Healing Our Waters-Great Lakes Coalition July 29, 2014 The Honorable Gina McCarthy Administrator, Environmental Protection Agency Chair, Federal Great Lakes Interagency Task Force U.S. Environmental Protection Agency Washington, DC 20460 Re: Comments on the Great Lakes Restoration Initiative Action Plan II Draft Dear Administrator McCarthy: On behalf of our over 115 member organizations, the Healing Our Waters-Great Lakes (HOW) Coalition would like to thank the federal agencies responsible for the implementation of the Great Lakes Restoration Initiative (GLRI) for your exhaustive work to build a strong, healthy program that is steadily producing results across the Great Lakes region. EPA and the Interagency Task Force have listened to the needs of the region, investing in top priorities in targeted geographical areas to clean up Areas of Concern, and reduce runoff causing toxic algae blooms. Great Lakes restoration efforts are improving the lives of millions of people and work is continuing on projects throughout the region that will restore the Great Lakes and address the most urgent problems facing them. These projects are cleaning up drinking water flowing to millions of homes and thousands of industries and improving infrastructure important for future economic growth in the eight-state region of Minnesota, Wisconsin, Illinois, Indiana, Michigan, Ohio, Pennsylvania and New York. These projects are delivering results throughout, including fish and wildlife returning to places after decades-long absences; businesses emerging and thriving on restored waterfronts; and people fishing, kayaking, and swimming in restored waterways. Our comments below are in response to the request from the Federal Great Lakes Interagency Task Force for stakeholder views on the draft GLRI Action Plan II that was released to the public on May 30, 2014. Comments First, we continue to believe that the investments of the GLRI must not be undermined by poor policy choices made as part of any regulatory process. Congress has graciously provided more than $1.6 billion for over 2,000 projects to clean up toxic hot spots, restore wildlife habitat, and keep beaches open, among many other important activities. Policy choices on a range of activities can either support or undercut restoration progress made under the GLRI, speed up or delay results, and lead to efficient or inefficient uses of the limited resources entrusted to the region. For example, EPA’s proposed rule clarifying jurisdiction of the Clean Water Act, which we support, can benefit the water quality in the lakes, but only if the rule is not weakened when finalized. Continuing to dispose of dredge material in the open waters of Lake Erie can undermine attempts to end algal blooms there. Unchecked energy development can lead to water impairments that reverse water quality or habitat improvements. Inadequate ballast water regulations could lead to new aquatic invasive species, dealing a blow to the ongoing work of managing and controlling impacts from existing invasive species throughout the region. We encourage the Federal Interagency Task Force to not ignore these issues and to view them as part of the restoration agenda. We HOW Coalition: Comments on Draft GLRI Action Plan, FY2015-FY2019 Page 2 of 5 continue to urge the Task Force to describe how it intends to enhance rather than undermine GLRI investments through policy decisions as part of the new updated plan. Second, while we appreciate the attempt at making the plan more user friendly and better designed, we believe important information was lost. The first action plan included a problem statement in each focus area before describing that area’s long-term goals and objectives. We do not believe that the new action plan must provide a recitation of all the problems facing the Great Lakes. However, we believe it is important for the updated plan to 1) describe what actions were taken in the first five years (which this plan does well), 2) describe the impacts those actions have had on the problems the Great Lakes face, and 3) explain why the actions being proposed under the new action plan will address these existing or new problems facing the Great Lakes. We hope the new action plan can be updated to reflect this outline. In addition, the first action plan did a poor job of integrating what we know to be the impacts of climate change on the Great Lakes system. Providing the overview we suggest above allows the new action plan to better describe how climate change will exacerbate the problems each focus area is attempting to address. We want to see this discussion in each focus area and not isolated to the discussion of cross-cutting issues. Third, we think the new action plan should better describe how the work to be undertaken under the new action plan will help the United States meet its obligations under the Great Lakes Water Quality Agreement. The region is coordinating its work among various plans, and the last action plan did a decent job at integrating all these plans through the implementation of GLRI grants. The GLWQA remains detached, however, from this action plan. We see the GLRI as the United States’ commitment to achieving