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Specific Questions for Stage 1 LaMP Review
Specific Questions for Stage 2 LaMP Review
"Lean and Mean Does Not a Strategy Make"
- Tom Peters
Under the Great Lakes Water Quality Agreement (GLWQA), as revised by Protocol in 1987, the International Joint Commission (Commission or IJC) provides reviews of Remedial Action Plans (RAPs) for each Area of Concern (AOC). The Commission's reviews have found that jurisdictions have done an admirable job of compiling existing environmental information and conducting studies to gather additional data necessary to describe environmental problems in their Stage 1 documents.
One former AOC, Collingwood Harbour, moved through the entire RAP process, and has since been delisted by Canada. Forty-two AOCs remain, for which three Stage 1 RAPs remain to be submitted for Commission review. This includes two separate plans being prepared on each side of the U.S. - Canadian border for the Niagara and St. Lawrence Rivers. Information regarding the status of RAP submissions to the Commission is presented in Figure 1.
The Commission's reviews have also highlighted several topics of interest. Preliminary characterization and remediation initiatives for contaminated sediments have confirmed that this is not only a major remediation challenge, but is the cause of impairment of beneficial uses for RAPs and Lakewide Management Plans (LaMPs). Notable efforts have been undertaken in both countries to quantify the extent of contaminated sediment and to identify or demonstrate options to remediate them. In Canada, the Great Lakes 2000 Cleanup Fund (CuF) has demonstrated 19 innovative technologies for the safe removal, handling and treatment of contaminated sediments. In the U.S., the Assessment and Remediation of Contaminated Sediments (ARCS) Program has conducted bench-scale testing of nine treatment technologies, four of which were then selected for pilot-scale demonstrations. These demonstrations were conducted in the Ashtabula River, Buffalo River, Grand Calumet River/Indiana Harbor Canal, Saginaw River/Bay and Sheboygan River AOCs (U.S. EPA 1994).
Because contaminated sediments influence the levels of contaminants in fish, they play a major role in human health concerns in the Great Lakes basin. Efforts have begun in both countries to better describe human health impacts in AOCs. To date, however, many RAP teams lack access to the expertise necessary to begin addressing human health concerns in their AOCs. This problem was noted in the Commission's Seventh Biennial Report on Great Lakes Water Quality (IJC 1994). Although much of the human health research in the Great Lakes basin, to date, has been targeted toward the consumption of fish, additional research now underway related to other forms of exposure will provide more data for incorporation in the RAP documents. Because much of these data will be available after Stage 2 or even Stage 3 documents have been completed, care needs to be taken to ensure that they complement existing RAPs, rather than as barriers to timely remediation.
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Figure 1.Many jurisdictions are using some form of update to their RAP documents to capture refinements to the problem definition and to report progress as they implement remedial measures. These updates are especially valuable for providing information to the public on topics for which limited information was formerly available, such as contaminated sediment remediation options and effects of contaminants on human health.
The RAP process provides an unique opportunity for local communities to initiate actions with the assistance and support of the federal, state or provincial governments to develop programs and initiatives that solve today's problems while helping each community to achieve its goals for the future. To date, however, only a few AOCs have taken advantage of these unique opportunities. Collingwood Harbour is a prime example of a community maximizing its benefits from such an opportunity.
The Commission completed its review of the Collingwood Harbour Stage 2 and Stage 3 RAPs on August 12, 1994 and September 23, 1994, respectively, and noted several findings which may be of significance to AOCs in the Great Lakes basin. The cooperation between the RAP Team and the Public Advisory Committee (PAC) in the designation of use goals was notable because it provided a united front for working with the community in accomplishing its goals. The RAP Team and PAC gathered input from the general public before attempting to reach consensus on the preferred remedial measures. Pollution prevention activities, including water conservation efforts that targeted the general public in addition to the traditional targets of industrial and municipal dischargers, were also adopted in the implementation strategy for Collingwood Harbour (Collingwood Harbour Action Team 1993). Encouraging water conservation at Collingwood Harbour is an excellent example of adopting a cost-effective remedial option. The RAP Team determined that promoting water conservation could achieve a reduction in phosphorus loading from the wastewater treatment plant at a much lower cost than would upgrades to the plant. As remediation efforts are considered and initiated for expensive environmental problems such as contaminated sediments in complex AOCs such as the Lower Green Bay and Fox River, socio-economic considerations will become major factors influencing the rate and extent of remediation accomplished. Socio-economic considerations will also be vital in the virtual elimination process for certain Critical Pollutants in LaMPs.
