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Areas of Concern (AoCs)
RESTORING UNITED STATES AREAS OF CONCERN:
DELISTING PRINCIPLES AND GUIDELINES
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INTRODUCTION
Remedial Action Plans (RAPs) for Great Lakes Areas of Concern (AoCs) are perhaps the best example of community-based environmental protection in existence. Through a blend of public and private agencies and organizations, the RAPs continue to be a catalyst to advance the watershed approach for ecosystem remediation and restoration, and they continue to make progress towards the restoration and protection of the all of the forty-two remaining Great Lakes AoCs (see figure 1).
The progress made in the RAP Program has led to the question of how and when to formally delist AoCs as the implementation of all recommended actions for restoring beneficial uses are completed, and as the uses are restored and maintained. The critical test for any such process and associated criteria is to insure that it is rigorous, scientifically defensible, and allows for full review and comment from interested and affected stakeholders. Acting on directions from the United States Policy Committee (USPC), USEPA’s Great Lakes National Program Office (GLNPO) convened the U.S. RAP Workgroup (comprised of representatives from the eight Great Lakes states and other U.S. federal agencies, with observers from the Canadian federal and provincial agencies and the International Joint Commission [IJC]), in order to draft these guidelines.
These guidelines offer various options for showing progress, maintaining momentum, and formal delisting, which a RAP Implementation Group (defined as the state agency responsible for the RAP program and the local public stakeholder group working with the state agency on the RAP) can use as guideposts and tools in their work. It is not envisioned that all parts of the guidelines will be applicable to all the AoCs; rather, those that suit the needs of a particular AoC can be adopted by the RAP Implementation Groups. There will be no sanctions imposed upon a State’s RAP program based on which tools they may choose to use or not use.
Many important issues need to be addressed in order to achieve our shared goal of restoring and maintaining beneficial uses in the AoCs. We must be able to balance our collective desire to clean up and delist AoCs while maintaining the integrity of the RAP program and our role as environmental stewards. This is not meant to temper our push for delisting. Rather, we should view these questions as a sure sign that the U.S. RAP program is making significant progress, which makes the time ripe for addressing delisting related issues.
Appendix 1 provides brief background information on the genesis of the AoC program and Appendix 2 describes the drafting process for this document.