and is demonstrating innovative
treatment technologies in five Areas of Concern. ARCS will develop guidance on assessment methods and on
remedial alternatives to assist local decision-makers in addressing contaminated sediment situations
within Areas of Concern. ARCS is also discussed at greater length in the next chapter.
Lakewide Management Planning
The United States and Canada have also committed to develop and implement
Lakewide Management Plans
(LAMPs) to address whole-lake problems that extend beyond Areas of Concern. While EPA has the lead
responsibility within the United States for developing these plans, participation by other Federal
agencies, States, Tribes and local communities is fundamental to their success. A joint Federal-State
policy committee has been established to guide the LAMP process and to incorporate participation by the
public.
During FY 1991, EPA completed LAMPs for the Lakes that have experienced the greatest contamination--
Michigan and Ontario. The early objectives of LAMPs are to identify key pollutants and their sources and
to schedule reduction measures. In FY 1992, the Agency began working with partners on a LAMP for Lake
Superior; plans for Lakes Erie and Huron will follow.
To implement geographic targeting, EPA and States apply appropriate measures from their full range of
programs--air, land, and water. This section discusses some of these programs and their application to
the Great Lakes.
Air Programs
Since the discovery of polychlorinated biphenyls (PCBs) and other bioaccumulative toxicants on remote
Isle Royale in Lake Superior in the late 1970s, the Great Lakes scientific community has been aware of
the potential importance of the atmosphere as a pollution pathway. Researchers theorized that this
contamination could only have resulted from atmospheric deposition. More recent research has concluded
that the atmosphere is a significant pathway for mercury, which accumulates in fish in some inland
lakes, posing risks to consumers of sport fish.
Under amendments to the Clean Air Act passed in l990, all U.S industrial sources of air pollution must
significantly decrease their emissons of 189 different toxic pollutants over a ten year period. In
addition, EPA and Canada have recently established stations on each of the Great Lakes to begin routine
monitoring of toxicants. And during 1994, EPA will complete its first report on the extent, sources and
effects of atmospheric deposition to selected water bodies, including the Great Lakes.
Land Programs
Under the Superfund Program, EPA and States address abandoned and uncontrolled hazardous waste sites
that endanger public health, welfare, or the environment. Currently, about 140 NPL sites in the Great
Lakes watershed are targeted by Superfund for permanent cleanup; 25 of these are vital to restoration of
14 Areas of Concern. For instance, the Superfund Program is addressing the site of greatest PCB
contamination in the Great Lakes--Waukegan Harbor, Illinois. Through 1993, one million pounds of PCBs in
and around this harbor are being removed, treated, burned, or isolated.
Whereas Superfund generally addresses past contamination, the
Resource Conservation and Recovery Act
(RCRA) regulates today's management of hazardous wastes, from generation through disposal. Facilities
that treat, store, or dispose of hazardous waste must obtain permits that set forth management standards
and closure requirements. If contamination is suspected at a RCRA-regulated facility, EPA or States may
require the facility to conduct an investigation and correct any problems. Inspections of RCRA-regulated
facilities are an important element of Special Geographic Initiatives. In the past several years, EPA
and States have required RCRA-regulated facilities to conduct investigations and take corrective
measures in five Great Lakes Areas of Concern. EPA has also issued regulations for onshore and offshore
oil facilities to prevent accidental spill of oil. These regulations require such facilities to follow
Spill Prevention Control an Countermeasures (SPCC) Plans, which are subject to EPA inspection. During
1991, EPA planned 182 SPCC inspections within the Great Lakes watershed and completed 196, almost triple
the number conducted in 1990.
Water Programs
A discharge of pollutants into the surface waters of the United States is regulated by a
National
Pollutant Discharge Elimination System (NPDES) permit issued by EPA or a State. Permits limit the
discharge of contaminants and establish treatment performance requirements for industrial and municipal
wastewater. There are about 600 major and 3,000 minor NPDES dischargers in the Great Lakes watershed.
