Major Obstacles to Implementation

The seven examples provided showcase successful concepts, techniques and institutional characteristics that have furthered action toward remediation and have created community momentum in their Areas of Concern. The examples also illustrate the importance of examining different strategies that work and apply them in other AOCs. During the past several years of reviewing RAPs and assisting in their planning, IJC has found several common reasons as to why remedial programs in a number of AOCs have been stalled.

Lack of Planning for Implementation of "Big Ticket" Remedial Measures

In many AOCs, planning for implementation has not included the steps needed to quantify the cost of potential remedial options nor identify possible methods of financing "big ticket" remedial measures. These measures, often for the treatment or removal of contaminated sediment or sewerage infrastructure improvements, can cost millions and sometimes billions of dollars. There are several shortcomings to this major flaw in planning.

This last shortcoming can result in special challenges for funding comprehensive remediation in AOCs with contaminated sediment located outside targeted contaminated sites. In addition, some jurisdictions have initiated habitat enhancement projects in AOCs before the removal or treatment of contaminated sediment, which occurred in the Hamilton Harbor AOC. This practice can result in greater fish or wildlife utilization of a contaminated habitat. In AOCs, such as the Detroit River, lack of planning for sediment remediation has meant that no government financed remediation of sediment has occurred. Thus, it has been estimated that the cleanup of contaminated sediment in the Detroit River AOC could take at least 40 years.

Reductions in Government Support with No Associated Increase in Local Capacity

Reductions in government funding and staffing for AOC restoration activities are almost universal throughout the Great Lakes basin. Many cutbacks have occurred with little notice and no publicity. This manner of downloading expensive and complex activities on communities has resulted in considerable frustration at the local level and a resultant decline in activity in many affected AOCs. The failure to build the local capacity to assume tasks related to remediation prior to the cutbacks has led to a "sink or swim" challenge, especially for the more marginal RAP efforts. Some public advisory committees struggle to cover day-to-day expenses while others aggressively seek donations and grants.

The status of some efforts remains unclear. For example, the province of Ontario proposed utilizing a natural regeneration stage to restore certain areas of contaminated sediment once source controls had been initiated. At one time, representatives of Ontario public advisory committees considered possibly redesignating these AOCs as Areas of Recovery or Areas of Restoration. However, in September 1997, they unanimously passed a resolution stating that AOCs should not be renamed or redesignated until after all beneficial uses have been restored. Lack of funding appears to be the driving force behind suggested changes of this nature.

Attempted downloading of financial and organizational responsibilities appears to contribute to citizen frustration regarding the lack of progress in some AOCs. Citizens in some AOCs note that they have devoted years to working with government agencies toward the goal of remediation only to be informed recently that cleanup efforts are regarded as purely local problems. Having bought into what they perceived to be a government process, they were informed that they own the process and problem, even though the local community cannot afford to address them on its own. Except for a very few instances, most planning efforts for restoration of AOCs appear to have overlooked two of the most elementary questions regarding water resources planning: what are the various alternatives for possible implementation and what are the costs and benefits of each alternative?

Funding for restoration of AOCs has received limited attention as a principal concern for implementing agencies in the Great Lakes basin. Far too little effort has gone into determining the highest priority remedial activities and pursuing necessary funding to finance their implementation. Necessary funding for optimal remediation appears to be increasing, perhaps due to better quantification of costs. An increasing number of remedial activities have yet to be funded and implementation budgets are under continued pressure as available funding appears to be shrinking.

Lack of continuity in staffing for AOCs is a common problem related to funding cutbacks. It has been difficult to locate and contact the appropriate agency staff member in regard to some AOCs. Changes in responsible persons are often not well publicized and some AOCs have contact persons located in distant locations.

Sizable reductions in the government spending and staffing have occurred with no corresponding increases in funding and staffing from other sources. AOCs that have seen some increases in grant funding or partnership arrangements appear to have extraordinary local leadership or are recipient of short term funding designed not for implementation activities but for staff support. Technical support is often being supplied from distant locations with little "hands-on" expertise being made available to public advisory committees and local jurisdictions. Information gathered so far in IJCs Status Assessments clearly shows the strong desirability of stable, locally-based agency support.

Failure to Set Priorities Within and Between AOCs

Prioritization between individual remedial options and between AOCs appears to be ad hoc. The activity lacks transparency. It also appears that binational AOCs are not assigned any higher priority for resources than other AOCs. Many binational AOCs have extensive industrial areas and the added challenges of working across an international border as well as the problem of transboundary pollution and a more direct impact immediately downstream. To give an example of what can be done: the state of Illinois has developed transparent prioritization processes to produce greater impact on human health issues and ecosystem protection. Therefore, the Illinois Environmental Protection Agency developed a framework to direct available resources to watersheds where the greatest environmental benefit can be realized. This framework has been developed into a report format and is available via the Internet. While this effort is a statewide program, the approach taken by Illinois is both reasonable and commendable and similar criteria could be developed by jurisdictions to target actions within and between AOCs.

The current level of financial and staffing commitment in most AOCs is not sufficient to adequately address existing environmental problems. In some AOCs, environmental problems are still not well quantified. Consequently, total costs for remediation have not been determined. The current level of government support to AOC restoration is not expected to increase and in fact may decrease in the future. Accordingly, greater need for prioritization both within and between AOCs is crucial. Few AOCs have set priorities between competing environmental problems. Effort is often devoted to problems that appear to be the readily funded rather than the problems that result in the greatest environmental harm. Recent information regarding human health effects (Johnson et al. 1997, Lonky et al. 1996) confirms the need to fully address the problem of persistent toxic substances as a high priority.

Public Participation

In an era of many competing messages, intensive and perhaps expensive media campaigns are needed to reach and inform audiences of even popular themes, such as environmental restoration efforts. Little effort has been devoted toward the use of mass media, particularly in the more urbanized AOCs. Many of these areas have substantial resources and talent in the fields of television and radio. The use of public service announcements, broadcast at no-cost, presents a useful opportunity to reach segments of the population difficult to access.

Information Transfer

The transfer of information and technology between AOCs appears to be random and infrequent. Considerable new information, associated particularly with human health effects and sediment remediation, is available but apparently is not distributed to the AOC communities in any systematic fashion. Innovative use of existing information technology has the potential to assist n providing rapid transfer of information and technology to AOC teams that are seeking such assistance. U.S. EPAs web site provides resources for nonprofit organizations and is a notable example of the type of product that can be provided. This web site provides easy access to environmental and health information. Its address is http://www.epa.gov/epahome/nonprof.htm(.)

Failure to Quantify Benefits of Remediation, Particularly Regarding Human Health

Information regarding the benefits derived from remedial activities is not widely distributed to AOCs throughout the basin. Environment Canada has undertaken studies quantifying the economic benefits, but little information regarding the human health benefits particularly in regard to the remediation of contaminated sediment is readily available within the various AOCs. Human health concerns related to in situ persistent toxic substances have led to a notable AOC success story regarding the cleanup of contaminated sediment in Waukegan Harbor. This AOC, just north of Chicago, Illinois, is a significant "beacon" for success in regard to the cleanup of polychlorinated biphenyls (PCBs). Dredging to remove PCB contaminated sediment began in 1991 and in February 1997, signs warning of a localized fish advisory due to contaminant sources within the harbor were removed.

Since sediment in many AOCs is significantly contaminated with persistent toxic substances, the benefits of successful restorations, such as in Waukegan Harbor, should be better documented by the implementing agencies. This is especially important regarding human health benefits because cleanup costs for other AOCs might be regarded as excessive by some unless tangible human health benefits are emphasized.