While the ready availability of government and private support -- including financial -- at Collingwood Harbour reflect the hard work and dedication of the numerous individuals involved in the effort, their experience make apparent what will be major hurdles in the more complex AOCs, e.g. the Grand Calumet River/Indiana Harbor Canal or the Lower Green Bay and Fox River. Challenges include how to consult with a substantial portion of the concerned public, how to obtain their support for remedial activities, how to obtain financial support needed for remediation efforts and, perhaps most important, how to obtain cost- effective remediation. To place the scale of necessary efforts in proper perspective, consider that approximately 8,000 cubic meters of contaminated sediments were removed from Collingwood Harbour, while there are an estimated seven to nine million cubic meters of sediments containing more than 0.05 mg/kg polychlorinated biphenyls in the Fox River (WDNR 1993), and remedial actions for the Fox River system have been estimated at $1 billion (DePinto 1994). Obviously, potential remediation efforts of this scale require a valid framework to economically evaluate remedial options so they can be easily understood by the public. Perhaps most importantly, with decreased resources available to pay for implementation, such a framework must also provide a method to prioritize implementation efforts between selected remedial options within a AOC and even between AOCs.
These issues, while not explicitly noted in Annex 2 of the GLWQA, have been considered in some AOCs and preliminary actions are being taken. For example, in the Lower Green Bay and Fox River AOC, the Fox River Coalition made up of representatives from municipalities, industry, wastewater treatment facilities and state and local government, was formed in 1992 to develop a plan and timetable for cleanup of contaminated sediments in the Lower Fox River (WDNR 1995). The coalition has concluded that, "Contaminated sediment data available for downstream areas were too large-scale to allow identification of specific areas (for remediation)...The group maintained that it was technically and economically impractical to plan remediation for seven million cubic meters of contaminated sediment without differentiating priority areas." In fact, while the coalition maintains that the total cost of remediation of the entire river should be determined in order to finalize a funding program, local governments maintain that remediation activities should be staggered after completion of the individual projects and monitoring data, which is then used to determine the environmental benefit of each project. Prioritizing efforts and seeking funding to complete projects has been noted by the coalition: "The group recommends creation of a statewide sediment remediation program. Such a program would prioritize projects...The group will seek private and public funding at local, state and federal levels."
Many observations of the Fox River Coalition concerning socio-economic factors of sediment remediation coincide with Commission staff findings as a result of examining planning and implementation activities of various RAP and LaMP efforts. These findings, outlined below, are applicable to LaMPs as well as RAPs.
Numerous individuals throughout the Basin have dedicated countless hours toward remedial activities. The Commission attempts to recognize these individuals and reward their dedication. Some Areas of Concern such as the Grand Calumet River/Indiana Harbor are very complex and require innovative partnerships in order to advance remedial actions.
Photo Captions
Commissioner Susan Bayh and former Commissioner Gordon Walker present Doug Garbutt, Mayor, Town of Collingwood with a certificate recognizing his work toward the remedial action planning process at Collingwood Harbour.
Ed Houghton, Public Advisory Committee Chairperson receiving a certificate of recognition from Commissioner Susan Bayh and Gail Krantzberg, former Coordinator of the Collingwood Harbour Remedial Action Plan receives a certificate from former Commissioner Gordon Walker.
Commissioner Alice Chamberlin and Robert Tolpa, U.S. Environmental Protection Agency, Region V examine conditions at the Grand Calumet River/Indiana Harbor Canal Area of Concern.
Funding for RAPs and LaMPs will always be limited. Therefore, it is critical when developing RAPs and LaMPs to complete incremental and cost-effectiveness analyses. The former involves showing what gains stem from each additional allocation of resources to reduce beneficial use impairment and hence improve water quality, or conversely, what reductions in benefits result from reducing resources devoted to controlling the adverse impacts on beneficial uses. Examination of cost-effectiveness involves determining which actions will most improve beneficial uses per unit of resource input, i.e. which actions provide the most bang for the buck or where the most public good can be done for the least money.