Two principles govern NPDES permits. The first principle is that dischargers meet technology-based
treatment standards by industrial category. The second is that more stringent limits are imposed to
protect water quality where technology-based limits prove insufficient to maintain designated water
quality. Through water quality standards, States define the chemical and biological conditions necessary
to maintain water quality. To assist States in establishing these standards, EPA prepares criteria to
define the maximum allowable concentrations of pollutants that are acceptable for human health and
aquatic life, based on scientific evidence.
In 1989, EPA and States began a "Great Lakes Water Quality Initiative" to develop binding guidance for
States on water quality criteria for the Great Lakes, implementation procedures, and anti-degradation
policy. EPA published this proposed guidance in April 1993. Implementation of the guidance will fulfill
several purposes. It will ensure that Great Lakes environmental needs are fully incorporated into State
water quality programs, which will provide a sound scientific basis for water quality-based protection
of the Lakes. It will also promote consistency among States in their standards and implementation
procedures for the Lakes, and serve as the basis for agreeing with Canada on chemical specific
objectives for the Great Lakes.
Other water programs also benefit the Great Lakes ecosystem. For example, one program addresses
contaminated storm water (rainwater runoff). Before entering a sewer, rain runoff can collect soil-
surface contaminants that are then funneled into receiving surface waters by storm sewers. Following a
rule that EPA issued in 1990, large cities and certain industries are curtailing discharges of
contaminated storm water, subject to the terms of NPDES permits, which emphasize management practices
and pollutant monitoring.
Particularly in older urban areas, storm water and household wastewater are delivered to municipal
wastewater treatment facilities via combined sewers. During rainstorms, increased flow can exceed either
a facility's treatment capacity or the carrying capacity of a sewer, leading to the release of untreated
wastewater. The significance of combined sewer overflows (CSOs) varies around the Great Lakes. Michigan
reports that CSOs are a major cause of impairments to its rivers, including the Rouge River, which
receives an estimated 7.8 billion gallons of untreated water each year as it flows through
metropolitan Detroit. States with such problems are pursuing strategies to control CSO releases to meet
their water quality standards. In some areas, these strategies entail major capital investments, such as
sewer separation and tunnels or basins to store untreated water. It is expected that, together, the
storm water and CSO control programs will significantly reduce wet weather loadings of pollutants to the
Great Lakes, especially around urban areas.
During the last two decades, EPA, States, and municipalities have made a concerted investment to improve
municipal wastewater treatment. As a result, 95 percent of U.S. treatment facilities in the region now
provide at least "secondary" treatment. Remaining jurisdictions are following schedules to achieve this
treatment level and continue to improve their facilities.
The Clean Water Act also requires certain industries to "pretreat" toxic discharges to municipal
treatment systems. Approximately 170 major municipal dischargers on the U.S. side of the Great Lakes
have industrial pretreatment programs that are subject to regular inspections by EPA and States.
Implementation of pretreatment requirements has effected sharp reductions in contaminant inflows to many
facilities.
EPA jointly administers the principal Federal regulatory program to protect wetlands with the Army Corps
of Engineers. This program issues permits to regulate the discharge of dredge or fill materials into
water, including wetlands. The Agency seeks to prevent a net loss of wetlands on national basis in the
short term and to increase the quantity and quality of wetlands in the long term. EPA also joins States
in identifying high value wetlands in order to give advance notification to landowners prior to permit
applications.
In addition, the Agency has made the Great Lakes watershed a priority in its support to State nonpoint
source control programs, including education and incentive programs to abate runoff of pesticides,
fertilizers, and animal wastes from farmland and others to prevent urban runoff of wastes from homes
and industries.
EPA and States are encouraging public involvement in their activities and promoting public stewardship
of the Lakes:
- Local community "stakeholders" are strongly involved in Remedial Action Planning, helping governments
be more responsive to local concerns.
- Representatives from environmental groups, business associations, and municipalities were invited to
comment during development of guidance under the Water Quality Initiative.