the shared objectives under the GLWQA and believe the new action plan should provide clearer linkages towards its implementation. This is especially true for the new action plan’s measures of progress, which we address below. Fourth, we are pleased to see the incorporation of a science-based adaptive management framework into the draft action plan. Such a framework can potentially be used not only in prioritizing areas and problems, but also in assessing progress (both in aggregate and project level, and as part of an iterative process to improve restoration outcomes). However we still believe improvements are warranted in developing and implementing such a framework: The plan should clarify whether there will be a separate implementation plan for the adaptive management framework (or whether this will be incorporated into an annual planning document). Creating a specific plan will provide greater assurance that all key components of the framework are incorporated into program and project implementation and evaluation. The action plan should emphasize more the importance of experimentation and learning in the adaptive management process as applied through the GLRI. This would include a greater emphasis on environmental outcomes (rather than simply activity measures) and more efforts involving user-driven research, monitoring, assessment, and other relevant components. This is a difficult task, but there may be lessons available from outside the basin, including as identified in a National Research Council committee report on Chesapeake Bay restoration (Achieving Nutrient and Sediment Reduction Goals in the Chesapeake Bay: An Evaluation of Program Strategies and Implementation). The importance of monitoring is recognized in the draft action plan (including in specific focus areas and in noting annual Great Lakes monitoring will be conducted). We still believe there should be greater specificity in regards to monitoring, including at the project level. The broad synoptic Great Lakes coastal wetland monitoring project is providing invaluable data on coastal wetlands, but it is important that the framework highlight the importance of ongoing monitoring HOW Coalition: Comments on Draft GLRI Action Plan, FY2015-FY2019 Page 3 of 5 of these important habitats and other key components of the ecosystem. It is also important to recognize that some monitoring efforts may need to be added or modified in order to be optimized to assess restoration success. GLRI funding may need to be available to allow groups implementing on-the-ground projects to assess the outcomes of their projects on the long-term health of the Lakes. At this time, many groups do not have the resources needed to track progress outside of GLRI funding. The draft action plan references seeking input from the Great Lakes Advisory Board (GLAB) and the scientific community, but it is still not clear if there will be any formal mechanisms for funding the requisite science needed to effect solid evaluation of outcomes and implementation of adaptive management. Such mechanisms are needed and should be identified in the action plan. Fifth, in tracking progress, it is obviously necessary to have adequate environmental indicators in place. Within the Great Lakes, we have 20 years of development and implementation of State of the Lakes Ecosystem Conference (SOLEC) indicators, as well as recently recommended International Joint Commission ecosystem indicators. These efforts have shown that development of indicators is not a trivial task with characteristics such as purpose and ability to be communicated effectively among issues to be considered. While we appreciate the challenge faced in trying to determine good, reliable measures of progress, we believe that the draft plan needs to re-evaluate the use of “number of projects” as a measure, which it has used in a number of areas. Counting the number of projects funded with GLRI funds is easy, and we can imagine that the types of projects funded will likely be ones that lead to positive environmental outcomes. However, there is too much uncertainty left in such an approach. Billions of dollars have been entrusted to the region and we want to ensure those resources are well spent towards achieving the ecological responses we all want to see. Therefore, we believe the measures of progress must be linked to quantifiable, numeric ecological goals. This could be as simple as linking the action plan’s measures of progress to appropriate indicators, including indicators that can help identify effectiveness of restoration actions, whether from SOLEC, the IJC (which is our preference), or both. Sixth, the action plan should be clearer on the role of general public and the academic community involvement in the process, including offering more involvement in goal-setting and program development and evaluation (e.g., through the GLAB and otherwise), rather than only emphasizing input and consultation later in the process (e.g., delisting beneficial use impairments in an Area of Concern). Such involvement and broader education on the Great Lakes ecosystem can also help in sustaining interest in and support for restoration efforts, as well as