Because funds are limited and will undoubtedly become more limited, it is also critical to establish priorities. Not all beneficial use impairments are necessarily of equal importance. Nor does control of all pollutants have the same urgency. Various criteria can be used to rank environmental stressors, as is being done with the "tiering" of pollutants in the development of LaMPs.
Management in RAPs or LaMPs is a continuous, adaptive process. It takes place in a dynamic context, in terms of : (a) changing demographic and economic conditions; (b) changing demands for outputs, reflecting changing social tastes; (c) changing ecosystems; and (d) changing weather patterns from year to year, and perhaps long-term with changing climatic conditions. A management strategy must take into account:
In March 1995, the Commission conducted a workshop to gather input in the formulation of a series of questions to be used by Commission reviewers in evaluating Stage 1 and Stage 2 LaMPs, and in the evaluation of the designation of Critical Pollutants. These questions are listed below. Questions suitable for use in reviewing Stage 3 and Stage 4 LaMPs are under development.
To ensure that Lakewide Management Plans (LaMPs) at all stages embody a systematic and comprehensive ecosystem approach to restoring and protecting beneficial uses in open lake waters. To ensure that ongoing or planned activities which may influence the chemical, physical and biological integrity of the waters of each lake are adequately described in the respective LaMP for that lake.
Specific Questions for Stage 1 LaMP Review:
Collingwood Harbour Action Team. 1993. Stage 2 Report: Implementation Annex. Toronto, Ontario. 45 pp.
DePinto, J.V. 1994. Role of Mass Balance Modeling in Research and Management of Toxic Chemicals in the Great Lakes: The Green Bay Mass Balance Study. Great Lakes Research Review 1(1):1-8.
International Joint Commission. 1994. Seventh Biennial Report on Great Lakes Water Quality. Windsor, Ontario. 59 pp.
U.S. Environmental Protection Agency. 1994. Assessment and Remediation of Contaminated Sediments (ARCS) Program: Final Summary Report. Chicago, Illinois. 48 pp.
Wisconsin Department of Natural Resources. 1993. Lower Green Bay Remedial Action Plan 1993 Update. Madison, Wisconsin. 241 pp.
Wisconsin Department of Natural Resources. 1995. The Fox River Coalition. Madison, Wisconsin. 24 pp.
Alice Chamberlin
Commissioner, U.S. Section
International Joint Commission
1250 23rd Street N.W., Suite 100
Washington, DC 20440
Gordon W. Walker, Q.C.
Commissioner, Cdn. Section
International Joint Commission
100 Metcalfe St., 18th Floor
Ottawa, Ontario K1P 5M1
Dr. Harold J. Day
College of Environmental Science
University of Wisconsin-Green Bay
2420 Nicolet Drive
Green Bay, Wisconsin 54311-7001
Mr. Doug McTavish, Director
Great Lakes Regional Office
International Joint Commission
100 Ouellette Ave., Eighth Floor
Windsor, Ontario N9A 6T3
Ms. Susan Sylvester
Wisconsin Dept. of Natural Resources
Administrator, AD/5
Division of Environmental Quality
101 S. Webster St.
P.O. Box 7921
Madison, Wisconsin 53707-7921
Mr. E.T. Wagner, P. Eng.
Director, Water and Air Resources
Waterfront Regeneration Trust
207 Queen's Quay West, Ste. 580
Toronto, Ontario M5J 1A7
Staff Coordinators
Dr. Murray Clamen
International Joint Commission
Canadian Section
100 Metcalfe Street, 18th Floor
Ottawa, Ontario K1P 5M1
Mr. James Chandler
International Joint Commission
United States Section
1250 23rd Street N.W., Suite 100
Washington, D.C. 20440
Mr. Bruce Kirschner
International Joint Commission
Great Lakes Regional Office
100 Ouellette Ave., Eighth Floor
Windsor, Ontario N9A 6T3