- In 1991, EPA put into service a state-of-the-art research vessel that will also serve as an
educational platform. Tours for the public, including school children, will promote broader awareness of
Great Lakes environmental issues.
- EPA's Assessment and Remediation of Contaminated Sediments (ARCS) program to test innovative remedial
technologies for sediment contamination has held public meetings to inform residents living near the arreas of study.
To ensure that their decisions are based on the best current scientific information, the Agency and its
partners are working to improve their measurement of the health of the Great Lakes ecosystem and to
sharpen their integration and analysis of environmental data. In the past, EPA has often relied on
administrative statistics, such as numbers of permits, grants, and enforcement actions, as surrogate
measures of effectiveness. In the future, the Agency will increasingly assess environmental progress by
monitoring water, land, and air conditions and by monitoring biological responses of plants and animals
to these conditions. Biological measures of well-being could include the balance between pollution-
tolerant and pollution-sensitive species, or the balance between algae-grazing and predator fish. The
foundation of the Agency's strengthened monitoring effort will be the
Environmental Monitoring and
Assessment Program (EMAP), which is a national program that gauges the health of our Nation's
ecosystems. One ecosystem that EMAP will study will be the Great Lakes.
Recently, the following steps have been taken to assess the health of the Great Lakes:
- In 1991, EPA put into service a new 180 foot long research vessel, the Lake Guardian. This ship can
sample water quality to the deepest depths of the Great Lakes and bottom sediments to a depth of 40
feet. The ship was named through a contest among elementary school students around the Great Lakes.
- Since 1989, EPA has sponsored a major study and demonstration program--the ARCS program--to assess
contaminated Great Lakes bottom sediments, test promising remedial technologies, and develop guidance on
addressing such contamination. Through 1992, EPA had assessed five Areas of Concern, identified
treatment technologies to be tested at each, and demonstrated these in the field.
- In 1991, EPA established three master stations to monitor atmospheric deposition of toxic
contaminants. Between them, the United States and Canada now have one master station on each of the
Great Lakes.
- During 1992, EPA, Wisconsin, and partners concluded analytic aspects of their study of the sources,
paths, and fates of several toxicants in Green Bay. The study has provided valuable lessons for whole-
lake analyses in support of LAMPs.
- As part of the LAMP processes, ecosystem objectives are being developed for each of the Lakes.
- EPA, the Fish and Wildlife Service, and States continue to monitor targeted toxic contaminants across
several fish and wildlife species.
- In 1992, EPA bought a high performance computer that will be placed in Bay City, Michigan, for
modelling of the Great Lakes, including hydrodynamic processes, air deposition, pollutant loadings, and
sedimentation. This will be an early step toward establishing an environmental center at the head of
Saginaw Bay that will be dedicated to scientific study of the Lakes.
- EPA is also working to strengthen its integration and analysis of environmental data on the Great Lakes.
Through its various programs, the Agency collects data on air and water pollution, hazardous waste
sites, pesticides, drinking water, radiation, and the health effects of pollutants. Much of this
information is obtained pursuant to separate laws and is narrowly focused to serve these mandates. In
general, it is difficult to integrate these data to obtain a comprehensive view of total pollutant
releases by a facility and surrounding ecological conditions. Such an overview would assist
decisionmaking for permits and enforcement. Accordingly, the Agency is working to increase the
availability of environmental data to support decisionmaking by Federal, State, and local governments
aand to make information more accessible to the public.
EPA and States are taking advantage of all opportunities to work with their counterparts in Canada.
Canadian representatives have been invited to ARCS program meetings to keep apprised of U.S. findings
regarding technologies to address contaminated sediments. Canadian observers have also been invited to
attend meetings concerning the Water Quality Initiative. In addition, EPA and States are working with
Canadian counterparts on RAPs for shared Areas of Concern and on LAMPs for shared Lakes. The two nations
are also sponsoring joint activities, such as the symposium on pollution prevention and their binational
Lake Superior Initiative, mentioned previously.