documenting positive environmental outcomes, in particular in cases where response times are longer (again, as noted in the aforementioned Chesapeake Bay report). Similarly, the draft action plan appropriately highlights the importance of environmental education and stewardship. In addition to focusing on educator training, the action plan could highlight the potential for these and other efforts to engage student groups in active involvement (where appropriate) in local restoration efforts, ranging from studying nutrient management in agricultural watersheds to approaches to habitat restoration in more urban areas. Seventh, we like that the action plan continues to stay focused on five areas: cleaning up toxics and Areas of Concern, combating invasive species, promoting nearshore health, restoring wetlands and other habitat, and science-based adaptive management. We also continue to support maintaining a special emphasis on the new action plan’s principal initiatives “Remediate, restore and delist Areas of Concern”, “Control established invasive species”, and “Reduce nutrient loads from agricultural watersheds.” These areas continue to be the biggest sources of stress for the Lakes, contributing to what scientists have described as “ecosystem breakdown…where intensifying levels of stress from a combination of sources have HOW Coalition: Comments on Draft GLRI Action Plan, FY2015-FY2019 Page 4 of 5 overwhelmed the natural processes that normally stabilize and buffer the [Great Lakes] system from permanent change.” (Bails, et.al. 2005) These three priority areas reflect the causes of this ecosystem breakdown because they either represent the severe historic damage caused to the lakes nearshore (AOCs) or the ongoing stresses from human-induced sources (invasive species or nutrient pollution). We believe that it is appropriate for the GLRI to continue prioritizing them, especially since the problems they represent took decades to develop and in many cases will take decades more of focused attention to solve. However, as we have stated before, we provide this caveat: while the special focus on AOCs, nonpoint runoff, and invasive species to date has been important, they are not the only problems or stresses facing the Lakes. We expect the GLRI action plan to fund activities in all areas as a prescription for recovery. We appreciate the opportunity to provide these comments. Please do not hesitate to contact Chad Lord, our Coalition’s policy director, at (202) 454-3385 or [email protected] with questions. Sincerely, Joel Brammeier President Alliance for the Great Lakes Katie Rousseau Director, Clean Water Supply American Rivers Brian Smith Associate Executive Director Citizens Campaign for the Environment Michael Griffin Executive Director County Executives of America Jean Pogge CEO Delta Institute Gildo Tori Director of Public Policy Ducks Unlimited, Great Lakes/Mid-Atlantic Region Howard Lerner Executive Director Environmental Law & Policy Center Jill Ryan Executive Director Freshwater Future Mike Strigel Executive Director Gathering Waters Conservancy Mike Leahy Conservation Director Izaak Walton League of America Mark Owens President, Austin Chapter Izaak Walton League of America John Crampton President – Bush Lake Chapter Izaak Walton League of America Jill Crafton Chair, Great Lakes Committee Izaak Walton League of America Ivan J. Hack, Jr. President, Headwaters Chapter Izaak Walton League of America Mark Owens Vice President, Minnesota Division Izaak Walton League of America Sandy Bihn Executive Director Lake Erie Waterkeeper Inc. Nancy G. Brown President League of Women Voter of Ohio HOW Coalition: Comments on Draft GLRI Action Plan, FY2015-FY2019 Page 5 of 5 Jennifer Clark Interim Executive Director Michigan United Conservation Clubs John J. Ropp President/CEO Michigan Wildlife Conservancy Cheryl Nenn Riverkeeper Milwaukee Riverkeeper Scott Strand Executive Director Minnesota Center for Environmental Advocacy Gary Botzek Executive Director Minnesota Conservation Federation Steve Morse Executive Director Minnesota Environmental Partnership Christine Goepfert Acting Regional Director, Midwest Region National Parks Conservation Association Karen Hobbs Senior Policy Analyst Natural Resources Defense Council Andy Buchsbaum Executive Director, Great Lakes Regional Center National Wildlife Federation Kristy Meyer Director of Clean Water Programs Ohio Environmental Council Don Hollister Executive Director Ohio League of Conservation Voters Ray Stewart President Ohio Wetlands Association Irene Senn Coordinator Religious Coalition for the Great Lakes Merritt Frey River Habitat Program Director River Network Nicole Barker Executive Director Save the Dunes Lee Willbanks Executive Director Save the River Suzanne Moynihan, SSND Director The EDGE (Education Dreams for a Green Era) Lisa Brush Executive Director The Stewardship Project Christine Chrissman Executive Director The Watershed Center Grand Traverse Bay Jennifer McKay Policy Specialist Tip of the Mitt Watershed Council Dendra Best WasteWater Education.org Ellen Satterlee CEO Wege Foundation
Posted on: Wed, 06 Aug 2014 19:07:07 +0000
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